Aug. 8, 2023
I am strongly in support of proposal S7-32-10. Fair and open financial markets depend on transparency. Without transparency large numbers of market participants are unable to remain competitive. Without swaps reporting requirements investors are unable to sufficiently assess the risk in their investments. This contributes to market instability and inefficiency. Proper and timely reporting of swaps would prevent market events that pose systemic risk, such as the Archegos collapse, which was due to massive leverage hiding in a multitude of swaps that do not require reporting. 12 years of ongoing "no-action-relief" in swaps reporting is inexcusable and overall detrimental to functional and resilient market structure. The derivatives market is magnitudes larger than the securities market, and has direct impact on the underlying securities. This makes it of primary importance to enforce transparency in swaps reporting. I support reporting requirements for not only small, but all swap positions to ensure all market participants are able to make informed investment decisions. The reporting treshold amount for swaps should be changed from the current $70 to 0 in USD or any other currency. Continuing to not address the issue of swaps reporting for 12 years is a failure of the mandate of the SEC and the CFTC - namely by chairman of the CFTC Rostin Behnam. Lesser reporting requirements have never led to more fair, orderly and efficient markets, as the commission's mandate states. Therefore I fully support proposal S7-32-10. Sincerely, Jyri Hukkataival