Dec. 27, 2022
December 27, 2022 Dear Ms. Countryman, This comment is in response to rulemaking proposal S7-32-10 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. I am in favor of curbing fraudulent activities in the U.S. swaps and securities markets, especially when it comes to the DTCC and its subsidiaries, the NSCC, DTC, and its nominee, Cede Co. especially in the event of stock splits. I found myself absolutely flabbergasted after finding out about the highly questionable practices of the DTC's distribution of 4:1 split shares that were issued as dividends in a GameStop Corporation, a company that so many investors cherish, as its stocks is one of the most popular and most frequently traded amongst investment advisers, market makers, and retail investors alike. After a 4-for-1 stock split on July 22nd, 2022, some broker/dealers received notification from the DTCC that they were issued additional shares, other broker/dealers received notification that they would not receive any shares and should simply split the shares on their end. A lack of consistent post-split security distribution practice has become obvious even to less well-informed market observers. The introduction of utterly basic reconciliation practices between the DTCC and its member organizations should immediately be put in place in order to allow for easy tracking how many shares of a company have been issued in total and how many shares have been distributed to which broker/dealer after a stock split. With even the most basic accounting principles not in place, how does the SEC expect the investing public to keep putting their trust in the U.S. financial markets, let alone the regulating bodies? Without such post-split reconciliation measures, the U.S. stock market resembles an absurd game of musical chairs, run by a bunch of sad and clueless clowns. The U.S. financial market very urgently needs a major overhaul regarding the reconciliation and transparent as well as the timely record-keeping of post-split securities distribution. Sincerely, Gene Liu, a very concerned investor