Feb. 04, 2022
To Whom it Concerns, As I don't have the background to intelligently comment on most of these proposed rules I will keep my feedback relatively brief and pertaining to content that a layman such as myself can readily grasp. It is genuinely heartening to see the kind of language used in this document. In particular I want to draw attention to this paragraph; This externality is one where a market participant who decides to take on a large leveraged position in the underlying entity through a TRS will not internalize the total societal cost of a negative outcome where it declares bankruptcy. I don't know how common it is to refer to "externalities" and "societal cost" in the rules of the SEC but based on the present state of regulation and enforcement of those rules on Wall Street it can't be very much, if at all. Swaps were a critical facet of the failures that led to the Global Financial Crisis in 2008. As a relatively well-informed retail investor in a particular security deemed to have "idiosyncratic risk" it is obvious to me that swaps are continuing to have a massively detrimental effect on fair and orderly capital markets. These rules and others like it are at least a decade late but better late than never. Presuming they will be enforced with energy and commitment they should go an appreciable way in promoting a "market environment that is worthy of the public's trust". I want to commend SEC Chairman Gary Gensler and his colleagues who have been instrumental in re-proposing these rules. If passed and enforced rigorously I am hopeful that they will offer real and effective protection for investors and society while facilitating capital formation that will better internalize negative outcomes. Respectfully, James Spark