Subject: File No. S7-32-10
From: David S Kaffenberger

February 7, 2022

Proposed Rule 10B-1: Position Reporting of Large Security-Based Swap Positions

This is a great step forward. However, violations of the mandatory reporting need to carry penalties harsh enough to encourage compliance with reporting. Please don't make it \"the cost of doing business.\" It has to hurt if it is grossly violated.