December 14, 2010
Dear Sir or Madam,
I am writing you today to give my views on Exchange Act Rule 9j-1. It is is intended to prohibit fraud, manipulation, and deception in connection with the offer, purchase or sale of any security-based swap, as well as in connection with the exercise of any right or performance of any obligation under a security-based swap, including the avoidance of such exercise or performance. This rule is long overdue and finally grants the SEC enforcement powers specific to the nature, term and complexity of security-based swaps.
I believe the proposed rule is very important for making sure that security-based swap markets are used honestly, and that the SEC can answer with a strict penalty for any fraudulent or manipulative behavior. I believe that because this provision is already somewhat in effect within other provisions, that the benefits outweigh the costs by a wide margin. I support this proposed rule.