Oct. 31, 2022
October 31, 2022 First off, I cannot believe, I have to resubmit a comment on something this immensely important, because it got \"accidentally deleted without backup\". That in itself is surreal to me. We are watching from Europe. If this farce continues, an entire generation of international investors and the generations that follow, will see no credibility in the stock markets, not only in the US but globally. The US has always had a responsibility, to lead the democratic world by example. As such, I cannot believe that submissions like S7-32-10 have to be seriously discussed, the same way I cannot believe that comments by we the people can simply be \"lost\" on such a scale. How is this proposal in the slightest way contentious? How can it be contentious to include ironclad provisions to avoid the evasion of such a proposal? The need to include such provisions in itself is incredibly shameful and telling of the supposedly greatest economy and stock market in the world. Yet it is sadly necessary. And someone actually wants to contest this? I thought Hester Pierce was a one time accident not a recurring theme. Are there seriously more people than her, who make the incredibly moronic argument that \"too much information is a bad thing\" in a supposedly free market? A free market requires free and equal access to information. Not a class-system of information. Price discovery cannot happen, when dark pools exist. Rules for thee but not for me, the violation of laws and ensuing fines being a fraction of the value of the crimes committed, thus simply becoming business expenses, this cannot and will not continue. If anyone/any area of the market requires tighter reporting duties and oversight, it is wall street and swaps in particular. Especially parties that engage in swaps in the range of hundreds of millions. They are also, coincidentally, the best equipped to deal with such an additional accounting/bookkeeping burden. As they never fail to remind us, how quint-essential they are for the market as a whole and only they can do, what they do. Some simple accounting/reporting should pose minimal challenge to them. I agree with the definition of security based swaps as layed out in S7-32-10 and also agree that it has to be an appropriately broad definition in order to avoid evasion by the numerous bad faith actors on wall street. Our markets are global, as such I am of the general conviction that rules for markets should be made on an international/global scale. S7-32-10 is no exception. I am also of the general conviction that reporting/data should be as close to real time as possible. Whether that means a day or an hour. S7-32-10 is no exception. Furthermore, I have always been of the conviction that if a rule or law is passed, then it obviously should also be implemented and upheld. As a EU citizen, I am painfully aware of the fact that, particluarly in the finance industry, the simple passing and even implemention of a law, does not necessarily mean that it is being upheld or enforced. Sometimes an effective law can be effectively ignored for decades. We need more proposals like S7-32-10, not fewer. If there is a chance to right this ship and keep it from sinking, it will take changes like this one. Do the right thing here. Its obvious.