Subject: Comments on File No. S7-32-10
From: Graham Ladner
Affiliation:

Jul. 25, 2023

To whom it may concern, 


I am writing to you today to express my strong support for the proposed increase in reporting requirements for swap positions. 


Proper enforcement of existing laws simply cannot be performed without the data that would be required by the updated rules. 


Not enforcing reasonable reporting for large, security-based swap positions is tantamount to a dereliction of duty; large, security-based swap positions can create systemic risk within global markets (even when they aren't used maliciously) and proper enforcement of securities laws requires that the regulator be able to assess the nature and size of swap positions to assess their systemic risk potential, as well as their legality. 


Sincerely, 
Graham Ladner 
Individual investor