Subject: File No. S7-14-18
From: Sushant Kumar

August 31, 2018

big banks know how to get away from regulation. central risk book is their latest attempt. central risk book team in some banks are really different. these teams use client data for trading signal alpha research. the head of desk always try to request more client transaction data for his backtest. these teams are huge and head of desk try to hire even more. central risk book desks in these banks have more traders or trading strategists than any other banks.these banks send client order to central risk book without client awareness. all eligible flow will be absorbed by this desk and this desk can hold position for several days. regulators need to investigate big banks central risk book to make sure they are not prop trading and misusing client data. head of this desk must go to jail if his team is prop trading or misusing client flow data.