Aug. 20, 2023
To the Securities and Exchange Commission, I write in strong support of the SEC proposal S7-32-10. The financial industry undeniably requires robust oversight to ensure transparency, fairness, and the protection of all market participants. By addressing issues of fraud, manipulation, and deception in connection with security-based swaps, this proposal is a commendable step towards creating a more level playing field. However, for the proposal to be truly effective and for institutions to fully understand the gravity of non-compliance, it is imperative that the SEC provides clear and unambiguous definitions of the penalties associated with violations. Clearly defined penalties will not only deter potential violators but also provide a framework for consistent enforcement. Furthermore, safeguarding the autonomy of Chief Compliance Officers is crucial for maintaining the integrity of compliance functions within financial institutions. I commend the SEC for this initiative and urge its swift implementation, with the added emphasis on clarifying the repercussions of non-compliance. Sincerely, Brian Law