February 18, 2022
I fully support the implementation of
-New Rule 10B-1 and request a quantitative threshold below 10M as the baseline for public dissemination. Transaction data must be available for immediate reporting and dissemination. SBSDR must report and meet the above requirements for security based swaps and related
securities.
-Rule 9j-1 - https://www.federalregister.gov/d/2021-27531/p-276
Investors, including myself, lack confidence in the strength of antifraud standards in the swap
market. Omission of data and freezes until 2023, by the CFTC, are abhorrent violations of the
public and punish those who are already at a severe asymmetric information risk. To the public the security-based swap market represents a dangerous externality that spillovers are nigh impossible to identify ahead of time, and since participants can not truly internalize the risk of failure, any chilling effect is immaterial. All impact from partial executions, terminations etc (https://www.federalregister.gov/d/2021-27531/p-202) must be addressed publicly. I fully support more punishment due to misconduct individuals, and firms in this market
place, and urge the SEC to do so as well. The fines should be at least 200% of the value of the potential gains from the swaps
https://www.federalregister.gov/d/2021-27531/p-226
https://www.federalregister.gov/d/2021-27531/p-232
I fully support the SECs stand here. FINRAs fines, the use of dark pools, PFOF, are
all crippling true price discovery in order for unlimited liquidity. Market participants of a
certain size can effectively manipulate a price in any direction they please with no public
dissemination.
https://www.federalregister.gov/d/2021-27531/p-264 - I support both actual and attempted
conduct and support extending provisions.
https://www.federalregister.gov/d/2021-27531/p-268 - I support this. Due to the scope of this
market rules must be firm as individuals will be pressured to commit illicit actions,
knowing they can effectively personally Bailed out in the future through a new
position/ect.
Finally I believe that Broker-Dealers who borrow securities to relend, or to cover fails to
deliver, should not be allowed to do that. Borrowed shares must not be allowed to close
out fails to deliver. It is extremely damaging. You are depriving investors of voting for
corporate governance, damaging true price discover, and damaging market efficiency.