Oct. 18, 2022
October 18, 2022 I appreciate you reopening the chance to comment. Many financial industry participants heavily opposed this proposed rule after the 2008 financial crisis revealed an inadequate regulatory framework for a significant part of our financial markets. Especially considering current market and regulatory conditions, I fully support the SEC's efforts in this Proposed Rule including the all aspects of: a) Prohibiting fraud, manipulation, and deception in connection with security based swaps, b) Preventing undue influence over Chief Compliance Officers, and c) Position reporting of Large Security Based Swap Positions. As this particular proposed rule arises from the aftermath of the 2008 financial crisis where fraud, manipulation and swaps resulted in systemic risk to the financial system, it appears the self-interested financial participants opposing this Proposed Rule may generate significant profit from maintaining their ability to commit fraud and manipulate the markets. As taxpayers ultimately bailed out the financial institutions in 2008, systemic risk has been and continues to be unduly shifted away from the perpetrator onto the innocent, hard working families of this Country. Therefore, as a key part of the SEC's mission is \"to protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formation\", it is well within the SEC's mission to proactively set in place more strict regulations and penalties for violations -- especially considering how \"these markets were not yet subject to a comprehensive regulatory framework\". Failing to set up a comprehensive regulatory framework in the aftermath of 2008 is, quite simply, a failure to accomplish the SEC's mission that has given rise to yet another global financial crisis on the horizon. Please: 1) Prohibit fraud, manipulation, and deception throughout our entire financial market. 2) Ensure that Compliance Officers have the freedom and tools to perform their duty. 3) Require reporting of ALL positions (including shorts and swaps) that may directly or indirectly give rise to outsized leverage and/or risk. 4) Enact strong penalties to deter violations such that violations do not incur fines that are \"merely a cost of doing business\". At a minimum, violators should be forced to disgorge all profits and be subject to significant penalties deterring future violations. Thank you