Oct. 30, 2022
October 30, 2022 ###I incorrectly submitted an attached comment for this proposed rule, S7-32-10, meant for proposed rule S7-08-22 at roughly 4:36PM EST on the previous day, 29 Oct 2022. If that could be disregarded, it'd be appreciated if not, apologies for the time wasted sifting past my mistake and reading this now. Please have the remainder of this comment reflect my opinion on this proposed rule, S7-32-10.### First, I would like to state clearly I support this proposed rule, and I greatly appreciate the effort behind its creation and proposal. It's evident there needs to be transparency introduced as these currently opaque swaps have proven themselves as tools of exploitation which can - because they did (and still are) in the Archegos collapse, Mar 2021 - result in drawn out court cases where transparency for any real investigation to happen is demanded, finger pointing amongst prime brokers occuring (that could potentially be resolved, if not completly deterred, with transparency around swaps) and completely unpredictable investor harm that leaves little to no recourse for the investor. #1# In the already mentioned Archegos collapse, how could an investor - but specifically in the case of the retail investor - begin to have any clue one or more of their investments would drop by 27%? #2# The answer is: they couldn't. If there isn't anything deterring those within banking houses, or the banking houses themselves, from causing such unforeseeable monetary harm to everyday investors without certain compensation equal to or greater than the loss incurred, there needs to be a way for investors to spot the risk themselves in order to distance themselves away from it. When you look at the market as a system and the SEC's responsibility of securing it against calamity, realize you're currently adopting the strategy of \"security through obscurity\" and the longer you allow documented harmful exploits to exist unremedied, even when the reward for the exploiter isn't completely understood, the more you'll appear as a trap who benefits from the exploiting. Fix it by adopting an \"open\" policy as soon as possible by applying this rule. Second, you mention having the tool of the N-PORT form and the coverage it has to gain insight into some swap data, but completely fail to mention how useless this data is in risk assessment/prevention and investor protection. The N-PORT form can be reported up to 60 days after the quarter end-date for which it's reporting on, meaning the first month within the report can be 5 months old before you even see it. Also, can you even track N-PORT filings in a useful way with the loose standards? You allow participants to submit various identifiers appearing in different fields (e.g. \"Inhouse Asset ID\