Aug. 20, 2023
The lack of transparency on swaps for the US financial system in 2023 is incomprehensible. The public needs a system that is not at existential risk of catastrophic implosion, and the hiding of any transaction class with the magnitude of swaps makes that impossible. Transparency in the financial system is intrinsically good, and any deviation from the default of transparency should be clearly justified. There is no such justification for swaps. The market makers and investment banks would claim that the cost is too high (in either time or money). In 2023, that kind of argument is absurd on its face. If the accounting systems of these financial institutions can't meet any transparency requirement at the push of a button, then their license as a bank or brokerage should be revoked. Worse: the acceptance of this excuse gives financial actors a reason to be more complicated/opaque. This is plainly bad. In 2023, all swaps should be reported in real-time. The SEC must take action on this glaring vulnerability of the financial system, and must stop accepting tepid arguments from the entities they regulate as making any sense. Thank you for the opportunity to comment on this issue.