April 7, 2022
I am writing in favor of more transparency and daily reporting of swap positions, including counterparties and their risks, and a complete breakdown of what securities are within these positions. Swap positions that are not reported pose a significant risk to the markets, as we saw with the collapse of Archegos through their obfuscated short positions.
It also appears that short interest is being hidden in swaps, and I hope this regulation will help shine a light on risky positions that are currently not reported publicly in any digestible plain-language manner.
In addition, I would like to express my strong support for enforcement of any violations, including personal financial liability, and referrals to the DOJ for criminal prosecution, should a participant be found to report positions inaccurately. A fine leveraged to the reporting company instead of the individual reporting fraudulently is not an effective deterrent. This must include personal liability to any violators of this regulation.