Oct. 31, 2022
October 31, 2022 If market participants have large concentrated positions in a security-based swap on a single issuer... That is inherently a conflict of interest. This allows big players to outperform the little guy EVERY SINGLE TIME, no matter the circumstances. Through big swings and pump-and-dumps invisible to EVERYONE BUT THE PARTICIPANTS OF THE TRADE... This is an outrageous and egregious behavior in a 'free market'. Among this, international escape hatches have been known alternative paths to essentially the same behavior. We cannot continue to let American businesses be incentivized to play a game that is beyond United States jurisdiction, in order to rabbit hole their way out of the rules to outperform their competition. We have seen this behavior with events like the Panama papers and various 'financial safe-haven' islands for things like tax evasion. This behavior is duplicated here and our system not only allows for this, but incentivizes this behavior. I recommend the SEC implement this rule as fast as possible and immediately begin implementation of its measures in full. Our country has a lot on the line with your decision.