Subject: S7-32-10: WebForm Comments from Jacob Daniel Barker
From: Jacob Daniel Barker
Affiliation:

Oct. 29, 2022


October 29, 2022

 Thank you for bringing this to the table to attempt to provide extra transparency in the markets to make them more fair and free for all investors.

The fact that this brings this information to the public's eye, even if they are not average investors is something that is sorely needed in our financial systems.

Large swaps NEED to be known about not because it would help smaller investors, but because these swaps are potentially landmines for our financial securities.

I would love to see more rules like these in the future. Transparency is only disadvantageous for those looking to do things under the radar. Why should average investors be on the radar but other entities not be?

I would suggest that the threshold be lowered to 1-2 million at the most for swaps reporting positions just because anything higher than this shouldn't be invisible.

This is also to say that these rules shouldn't stop at our border or our currency. If it can be swapped, it can be hidden.

When measuring a swaps position and weight, the entire portfolio should be looked at altogether, not just the bits that add up in the system when it is flagged.

The swaps reporting requirement should be including ALL securities and non securities based financial instruments that could be used to obfuscate a entities position. If a company buys a bunch of bananas to outlast the US dollar, each of those bananas should be accounted for.

Keeping the definition of securities loose, lowers the chance that something could slip under the radar and be intentionally used to cover a position inversely that it would be showing externally, internally. This is good.

The daily reporting will go a long way to making these markets more fair for everyone. Thank you for your time putting this together, this is one more step towards a brighter future.

Please hammer this one through as soon as possible.