Subject: S7-14-22
From: Bryce Keeney
Affiliation:

Apr. 27, 2022

Public Comment

Bryce Keeney

S7-14-22

Do not exempt clearing agencies for the definition of exchange. This allows a loop hole whereby clearing agencies could do the bidding of exchanges, yet would be exempt from the reporting, thereby negating the work that is being done. 

History has shown that all financial institutions have the potential to be corrupt actors, and therefor the SEC needs to implement rules that assume BAD ACTIONS and works to prevent their attempted abuse. Allowing exemptions is a major way to allow the bad actions to occur. 

Do not allow the abusive use of derivatives. Derivitives are not the purpose of the market, so please align rules to focus on the primary purpose, not to support tertiary aspects that result in systemic risk and systemic abuse. 

Rule 808 – Do not allow requests for confidential treatment. This is abused currently and very little information is made available to the public. 

Rule 814 question 71. 
Yes, more detailed rules are needed to address the separation of these entities. Rules must be made purposely to avoid the aggregation of powers in the financial markets. Any business operating on both sides needs to clearly separate their roles. 


Bryce Keeney 
Product Manager