Subject: S7-32-10: Webform Comments from Trevor Ward
From: Trevor Ward
Affiliation:

Oct. 30, 2024

In the context of S7-32-10, the regulation regarding the
public disclosure of large security-based swap positions, it is
essential to emphasize that companies have a fiduciary duty to be
transparent to individual investors, who are, in fact, the rightful
owners of these entities. This perspective not only highlights the
moral and ethical responsibilities of corporate governance but also
underscores the foundational principles of fairness and equity in the
financial markets.

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Ownership and Fiduciary Responsibility: Individual investors are the
shareholders of publicly traded companies, and as such, they
inherently own a portion of these organizations. The management and
board of directors, who are tasked with overseeing the company’s
operations and strategic direction, have a fiduciary duty to act in
the best interests of these owners. This duty encompasses a commitment
to transparency, ensuring that individual investors are provided with
the necessary information to make informed decisions about their
investments. Without transparency, individual investors are left in
the dark, unable to assess the risks and potential rewards associated
with their ownership stakes.

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Informed Decision-Making: Transparency is vital for informed
decision-making. The complexities of financial instruments, such as
security-based swaps, can significantly impact a company's risk
profile and overall financial health. When companies fail to disclose
relevant information about their swap positions, they undermine the
ability of individual investors to understand the true nature of their
investments. This lack of disclosure not only violates the fiduciary
duty owed to these investors but also exposes them to unexpected risks
that could lead to substantial financial losses.

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Equitable Treatment in the Market: The argument for transparency
extends beyond legal obligations; it speaks to the need for equitable
treatment in the marketplace. Institutional investors typically have
greater access to information and analytical resources compared to
individual investors. By mandating transparency in swap positions,
regulators can help level the playing field, ensuring that all
investors—regardless of their size or resources—are equipped with
the same critical information. This equitable access fosters trust in
the financial system, reinforcing the notion that individual investors
are valued participants in the corporate landscape.

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Long-Term Corporate Success: Companies that prioritize transparency
and uphold their fiduciary responsibilities tend to cultivate stronger
relationships with their investors, ultimately leading to enhanced
long-term performance. A transparent corporate culture not only builds
trust but also aligns the interests of management with those of
shareholders. This alignment is crucial for sustainable growth, as
companies that neglect their fiduciary duty may face reputational
damage and declining investor confidence, negatively impacting their
long-term viability.

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Conclusion: In conclusion, the regulation concerning the public
disclosure of large security-based swap positions is not merely a
compliance issue; it is fundamentally about acknowledging the
fiduciary duty that companies owe to their individual investors. These
investors are the rightful owners of the companies, and as such, they
deserve transparency regarding the financial activities that can
significantly influence their investments. By ensuring that individual
investors have access to pertinent information, we can promote a more
equitable and trustworthy financial market, benefiting all
stakeholders involved.