Aug. 20, 2023
I strongly support the Commission's proposal to mandate the disclosure of swap positions. Opponents of this proposal, largely fund managers, financial institutions and their affiliates, take for granted the obscene degree of unearned privilege they enjoy in the market relative to household investors and have a track record of disregarding the potential negative impact of their negligence and/or greed upon the rest of society. Their main points boil down to: don't rock the boat, you're messing things up; we have this under control, but their objections are driven by self-interest. The number of violations listed on FINRA's website, repeated by the usual firms almost as if it were an annual tradition, show that self-regulation paired with the current cost-of-doing-business levels of settlements and fines do not work. Failures, once they spill out into the public, are too spectacular to reverse or properly mitigate. Please help prevent this by making swaps transparent. Has everyone already forgotten about Archegos and its degenerate swaps? If those swaps had been publicly disclosed, the situation(Credit Suisse, anyone?) would not have worsened to the current degree. Fund managers and financial institutions are supposed to be the experts and professionals. They should be able to operate even with swap transparency. If secrecy is the only factor that makes a position competitive, is it a viable position to begin with? If they cannot succeed without swap obscurity, the following idiom applies to them just as it does to everyone else: "If you can't take the heat, stay out of the kitchen." That which cannot stand in the light should not stand at all. Thank you.