Subject: S7-32-10: WebForm Comments from Brian C Houchin
From: Brian C Houchin
Affiliation:

Oct. 29, 2022


October 29, 2022

 I believe that large swaps (such as $200 million or more) have the potential to cause instability in the market. As such, swap data needs to be reported daily to the investing public, enabling them to view and possibly to protect themselves from bad positions and elevated risk.

The $200 million mentioned above needs to be not just a single $200 million dollar swap. Entities engaging in four $50 million dollar swaps would need to report their swaps as soon as reaching the $200 million threshold.

The reporting requirements need to be based off of the underlying security, so that funds or firms cannot evade reporting by using other financial instruments. Swap reporting should be applied to both domestic and international swaps.

I would love to see more rules such as these in the future, thank you