Nov. 01, 2022
November 1, 2022 RE: S7-32-10 Swap data is currently being hidden which poses infinite risk to our global economy. This data needs to be more transparent, more accurate, and more timely. This information needs to be made public and updates need to be made DAILY. Swaps and especially large security based swap positions are lurking bombs that post a threat to our national and global financial security. This rule needs to be passed ASAP. 1) The threshold for what constitutes a \"large\" security based swap needs to be lowered to $100 million ($200 million gross). This will allow risk to be detected more quickly. 2) This rule needs to be global. Swap positions should not be allowed to be \"hidden\" internationally in order to evade US securities laws and reporting. 3) Reporting thresholds need to cover entire portfolios, not just individual positions. When one party holds many \"small\" swap positions, it may allow for an individual position risk to appear small, but the whole portfolio risk may be massive collectively. The SEC should follow the precedent in Rule 13h-1 which identifies large traders using the traders entire position in all NMS securities. This should include ALL positions regardless if they are equity or debt based so that institutions can not evade reporting using complex financial instruments.