Jul. 10, 2023
To The SEC: Public reporting is key to properly functioning markets. Time and time again we see that when market participants are not required to disclose information publicly in a timely manner bad things happen. Even when they are reported in a timely manner, Wall St. participants often attempt to make them as obtuse and unreadable as possible. 1. Data should not be aggregated, whether in securities reporting or swap reporting. The common argument that it prevents participants from determining trading patterns or strategies is an excuse to keep the data from regulators and those that might otherwise report impropriety. 2. Less reporting is not beneficial. Whether market participants like it or not, household investors are now part of the market and as such deserve fair, equal access to reporting data on securities they own. Unfortunately for Wall St. household investors are not "dumb money". They have educated themselves, understand how, where, when and why to read reporting data. To minimize reporting is not fair, nor does it create properly, stable functioning markets. At best, by limiting reporting, market participants are seeking to decrease competition in the market and to continue to hide shenanigans from the public investors who very much understand the system is rigged against them. 3. If swaps had been properly and judiciously reported in a timely manner, situations like Archegos would not have occurred. 4. As to the effects on volatility and liquidity, these are risk issues. Market participants should be accounting for the risk themselves and not trying to place the burden of risk management on regulators or regulations. If a given security is suffering from a liquidity issue, this is not the fault of reporting, nor is it the fault of investors choosing where and when to invest funds, it is more a function of Hedge Funds wanting to reduce risk via a regulatory framework to continue with unrestricted short selling while the public and regulators are blind to the information. Clear, specific, direct language must be there to ensure that household investors, infact all market participants, have timely access to security swap reporting in order to make effective financial decisions about investments. Restricting or otherwise reducing reporting has never favored fair, efficient markets and has only led to eventually massive instability in the markets. Thank You, D. Kraft -- OIIIIIIIO