Oct. 29, 2022
October 29, 2022 I am in full support of these proposed rule changes. I urge the SEC to adopt and enforce them immediately. I believe these proposed rule changes will go a long way to ensure more transparent and efficient markets for ALL parties involved. This data needs to be made public as it is in the best interest of our financial and national security. We need to prevent the next Archegos before it happens as it could potentially be larger and more damaging to financial markets as well as trust in the institutions regulating them. I hope to see many more rules like this one which propose accountability, transparency and regular public reporting requirements adopted in the near future. I agree with the definition of security based swaps in this proposal. It needs to maintain a broad definition in the hopes that future bad actors cannot evade these rules. Reporting of swap positions should include ALL security based swaps on each security or reference entity regardless of whether they are debt or equity based so that firms cannot evade reporting requirements by using other different types of complex financial instruments, including possibly new ones that have not even been invented yet. ENTIRE swap portfolios need to be subject to these reporting requirements. No exceptions should be made for any dealers. Aka large traders, small traders, authorized participants, family offices, banks, market makers, etc. This should also include foreign firms, not just American. A countries boarder should not determine if a firm can evade requirements or report differently to these rules. I also believe the threshold for reporting should be lowered to 50 million gross. This prevents firms from colluding together to spread out swap positions which may be potentially damaging or fraudulent and allows the detection of these positions sooner, before they can become an issue. The penalties for evasion and collusion of these rules and requirements should be made much more serious (jail time over monetary fines). This is due to the potential for serious damage to be done to the lives of ordinary citizens who are not able to pay attention to or comment on these issues in our financial markets. Please finalize, adopt and implement this rule immediately. Thank you