Subject: Re: File No. ; Request for Comment on Securities-Based Swaps
From: Garrett Godfrey
Affiliation:

Mar. 31, 2023

Dear Sir/Madam, 

I am writing to express my strong opposition to the proposed rule by the Securities and Exchange Commission (SEC) regarding securities-based swaps. As a concerned citizen, I believe that this rule would have negative implications on the financial industry and market participants. 

I strongly believe that the proposed rule, which would require registration of security-based swap dealers (SBSDs) and major security-based swap participants (MSBSPs), would have a negative impact on liquidity and the ability of market participants to efficiently manage risk. The proposed rule would significantly increase regulatory costs for SBSDs and MSBSPs, leading to a decline in liquidity and a corresponding increase in transaction costs. This would ultimately result in reduced market access for retail investors, smaller firms, and other market participants. 

Furthermore, the proposed rule would require SBSDs and MSBSPs to make a significant amount of confidential data available to regulators, including trade data and other sensitive information. This requirement raises concerns over privacy and data protection, which is a critical concern for all market participants. The proposed rule also introduces a complex regulatory framework, which will be challenging to implement and enforce. 

In summary, I believe that the proposed rule would have a negative impact on the financial industry and market participants. It would increase regulatory costs, reduce liquidity, and create data privacy concerns. I strongly urge the SEC to reconsider the proposed rule and take into account the concerns of market participants and the public. 

Thank you for your consideration of my comments on this important matter. 

Sincerely, 
Garrett Godfrey