Feb. 09, 2022
I’m writing to voice my support for the proposed rule S7-32-10 for the following reasons: I trust former SEC chair, CFTC principals, and the U.K. Financial Conduct Authority shared consensus of concern in 2019 over occurrences including “manufactured credit events” to “adversely affect integrity, confidence and reputation of the credit derivatives markets, [and] markets more generally,” as well as the 2018 ISDA board of directors who remarked these events could “could negatively impact the efficiency, reliability and fairness of the overall CDS market” Can we talk in plain English about what this means for a moment? “Manufactured market events” simply means someone is gaming the market. Are we a sober nation or are we not? Let’s be very clear about this. And if we are not a sober nation, are we fit to remain economic leaders on the world stage in this new millennium, as humanity encounters some of our greatest collective challenges? My view -- I submit to the commission, is that my ancestors did not flee centuries of autocratic tyranny overseas to establish a new nation on this continent; dedicated to freedom and liberty -- and die protecting their cause in our nation’s wars -- for it to devolve into an individualist looting at the expense of price discovery and capital formation that would otherwise hallmark free, fair, efficient, and orderly markets. My only concern with the proposed rule is that I can't find details on penalties for violation. It should go without saying, but the rule will mean nothing unless the reward for compliance is greater than the reward for infraction. I am well aware of the financial industry's "costs of doing business." The commission should understand: stakes are high. Retail, working in tandem with their regulators, have this opportunity to affirm to participants at home and abroad that confidence is well placed, and that America still values free, fair, and orderly markets. I am a carpenter, electrician, retail investor, and will be watching this case with great interest. Thank you for your time. Andrew Gervais