Oct. 29, 2022
October 29, 2022 First of all, I would like to voice my support for the proposed rule S7-32-10 - Prohibition Against Fraud, Manipulation, or Deception in Connection with Security-Based Swaps Prohibition against Undue Influence over Chief Compliance Officers Position Reporting of Large Security-Based Swap Positions A rule in this fashion is long overdue, transparency is never a bad thing, especially in the times where derivatives like security based swaps play such a large roles in our markets. As it is commonly known, sunlight is the best disinfectant. As the SEC probably has observed, swaps are a very handy tool to hide all sorts of positions due to the lack of proper reporting requirements. It is important to note that bad actors are the only ones who benefit from the lack of transparency, while claiming it is for the benefit of retail investors and all market participants alike. In my opinion, limit for reporting a swap should be lowered to $100 millions, to make it harder to hide large (potentially risky for national security) instrument as a bunch of smaller ones, just to fly under the radar. Also, any entity opening a swap have to report no later than end of first business day after swap was executed. Such reports have to be made publicly available immediately upon Filing. To end my comment, I would like to reiterate how important this rule is and that I strongly support it. Sincerely, A retail investor from Europe.