July 19, 2023
Transparency is needed more than ever in our markets. Hiding data from the public does nothing more than confirm foul play by bad actors in our markets.
The minimal threshold for reporting any asset or debt-based swap should be $0 USD. This includes all kinds of financial instruments and legal fiat currencies.
Daily reporting of all financial positions should be a legal requirement, irrespective of whether the position is held by parent companies or subsidiaries.
Every company and its subsidiaries should report all positions, both on regulated and unregulated markets/exchanges, without any exemptions based on the entity's legal or residential status. This applies to all businesses operating on US soil.
Reporting should include both traditional and digital assets without exemptions.
Positions, both positive or negative, should be reported separately to avoid loopholes and hide high-risk assets. The report should also indicate changes in position size by the end of the business day.
As most trading and transactions are automated through computer systems, EDGAR filings should also be automated and done by the end of each business day.
Complaints regarding transaction processing times should be disregarded as the system is largely automated, and costs associated with reporting implementation should be considered as a regular business expense.
The Commission should maintain a strict stance against non-reporting of financial assets, whether traditional or digital.
All new rules aimed at increasing the transparency and fairness of the financial system should be implemented without any threshold and should be applied at the end of any business day during which a position is opened, modified, or closed.
Fines for violating these rules should be at least ten times the value of the unreported position and publicly recorded.
The Commission should collaborate with financial regulators in other countries to address similar issues, as the problem is not unique to the US.