Subject: S7-32-10: WebForm Comments from Jeff Martin
From: Jeff Martin
Affiliation:

Oct. 31, 2022


 October 31, 2022

 There are many issues that this rule seeks to resolve.  This rule will support greater transparency around swaps which will make it impede participants ability to hide short positions.  It will also identify circumstances when a market participant has a large, concentrated position in a security-based swap on a single issuer.  In theory, as it currently stands, Hedge Funds can enter into tons of swaps allowing them to get short exposure to a stock without directly shorting it.  A hedge fund could enter into tons of swaps and creat a lot of syntheic shares and bear no burden to report this data.  These types of loopholes need to be eliminated and more transparent data around swaps needs to be more readily available.