Subject: S7-32-10: WebForm Comments from Anonymous
From: Anonymous
Affiliation:

Oct. 26, 2022

This rule actually moves in the right direction for once. However, there are some pretty glaring paradoxes.
How can information about an entity's swap positions be made public but also anonymous? What does that change? WE ALL KNOW THERE ARE MASSIVE SWAP POSITIONS. We need to know the entities that are attempting to create risk tolerance through these positions. What on earth does reporting that there are large swap positions alone do?
It also seems that if you are a swap dealer then you do not have to report the positions that you dealt? So, a swap dealer can amass large swap positions without actually owning any of the underlying security and never have to report that they never owned any of the security? This rule seems to indicate they are still only required to report transactions, which if we are honest they almost certainly do not do truthfully. Is that not just naked shorting but disguised as a swap? How many counterparties did they deal the swap? Overleverage of swaps is also naked shorting, in the case that you can't sell something multiple times, after the first the sales are clearly not legal since you no longer own the security. Is this currently what the entire swaps market looks like? No wondering the market is burning....