Subject: S7-32-10: WebForm Comments from Matthew Mudicka
From: Matthew Mudicka
Affiliation: Software Developer

Nov. 01, 2022



 November 1, 2022

 Vanessa A. Countryman
Secretary, Securities and Exchange Commission
100 F Street NE
Washington, DC 20549-1090

Dear Secretary Countryman:

I am writing to you on November 1st, 2022 in support of rule S7-32-10.

On October 19, 1993, Congress voted 264 to 159 to cut the financing to the Superconducting Supercollider underneath Texas just South of Dallas. And as a result of that, the academic job market for physicists collapsed overnight.

The next day, physicists around the country realized their job prospects vaporized instantaneously-but luckily financial firms like Goldman Sachs and many others were hiring. This cohort of physicists, would later go on to create the fields of: Financial Engineering and Quantitative Analysis-which would later result in the creation of financial instruments such as security based swaps.

The growth in these fields was exponential from 1993 to 2008, with swaps being one of the major issues during the 2008 monetary crisis. These financial instruments are undoubtedly important to the health and continued prosperity of our markets-but the problems that occurred in 2008, and the problems that may continue to occur-can be mitigated or stopped, with transparency and education-through the public disclosure of data relating to swaps.

As a software developer, I am inclined to speak on the importance of open source software which allows experts in the field to to work together to fix complex vulnerabilities-providing security and prosperity to all citizens across the globe.

I want to commend the Commission on the daily reporting of swaps, which would allow experts to detect and prevent vulnerabilities through this rule of daily disclosure. I would also like to see the daily reporting of swaps be done internationally, and I will be writing to the Prime Minister of Canada, as well as the Premier of Ontario, where I reside, to uphold to the standards that are being set right now in the United States.

Lastly, I hope the SEC can finalize this rule expediently to stop those that wish to evade reporting requirements. I would also like to speak about the SEC Rule 13h-1 and the precedent that was set, which looks at a traders entire position in all NMS securities to identify excessive risk-which can be bypassed using swaps-thus avoiding reporting requirements and breaking the spirit of the rule.

Thank you for your time and continued work on making markets more transparent.

Sincerely, Matthew


Sources

Congress voting to stop funding the Superconducting Supercollider
https://www.latimes.com/archives/la-xpm-1993-10-20-mn-47771-story.html

MIT Lecture by Stephen Blythe on Option Price and Probability Duality
https://youtu.be/eG_aRPy1KVE?t=288

SEC Rule 13h-1
https://www.sec.gov/files/Risk Alert - Large Trader 13h.pdf