March 9, 2022
To whom this may concern,
On August 31st, 2021, the CFTC released Release Number 8422-21 regarding reporting obligations for swap dealers being relieved until October 6, 2023, for no clear reason. The release mentions this is a relief on a temporary basis. A lot of things can happen in financial markets over the course of two years, relieving dealers from these reporting obligations leaves investors even more in the dark regarding what financial institutions are up to using swaps. It's extremely odd that this comes only months after the meltdown of Archegoes Capital Management which used Swaps to hide their positions. This was an extremely odd event and I am glad the SEC is taking steps to stop this move by the CFTC. Furthermore, I agree with the SEC's \"Reported Threshold Amount\" both in the context of CDSs and security-based swaps. I would like to bring attention to a part of financial institutions' balance sheets that I believe should be reported as swaps. \"Securities sold, but not yet purchased\". Many institutions have more than 60% of their liabilities in this category. I believe that these positions need to be disclosed under swaps as they are a huge part of these funds and will give investors insight into how exactly markets work. At the moment, short positions are not required to be reported, and with the recent interest taken into dark pools, retail investors need to know what these securities sold, but not yet purchased are.
Regards,
Sahil Mirchandani