Oct. 29, 2022
Large swaps are a threat to the stability of the global financial markets and and have consequences that threaten the dollar as world reserve currency. Archegos blew up because of these swaps and Credit Suisse is billions of dollars in debt because of it. I hope to see more rules like this one in the future I Request that the threshold be lowered to $100 million / $200 million gross. While the rule prohibits things like spreading a large swap position out to evade the threshold, this will be done and the SEC may or may not be in a position to detect it. By providing the public with more data, and slightly lowering the threshold, more of this fraud may be detected. It is important that the rule be hardened against evasion (eg by multiple actors colluding to build a large position through separately acquiring smaller positions that evade reporting requirements). I Agree with the definition of security-based swaps and state that it must be appropriately wide to minimize evasion. I Agree with daily reporting and praise the Commission’s public release of the data. It empowers citizens to protect themselves from excessive risk and the companies they own from hostile actors. “The Commission should absolutely utilize its authority under Section 10B(d) of the Exchange Act to publicly release data. Fraud is widespread, and the resources of the SEC are limited. By allowing the People to see potentially dangerous swap activity, they will be better able to assess the investments they make and observe the dynamics of the market. A more level playing field is absolutely in the public interest, and the damage that can be done via swap activity (e.g., Archegos) necessitates that investors be equipped to defend themselves and the markets they use. Please finalize this rule ASAP. Thank you Jhamal Becerra