Subject: File No. S7-07-15
From: Toby Marmion
Affiliation: University College London

February 7, 2022

To put it lightly the fact this needs any comment for passing is ludicrous. This rule specifically states its intention to reduce the possibility of fraud or other misconduct in relation to a security based-swap. Given this organisations job to specifically address these things it seems this is a cut and dry improvement.

As a so called retail investor who has also studied some finance its alarmingly clear how much disparity there is in information and influence between players in the market. So any measure that seeks to place a closer eye on the behaviour of those with more influence is certainly a positive one.