Subject: S7-32-10: WebForm Comments from Kenneth Yass
From: Kenneth Yass
Affiliation:

Oct. 31, 2022

 October 31, 2022

 I am voicing my vigorous support for ths proposal to prevent evasion of the reporting requirement for swaps.

As of this most recent week, I, a concerned investor, have become aware of the recent push by the CFTC to push swap reporting requirements until December 1, 2025 (https://www.cftc.gov/PressRoom/PressReleases/8618-22).

The capital market is often deified by many for myriad reasons, but one of the glaring nails that sticks into the skin of this idea is that there is absolutely little public disclosure that exists (and especially so in the interest of individuals and retail investors at large).

There have already been huge ramifications in the past with regards to large notional swaps that hide positions that can not simply boost or tank markets, but even worse. This should be but the first grain of sand in the public disclosure of this information. Note that this push by the CFTC to obscure swap reporting was done yet again with very little fanfare to the greater public, obscuring perhaps what damage might be done until it is too late in our capital markets.

The commission should absolutely follow the precedent set in 13h-1, identifying a trader's position across NMS securities. This is something that must be done not just in the United States, but should be pushed by the Commission to have corresponding parts in international financial agencies such as the FCA in the UK.

This rule must be finalized as soon as possible. Our capital markets are at risk of danger due to the obfuscation of these swaps already, and it is imperative that the Commission push to accelerate this move as fast as possible.