Aug. 20, 2023
To Whom It May Concern; Greetings. It is the intent of this letter to display support for proposal S7-32-10 with regard to SWAP disclosure and reporting. A fair, balanced, and transparent market is one that requires regulations be followed by all AP/MPs and for enforcement to actually occur. In the case of SWAPS it should be that any SWAP contract, be it TRS, equity, or otherwise be reported and properly disclosed, irrespective of size or positioning. It was seen that prior SWAP fiascos like Archegos/Credit Suisse/UBS only serve to obfuscate intent, positioning, and otherwise keep the larger capital markets in risk without a regulator to know how deeply connected and interwoven risks are. Lack of knowledge and disclosure does not lend to accurately and effectively tracking and mitigating market risk. In fact, lack of disclosure and reporting serves to potentially enable the abuse and manipulation of the markets by allowing AP/MPs to potentially engage in systematic naked short selling or to otherwise create phantom shares thereby diminishing true price discovery and real capital formation. An AP/MP can then continue illegal practices ad infinitum since no real disclosure or reporting regime exists nor is it enforced. It is absolutely criminal that the CFTC is allowed to continue to delay SWAPS reporting and it’s equally disgusting that the “regulators” are allowing this to happen. It appears that by the continued delay “regulators” are acutely aware of how incredibly screwed some parties/counterparties are and instead of doing the right thing and outing these criminals they’re assisting by delaying reporting. Audit the CFTC. Audit the DTCC. Audit the Federal Reserve. Audit all SROs. To address some comments made by some MFAs regarding liquidity: they are absolutely correct. They are worried that if SWAPS are disclosed and reported there will be less liquidity and their access to liquidity will be impacted. That’s true! Without beefing up portfolios using swaps that contain probably illegal content and pumping the names of the underlying how will they secure bagholders for when they finally are forced to dump on the markets?! For shame. How dare us dumb money investors cry out for transparency and information symmetry in the capital markets. Pass and enforce SWAP reporting. Respectfully Sent, DocBloodyB Disabled Combat Veteran Individual Investor