Oct. 30, 2022
To Whom it May Concern, I am writing to you today to declare my support for the reopened filing S7-32-10 which aims are increasing transparency and accountability within the Swaps market. The CFTC has recently extended the duration of their "no-report" period from January 2023 until 2025, removing the need for any financial institution to disclose their immense swap portfolios. After 2008, 2019, 2020, 2021, and now 2022 bailouts, I believe it has become patently clear to any regulatory body that cares to look: financial institutions are untrustworthy, deeply corrupt and wholly incompetent. For an easy example: Archegos. Credit Suisse has gone on record as stating "we cannot close 5% of Archegos positions", and those bad bets are still on Credit Suisse books today. 5% of Archegos position is enough to bankrupt a "Too Big To Fail" institution. This should never have been allowed to happen. Between the lack of oversight, accountability, and the knowledge that any major player in the markets WILL be bailed out by the Fed, institutions are now gambling on the socialising of losses wholesale. 95% of the issues surrounding Archegos and the turmoil Bill Hwang's Family Office created could have been completely avoided by simply enforcing REAL transparency within the Swap markets. If Credit Suisse, Morgan Stanley, Goldman Sachs, etc, could go to the appropriate regulator check their records, and see Archegos had 10 Billion dollars worth of leveraged Swaps already open with X Bank or Y Prime Broker, they would have known how insanely risky Hwang'a positions were and, at the very least, enforced heavier margin requirements if not outright declined his business for their own protection. ANY entity working within the Swaps market should be required to report ALL activity within the market. Swaps have become a hedge, a leveraged gamble, and collateral all at the same time. Their capacity for economic devastation is, in my opinion, as far reaching as MBS, CDOs and CDS were in 2008. Family Offices, Market Makers, Prime Brokers, Hedge Funds, Banks, all the obscure entities I don't even know about because I'm just a retail plebeian. All of them should be regulated and transparent within the swap market, both domestically and internationally. No Brazilian hedge funds with 700000 (pre-split, mid-2021) GME puts appearing and disappearing based on Swaps rolling over. No more hiding. I believe the SEC are becoming vert aware of how tenuous their position has become, both the Regulator and the American economy/world status. The only hope Western society has is to relax the stranglehold the rich now have over the poor, cut out the corruption, and rebuild trust with the rest of the world. I'm not smart enough or well informed enough to be able to critique the minutiae of this rule, nor to try and impress my opinions upon the SEC. However, I genuinely hope this rule is passed, enforced, and similar regulation is created by the SEC. In my opinion, this is a step in the right direction to helping mend the markets and investors trust in them. Well done, ladies and gentlemen. More like this! Regards, Benjamin Passlow