December 16, 2021
You had me at \"Prohibition against fraud, manipulation or deception.\"
Any amount of self-reporting of swap positions needs to be removed at this point in time, because the market participants doing this reporting have a vested interest in mis-reporting their positions.
They never get in trouble for it. The worst they get is a paltry fine AKA \"the cost of doing business.\"
How about making it a criminal offense to mis-report Swap positions? How about also including a fine which is actually proportionally significant to the crime? The current punishments are clearly FAR from an effective deterrent.
If I counterfeit a $20 bill, I will get fined THOUSANDS.
When market makers counterfeit or otherwise obfuscate their swap positions, they get fined $20 (relatively speaking).