Jul. 26, 2023
To whom it may concern, I want to make clear my belief that public reporting is key to properly functioning markets. To anyone closely watching the modern markets, we see that when participants are not required to disclose information publicly in a timely manner, the opportunities arrive to fudge data, behave badly, and create a culture of distrust to those who are watching from the sidelines. Even when they are reported in a timely manner, Wall St. participants often (in my opinion, purposely) 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 NEVER beneficial. Whether market participants like it or not, household investors are a key and growing part of the market and as such deserve fair, equal access to reporting data on the securities they own, to make informed decisions. They want to educate themselves, by learning how, where, when and why to read reporting data. To minimize reporting is not equitable, nor does it create properly, stable functioning markets. At best, by limiting reporting, market participants are seeking to decrease competition in the market and "tip the game" in their favor against public investors who fear the system may be rigged against them (a common feeling for a while when investors think - wait, if I did that, I would go to jail or be fined!). 3. There's already a history of situations where reporting would have prevented collapses in the market structure. For example, 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 investors, from household investors up through all manner of market participants, have timely access to security swap reporting in order to make effective financial decisions about investments and compete fairly in a market where speed and knowledge are paramount to robust risk management. Restricting or otherwise reducing reporting has never favored fair, efficient markets and will only continue to create instability and distrust in the markets. Regards, Adam B