Oct. 31, 2022
October 31, 2022 I support for the full public disclosure of this data to allow transparency in the market. I have sincere concerns that excessively large swaps are a threat to financial and national stability, as what happened to Archegos, and are not enforced nor monitored in any way. The entire swap portfolio should be reviewed to determine reporting requirements, not just whatever is convenient for funds to reveal. I would like more rules like this in the future. I would also like to request that the threshold be lowered to $100 million, and $200 million gross. These rules should also be applied internationally, so that rules can be evaded by going to other countries. 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 that funds and firms cannot evade reporting requirements by using different types of complex financial instruments. I agree with the definition of security-based swaps and state that it must be appropriately wide to minimize evasion. I agree with daily reporting and praise the Commissions public release of the data. These rules must be finalized ASAP