June 27, 2023
Subject: Comment on Proposed Rule: Position Reporting of Large Security-Based Swap Positions File No. S7-32-10
Dear Ms. Vanessa A. Countryman, Secretary, Securities and Exchange Commission,
I am writing to express my views on the proposed rule concerning the position reporting of large security-based swap positions. I appreciate the Commission's efforts to increase transparency and oversight in the security-based swap market, which is crucial for maintaining fairness and integrity in our financial markets.
I strongly support the proposed rule, which would require any person with a security-based swap position that exceeds a certain threshold to promptly file with the Commission a schedule disclosing certain information related to its security-based swap position. This rule is a significant step towards ensuring that all market participants, including retail investors, have access to the necessary information to make informed decisions.
However, I would like to emphasize the importance of ensuring that these rules are robust enough to prevent potential misuse of security-based swaps. As we have seen in the past, complex financial instruments such as these can be used for nefarious ends, potentially undermining the stability of our financial markets and disadvantaging retail investors.
Therefore, I urge the Commission to consider implementing additional safeguards to ensure that these transactions are completely transparent and that all relevant information is disclosed promptly. This could include more detailed reporting requirements, stricter penalties for non-compliance, and increased resources for monitoring and enforcement.
Thank you for considering my comments. I appreciate the opportunity to contribute to this important discussion.
Sincerely,
Michael Kyriacou