Subject: File No. S7-32-10
From: Tim Owers

December 16, 2021

I believe that publicly reporting positions is necessary for a functioning market so support the core idea of this proposal. Having said that, I believe the way it is written is incomplete and will have no effect on helping the market in any measurable way. I see no punishment set in place that is extreme enough to deter anyone from just ignoring the rule. I believe any entity caught breaking these laws should be fined at least 2x any profit made they made off of any trade not reported and any persons connected with such trades should be bared from finance and automatic prison time.