Oct. 31, 2022
To whom it may concern: Greater transparency is needed in markets. This rule will take a step in the right direction, but should enforce this with a penalty of 200% of the swap if found in violation. The fees the SEC has been charging participants is a gross miscalculation if these fees are to stop this behavior. We have derivatives and swaps running rampant in the background of our markets, bringing havoc to investors researching where a company may be exposed. To hide data on what companies are doing then take investor's’ money on the basis of “management” is a sad state of affairs, especially when the SEC’s public opinion is investors need to do more research. I can see detailed all the meeting the SEC has taken with the Managed Funds Association on this specific rule proposal. The Managed Funds Association is known as a powerful DC lobbying group that hedge funds manipulate congress through. Without transparency anyone outside of your agreements is led to believe these agreements are illegal and detrimental to anyone outside the agreement. Funny that you would take meetings from the groups this rule will hinder. It’s as if any reporting of positions in their view is too much information to share. Swaps with no reporting is only a way to obfuscate accounting and misdirect research. The only reason to have a swap and not report it is complete misdirection. How are investors to do their research when no information is provided? If the SEC doesn’t know what’s in a swap, how can they regulate it? The CFTC is refusing swap data and the SEC is saying they need more. We need all swap data reported daily. We need the CFTC to do their job and ultimately if the SEC would rather do it for them, great, you have $2billion and 4k employees. Retail investors need their watchdogs to increase the rate at which they actually make improvements in markets. Look how far behind the SEC already is. Credit default swaps destroyed the economy in 2008. And we can’t get a rule implemented on reporting this information…14 years later?! Institute this rule immediately Thanks, Greg Brandano gregory.brandano@gmail.com