Oct. 31, 2022
October 31, 2022 Hello, I am a foreign investor in the US stock market and concerned about the nontransparent use of swaps. I am highly supporting the PUBLIC disclosure of swap data. The Archegos problem and the now following breakdown of Credit Suisse could have only been prevented with much stricter transparency rules. Excessively large swaps like this are a threat to financial and national stability. Who wants to invest in a market full of 'time bombs' like this? I wish for more rules in the future to prevent market threats. - I request that the threshold be lowered to $100 million gross. It will be more easy to detect crime in the market in this way. - The rule should be applied internationally so funds and firms cannot use borders to evade the rules of the market. - The Commission should follow the precedent in Rule 13h-1, which identifies 'large traders' using the traders entire position in all NMS securities. The overall picture of a traders appetite for excessive risk can only be formed by looking at their total swap position. Allowing large traders to take on excessive risk via swaps in many different individual securities while avoiding reporting requirements is against the spirit of the rule, and goes against the Commissions prior rule making. - 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 strongly agree with the definition of security-based swaps. It must be appropriately wide to minimize evasion. - I strongly agree with daily reporting. The Commission should absolutely utilize its authority under Section 10B(d) of the Exchange Act to publicly release data. Fraud is widespread, and the resources of the SEC are limited. By allowing the People to see potentially dangerous swap activity, they will be better able to assess the investments they make and observe the dynamics of the market. A more level playing field is absolutely in the public interest, and the damage that can be done via swap activity (e.g., Archegos) necessitates that investors be equipped to defend themselves and the markets they use. Please finalize this rule as fast as possible. Sincerely, Khalid Haldanus