Subject: S7-32-10
Form Type F

To whom this may concern,



As we all know, the financial system participators employ highly qualified employees and extremely complicated and efficient computer systems and networks connected to a dozen official exchanges and non-official exchanges (crypto, off-book digital asset swaps).



Regarding the Reporting Threshold Amount, memorandum analysis showing the smallest reported swap is $70 USD, the minimum requirement for reporting any asset or debt-based-swap or position should be $0 USD, or any other legal fiat currency in use.



The daily reporting of all positions should have been required by law to be submitted automatically on a daily basis years ago.



Regarding the ownership of such positions being by either parent companies or child entities should not create any exemptions on reporting asset, swap or debt positions on a daily basis.



Any company and it's subsidiary(ies) should each be forced by law to report any and all positions without any exemptions regarding the legal entity of the subsidiary or residency as long as they operate on United States soil, in regulated or unregulated markets/exchanges.



Both traditional assets should be reported along with digital asset positions without exemptions. If the asset can be used as collateral in doing business, then it should be recorded with 100% transparency to the public.



Any position that holds a monetary value, positive or negative, should be reported separately to indicate both the long and the short positions, as to not bypass any loopholes or technicalities with hiding high risk assets through zero balanced positions through subsidiaries, shell, or shelf companies, just as global financial system participants are doing these days through so called "offshore safe havens".



Any change in position size, positive or negative, should be reported automatically by the end of business day.



As mentioned before, nearly everything is automated through computer systems, high speed trading and networks, having EDGAR filings be done at the end of business days should have been a legal requirement a decade prior.



Any complaints about the amount of hours lost processing these transactions should be considered as false and purposely prohibitive to market transparency. As most financial participants employ their own IT departments, these costs to implement reporting requirements should be considered as "cost of doing business" as they make hundreds of millions and billions in profits per year.



The commision should take a zero stance against non-reporting of financial assets, both positive or negative, traditional or digital. All positions should be reported seperately per legal entity/owner without exceptions.



With all the new rules proposed to make the financial system more transparent and fair for ALL market participants, this reporting rule should be set without a threshold and at the end of any business day that a position was opened, modified or closed.



The fines for violating these rules should also be increased, to be to the value of the reported profit, per violation, and be on public record so that market participants will know who they do business with. Claiming ignorance to violations is absurd.



I hope the Commission will bring in a new era of fairness and transparency, as was the reason for its creation in the first place.


Best regards,