Subject: Support for SEC proposal S7-32-10
From: Scott MacDonald
Affiliation:

Aug. 20, 2023

I support SEC proposal S7-32-10 for the same reason that I support any SEC proposal that provides more transparency, fairness and a level playing field among ALL market participants. In my opinion, anyone protesting this kind of proposal is doing so because they are up to some mischief or illegal activity that they wish to keep hidden so they can continue to compromise our markets and profit off their criminal activity. And I want to make it clear, I do not support a watered down version of this that anonymizes the reportings either, everything needs to be out in the open with hefty fines for failure to report accurately or in a timely manner. Institutions should be regularly audited to ensure they are compliance. 


I took the liberty of reading through a few of the other comments posted on the behalf of big institutions like hedge funds, market makers, banks, investment houses etc and they all lean into the same talking points: that them having to be transparent and open in their dealings is somehow going to hurt "liquidity, market efficiency, price discovery and competition". It's almost like they were all written by the same person and they are utter nonsense. Let's tackle them in order 


1)liquidity - ah the all-important liquidity fairy that Wall St so adores. Why do we need infinite liquidity? And why must we sacrifice so much to have it above all else? What's wrong the basic rules of supply and demand that have served us since trade began? If something is rare and in demand then its price should reflect that, it shouldn't be able to be manipulated by bad actors creating phantom shares that they never owned in the name of 'liquidity'. That's just stealing with a few extra steps. 

2)market efficiency - these institutions would have us believe that the burden of having to regularly report their swap activity will harm their efficiency, the same institutions that are somehow able to create incredibly complex high frequency trading algorithms that make billions of calculations per second to ensure best execution and profit for themselves. It's nonsense and it's a lie. They have massive processing power at their command, among the most advanced in the world in fact, there is absolutely no validity to this notion that they would be overly burdened having to report their swaps. 


3)price discovery - we don't have fair price discovery as it is, instead we have market makers who manipulate our markets and securities by routing some orders thru dark pools/OTC so they never hit the lit market and thus do not affect the price while allowing other orders to hit the lit market and move the price in the direction that most benefits them. Its an illusion. 


4)competition - how does something that affects all equally hurt competition? If this measure passes, all institutions are in the same boat, no one gets an advantage over the other, if anything this measure will help competition as it will level the playing field between the individual investor and the institutional investor. 


The mission statement of the SEC is 'to protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formation'. Right now we have 2 systems of justice at play, one that serves Wall St and its best interests and the other that serves the average individual investor, it's not fair, it's not balanced, it's completely out of sync. We need full transparency now. If Wall St is doing nothing wrong and breaking no laws then what do they have to be afraid of? Why protest this so adamantly unless you have something you'd like to remain hidden. End the lies, end the crime. This proposal is not a silver bullet that will magically fix our broken system, but it is a step in the right direction. 

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Scott MacDonald