Subject: S7-32-10
From: Adam Rensel
Affiliation:

Jul. 19, 2023

Hi there! I am all for more market transparency. This is especially important in an industry were self reporting is the norm. Financial system participants have been pushing the bleeding edge of computing and automated trading for decades across multiple asset classes. Reporting should be able to keep up with the speed of trading via automation in this day and age. This relates to the reporting threshold amount memorandum analysis showing that the smallest reported swap is $70usd. Automated trading firms deal in sub penny amounts which is far below this limit. There should be no limit on any asset or debt bases swap or position, these advanced traders have the data and already automate the process. 


Daily reporting should have been a requirement decades ago with the advent of automated trading systems, building automated reports is a standard process in any computerized system, it is not a burden and is likely already being done privately. All trading entities company and subsidiaries, regardless of type should be required to report trades. any claims of automated reporting causing business hours lost should be considered false. 


Lastly, fines related to violating these rules and frankly any rules should be at least 5x the value perpetuated by non reporting or reporting incorrectly. The financial markets lack accountability and real consequences need to be realized to avoid fines just being a cost of doing business. 


Please accept these rules changes and implement them as quickly as possible. It is in our countries best interest to reduce risk and fraud in captial markets, as they say, sunshine is the best cure for fraud in the darkness. Thank you! -- 

- Adam Rensel, Web Developer