Subject: S7-32-10
Form Type C

Dear Ms. Countryman,

I strongly support the commission’s effort to increase transparency in our financial markets with this rule change. I would like to add two points that I hope the commission will include in its final rule making on Swap disclosure.

Daily public disclosure of Swap data will result in more stability in our markets

Large swaps can be hugely influential, and the lack of public reporting can have destructive effects on financial firms and can result in increased volatility in our financial markets. The Archegos-Credit Suisse fallout makes this evidently clear. Archegos’ swap positions played a huge role in the downfall of Archegos, and its exposure in swaps to both the company and the financial market were not recognized in time. In response, Archegos’ portfolio was unwound rapidly, which led to significant losses to both its financiers and anyone else who held long positions in these stocks.

One can wonder if Archegos’ poor reporting of its swap exposure really was a standalone case. How many other firms have exposure in swaps that would exceed acceptable levels of risk-management?

The daily publicization of swap data will incentivize proper risk-management within financial firms, lowering exposure to acceptable levels of risk management and result in more stability within our financial markets.

I encourage the commission to finalize this rule as soon as possible

I am writing in strong support of the rule making to be passed and public data to be published on a daily basis for public transparency.

Thank you for considering my comments,