Aug. 20, 2023
Subject: S7-32-10 Form Type A Dear Securities and Exchange Commission, I support this proposal and commend the SEC for putting forth this rule. This rule would lead to increased transparency which I believe is necessary for more fair markets. Large swap positions are a danger to the financial system, such as what happened with Archegos. I would love to see more rules like this to increase transparency and buckle down on fraud in our markets. I have some suggestions to the rule to make it stronger, listed below. (1) The threshold should be lowered to $100 million / $200 million gross in order for more fraud to be detected. (2) This rule should be applied internationally so firms cannot evade the rules by hiding behind borders. (3) The Commission should follow the precedent in Rule 13h-1, which identifies large traders using the traders entire position in all NMS securities. The overall picture of a traders appetite for excessive risk can only be formed by looking at their total swap position. Allowing large traders to take on excessive risk via swaps in many different individual securities while avoiding reporting requirements is against the spirit of the rule, and goes against the Commissions prior rulemaking. (4) Security-Based Swap Position should include all security-based swaps based on the same underlying security or reference entity, regardless of whether they are debt (including CDS) or equity-based, so that funds and firms cannot evade reporting requirements by using different types of complex financial instruments. I agree with the definition of security-based swaps and that it must be appropriately wide to minimize evasion. I agree with daily reporting and I commend the Commissions public release of the data. Finally, I ask that the SEC finalize this rule as soon as possible. Thank you and Kind Regards, ~Daniel Liefwalker