Jul. 20, 2023
S7-32-10 - Large Security-Based Swap Reporting Dear SEC Commissioners, I am writing to express my strong support for Rule Proposal S7-32-10, which aims to enhance transparency and public disclosure of large security-based swap positions. As a concerned citizen and an advocate for fair and efficient financial markets, I believe that increased reporting requirements are crucial in ensuring the stability and integrity of our financial system. In light of the proposal, I would like to share my thoughts on the matter: 1. Reporting Threshold Amount: I recommend that the minimum requirement for reporting any asset or debt-based swap or position should be set at $0 USD or any other legal fiat currency in use. Daily reporting of all positions, without exemptions based on ownership structures, should have been a legal requirement long ago. The Commission should take a zero-tolerance approach to non-reporting of financial assets, regardless of whether they are traditional or digital. 2. Timely Reporting: I fully support the idea of daily reporting of any change in position size, positive or negative, by the end of the business day. Considering the automation and efficiency of modern computer systems in the financial industry, any concerns about the time spent on processing these transactions should not be a valid argument against timely reporting. 3. Public Release of Data: Transparency is vital to ensure a level playing field for all market participants. I applaud the Commission's commitment to publicly releasing the reported data, allowing investors to make informed decisions and observe market dynamics. Fraud is a significant concern, and providing the public with access to swap activity data will empower them to protect themselves and the markets they engage in. 4. Lowering Reporting Threshold: I request that the threshold be lowered to $100 million / $200 million gross to prevent evasion and to ensure that excessively large swaps do not pose a threat to financial and national stability. By providing more data to the public and slightly lowering the threshold, the SEC can potentially detect fraudulent activities and hidden risks more effectively. 5. International Application: I urge the SEC to apply this rule internationally to prevent funds and firms from using borders to evade market regulations. An all-encompassing approach will ensure a fair and level playing field across various jurisdictions. In conclusion, I strongly support Rule Proposal S7-32-10 and commend the SEC's efforts to enhance transparency and accountability in the financial markets. By implementing this rule without a reporting threshold and ensuring daily reporting, the Commission can contribute significantly to building trust and restoring confidence in the financial system. Thank you for considering my comments on this critical matter. I trust that you will act in the best interests of the public and the integrity of our financial markets. Please feel free to reach out if you require any further information. Sincerely, household investor, Jason Karkiewicz