Subject: Position Reporting of Security-Based Swap Positions (File No. S7-32-10)
From: Iwo Nowicki
Affiliation:

Oct. 29, 2022


Dear Secretary Countryman

I am writing this in a strong support of releasing SWAP data for public disclosure and increased market transparency. Every derivative can be a financial weapon of mass destruction to national security and financial stability, as it was presented by Archegos insolvency, which added to the current Credit Suisse financial struggles.

I advocate for for all SWAP related data to be available to the public, with no threshold limit and marked by individual investor/institution, holding these SWAPS, and SWAP related derivatives on the underlying security or reference entity, either they are debt or equity-based, therefore there will be no possibility of evading reporting of such SWAP positions.

I agree with security-based-swaps definition, though it should be exclusively wide to remove evasion possibilities.

I am also strongly for, obligatory live report SWAP data, with minimized to no latency.

It is crucial to keep our market safe from dangerous and idiosyncratic risk-making players, therefore I highly ask you to implement these changes in fast and mannerly fashion.

Sincerely

A Concerned Investor