Subject: File No. S7-32-10
From: Achille Davisson

December 17, 2021

Security-based swaps have been an integral part of many of the market failures in the past 20 years. They allow toxic positions that would have been forced to close earlier to fester and grow to become systemic risks to the financial system and economy at large.

Please do pass this rule to increase the reporting requirements for such trades so that a more accurate and effective price discovery can happen with affected securities and to limit the acute and systemic risk presented by institutional players taking and maintaining over-leveraged positions.