July 19, 2023
Related to proposed rule S7-32-10
The proposed rule does not go far enough in terms of public transparency. In order for markets to be free and fair, impartial and enforced regulation is required. In order for the public to have faith that markets are bing regulated in this manner, data related to matters which require this enforcement, specifically swaps, must be made publicly available. Only requiring swap data when a certain threshold is met, or worse, following Congressional advice and making that data only available to the SEC and hiding from the public entirely, will continue to drive a loss of public faith in the integrity of our markets, both within the US and abroad.
The public and the world are losing faith in our economic system and by extension the US dollar's privileged place as the World Reserve Currency. I urge this commission to take a step back and consider the long term implications of continuing to allow obscuration and obfuscation of data critical to the fair functioning of our markets. If fraud is happening, should the SEC not have the ability to have a full view of its scope? Should the public not have access to this same data to hold the SEC accountable to its duty of enforcement? Should the world not know that our markets are structured in a sustainable and fair way, with transparency as a guiding principle?
If fraud is happening, anything less than full transparency and enforcement is tantamount to aiding and abetting. And if no fraud exists, that same transparency is necessary to regain and maintain confidence in that fact. There is no world where a lack of transparency is the better path forward.
I sincerely hope this commission takes this comment and the many others like it from concerned and informed citizens to heart.
- Louis Knupp