Oct. 30, 2022
October 30, 2022 Dear Secretary Countryman: I am writing in strong support of 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 am writing to support transparency for the PUBLIC disclosure of data related to this rule. If swaps are used to create short positions, but are not required to be reported, it creates the opportunity to commit fraud by creating overweighted short positions which pose a systemic risk to the financial system. This should not be be an option. Thank you.