Oct. 31, 2022
October 31, 2022 I believe that transparency and public disclosure of swap data is vital to the financial and nation stability of this country. I hope to see more rules like this in the future to strength of economy for the future. I request that the threshold be lowered to $100 million / $200 million gross. By providing the public with more data, and slightly lowering the threshold, more of this fraud may be detected. Also, I believe in applying it internationally so funds cannot hid behind borders. The entire swap portfolio should be looked at to determine the reporting requirements not just the parts. Allowing large traders to take excessive risk via swaps in different securities goes against the spirit of the rule. Security-Based Swap Position should include all security-based swaps based on the same underlying security or reference entity, regardless of whether they are debt (including CDS) or equity-based, so funds and firms cannot evade reporting requirements by using different types of comp lex financial instruments. I agree with the definition of security-based swaps and believe it must be wide to minimize evasion. Also, I agree with daily reporting and praise the public release of the date. It empowers retail investors to protect themselves from excessive risk and companies that face their own hostile actors. I believe the rules should be finalized as soon as possible. Thanks you for you time