July 24, 2023
To whom it may concern,
I strongly support this S7-32-10 proposal. I strongly support transparency and the PUBLIC disclosure of this data. I am highly concerned that large swaps are a threat to national and financial stability. The financial system participators employ highly qualified employees and extremely complicated and efficient computer systems and networks connected to a dozen official exchanges and non-official exchanges (crypto, off-book digital asset swaps). There are entirely too many mechanisms where these convoluted systems could be abused, therefore transparency is a must. The minimum requirement for reporting any asset or debt bases swap or position should be $0 USD (or any other legal fiat currency in use). The daily reporting of any and all positions should have been required by law to be submitted automatically on a daily basis many years ago, as this would empower citizens to protect themselves from excessive risk and the companies they own from hostile actors. There should not be any exemptions regarding any laws on reporting assets, swap or debt positions on a daily basis. Any company and it's subsidiaries should each be forced by law to report any and all positions without any exemptions regarding the legal entity of the subsidiary or residency. Both traditional assets should be reported along with digital assets positions without exemptions. Any position that holds a monetary value, positive or negative, should be reported separately to indicate both the long and the short position so to not bypass any loopholes or technicalities with hiding high risk assets through zero balanced positions through subsidiaries, shell or shelf companies as global financial system participants are doing these days through so called \"offshore safe haven\" countries with questionable reporting and fraud/securities laws. Any change in position size, positive or negative, should be required to be reported automatically by the end of business day. As mentioned before, nearly everything is automated through computer systems, high speed trading and networks, therefore this transparency through daily reportings should have been a legal requirement many years ago. As a Senior IT and CyberSecurity Engineer, any complaints about the amount of hours lost processing these transactions should be considered as false and nothing more than bad actors that are wanting to keep transparency at bay. The commission should take a zero stance against non-reporting of financial assets, both positive or negative, traditional or digital. The fines for violating these rules should also be increased to be at least ten fold the value of the not reported position, per violation, and be on public record so that any participants will be able to do business in the United States with trust worthy intermediaries or partners to rebuild trust in the financial system. Repeat offenders of these rules should also have their licenses stripped and be banned from operating in our financial markets completely. Time and time again we have seen hostile actors, excessive risk, and extreme lack of transparency in our financial markets which always ends up leading to major negative financial impact to regular everyday citizens, while a small group of greed-driven individuals in our financial institutions profit. The People will no longer stand for this or allow this to continue. The Commission should absolutely utilize its authority under Section 10B(d) of the Exchange Act to publicly release data. Fraud is widespread, and the resources of the SEC are limited. By allowing the People to see potentially dangerous swap activity, they will be better able to assess the investments they make and observe the dynamics of the market. A more level playing field is absolutely in the public interest, and the damage that can be done via swap activity (e.g., Archegos) necessitates that investors be equipped to defend themselves and the markets they use. The SEC should finalize this rule AS SOON AS POSSIBLE. The People deserve a level playing field, fair markets, and transparency.
Best regards,
Josh Corbin