Subject: S7-32-10: WebForm Comments from Joshua Leung
From: Joshua Leung
Affiliation:

Oct. 31, 2022

 October 31, 2022

 I support real transparency and public disclosure of this data

I am very concerned about excessively large swaps that are a threat to financial and national stability evidenced by the Archegos saga. I think there are many more hidden from us.

I want to see the threshold be lowered to 100 million gross. This rule should be firmly against evasion such as multiple actors colluding to build a large position by acquiring small positions from multiple places.

I want to see this rule applied internationally. You should not be able to evade this with borders.

I agree with the current definition of security based swaps. It should be widened to minimize evasion.

I agree with daily reporting and I am happy to see the commission is releasing this data publicly. This further reassures checks and balances is properly honored.

I hope the SEC finalizes this rule as soon as possible and I hope to see more like this in the future