Subject: File No. s7-32-10
From: Puneet Duggal

July 19, 2023

Enhanced Market Transparency: The proposal aims to increase transparency in the financial markets by requiring reporting of large security-based swap positions. Transparency is crucial for investors, regulators, and the public to gain insights into market activities and identify potential risks.

Risk Mitigation: Reporting large positions in security-based swaps enables regulators to monitor and assess systemic risks. By identifying excessive concentrations of risk, regulators can take proactive measures to mitigate potential threats to financial stability.

Preventing Market Manipulation: With comprehensive data on large positions, regulators can better detect and deter market manipulation and abusive trading practices. This safeguards the integrity of the market and ensures fair and orderly trading for all participants.

Informed Regulatory Decisions: By having access to timely and accurate data, regulators can make more informed decisions regarding market oversight and risk management. This data-driven approach helps ensure that regulatory actions are well-targeted and effective.

Strengthening Investor Confidence: Transparent and well-regulated markets instill confidence in investors, encouraging them to participate and invest with greater trust. This can lead to increased market activity and capital flow, benefiting the overall economy.

Systemic Risk Monitoring: The proposal's reporting requirements aid in monitoring potential systemic risks that could impact the broader financial system. This proactive approach can help prevent or minimize the impact of financial crises.

Aligning with Global Standards: Many countries have implemented similar reporting requirements as part of their commitment to international regulatory standards. Supporting the proposal demonstrates a commitment to harmonizing financial regulations across borders.

Support for Regulatory Objectives: The proposal aligns with the broader objectives of financial regulatory reforms, such as those outlined in the Dodd-Frank Act. It reflects a commitment to a safer and more transparent financial system.

Promoting Fair Competition: The reporting requirement ensures that all market participants play by the same rules. This promotes fair competition and prevents certain entities from gaining an unfair advantage through opaque trading practices.