Oct. 31, 2022
October 31, 2022 Equities and swap markets are trending more and more towards obscuring and obfuscating market data and position information. While institutions may argue that this is necessary for them to maintain competitive advantages, it is increasingly clear that these are a tool that can is frequently abused to create - at best \"unwise\" practices and at worst catastrophically complicated and potentially unlawful arrangements that present tangible systemic risk. Markets in a true capitalist system demand transparency, and regulations that must be applied equally to all market participants. If large industrial equities market players are able to hide their positions not just from other market participants but potentially counter parties who may be extending margin, or other leverage on their behalf it is abundantly clear that this presents a massive risk profile to swap markets and any associated market products (equities etc) that can be bundled into swaps. This very risk is effecting markets right now and must be mitigated and managed through proper reporting requirements. From industry players to retail investors it is in our best interest to ensure equal and fair markets with proper reporting requirements for ALL financial and investment products. Swaps, equities, bonds etc all deserve regulation that is cross checked through open and effective reporting requirements. Accountability is mandatory for trust in a market system and accountability is attained through accurate understanding of a situation. We must have timely and accurate reporting for Swaps. Towards that end I advocate for the following points: The threshold be lowered to 100 million gross. The standard should be applied internationally. The portfolio in question be examined in whole not in part - to evaluate the total value and impact of this swap position. I endorse and agree with the definition of swaps as detailed in this rule. The reporting frequency being recommended as daily is absolutely integral to the efficacy of this rule. Security-Based Swap Positions include positions based both on the equity itself and debt, and constitute (together) the total value/form of Security based swaps for a specific security. Immediate implementation of this rule. Thank you for your consideration and solicitation of public comment as you pursue a more just and fair market for all.