Jul. 22, 2023
I am writing to express my utmost concern about the current state of the financial market and to strongly support the proposal for fair and transparent reporting of financial assets and swaps, as outlined in Proposal S7-32-10. As we are all aware, the financial system operates with highly qualified professionals and sophisticated computer systems, linked to numerous official and unofficial exchanges, including cryptocurrencies and off-book digital asset swaps. Given the complexity and scale of financial transactions in today's market, it is imperative to introduce stringent reporting requirements to ensure accountability, prevent evasion, and safeguard financial stability. One significant aspect of the proposed rule is the Reporting Threshold Amount memorandum analysis, which indicates that the smallest reported swap is $70 USD. I wholeheartedly believe that the minimum reporting requirement for any asset or debt-based swap should be set at $0 USD, or any other legal fiat currency in use. Furthermore, all positions, regardless of ownership by parent companies or child entities, should be subject to daily reporting without exceptions. Both traditional assets and digital assets should be reported separately, leaving no room for loopholes or technicalities that could hide high-risk assets. Any change in position size, positive or negative, must be reported automatically by the end of the business day to ensure timely information dissemination. The existing automated nature of the financial system renders the argument against daily reporting invalid, and any complaints about the hours lost in processing transactions should not be considered. To establish trust and fairness in the financial market, the SEC should take a firm stance against non-reporting of financial assets, and impose fines that are at least tenfold the value of the unreported position per violation. Public disclosure of these fines will act as a deterrent and help rebuild trust in the financial system. I strongly support the proposal to eliminate data aggregation in reporting, as it hinders transparency and enables market participants to obscure impropriety. Transparency is crucial to fostering properly functioning markets, and all market participants, including household investors, deserve equal access to timely reporting data. Recent events, such as the Archegos Capital Management situation and FTX debacle, highlight the urgent need for proper and timely reporting of swaps. By lowering the reporting threshold and applying these rules internationally, we can better detect and prevent fraudulent practices that may threaten financial stability. I wholeheartedly support the SEC's efforts to create a fair and transparent financial market. It is disappointing to witness opposition from certain quarters, seemingly influenced by financial donors and vested interests. The public deserves access to crucial market information, and public accountability should be at the forefront of regulatory actions. In conclusion, I implore the SEC to finalize the proposed rule as soon as possible, as it is critical to safeguarding the financial system and ensuring fair and transparent price discovery. I trust that you will take into consideration the concerns of concerned citizens like myself and prioritize the interests of the general public over any vested interests. Thank you for your attention to this matter. I believe that by implementing these changes, we can pave the way for a stronger, more transparent, and fair financial market that benefits all participants. Anonymous