Subject: S7-08-22: WebForm Comments from Colin Smith
From: Colin Smith
Affiliation:

Oct. 31, 2022



October 31, 2022

 The Proposal as currently crafted has a huge hole that must be remedied, one that the Commission is well aware. The failure to include derivative exposure in this rule will inevitably result in firms exploiting the loophole and will drive more and more firms into the less regulated and less transparent space of derivatives.