Subject: S7-32-10: WebForm Comments from Maximilian Kittner
From: Maximilian Kittner
Affiliation:

Oct. 30, 2022



October 30, 2022

 Ladies and Gentlemen,

I write as a very concerned foreign investor in the US markets. Frankly, I'm shocked at how little transparency there is and how little trust an individual investor can have in the US markets.

Just recently we saw and still haven't gotten the truth about the ORTEX share borrowing data for $GME, not to mention all the other ways retail always gets the short end of the stick.

Therefore I welcome more transparency and PUBLIC disclosure of accurate and up to date data.

I see SWAPS as a huge financial risk to the markets, because they let bad actors hide their true exposure to risks. I hope with this proposed rule and more like it in the future, things will improve. I request that the threshold for swaps reporting should be $100 million gross. Hopefully this makes it easier to detect fraud. Further I voice my support to enforce this rule internationally, so that any funds or firms cannot find shelter in financial havens. I suggest the SEC should look at the entire swap portfolio of firms and funds, not just parts of it.
I agree with the definition of security based swaps as proposed, it should be appropriately wide to minimize evasion and increase detection rate.
I want to commend the Commission on proposing daily reporting of swaps and the public release of the data. These things enable investors to make educated investment decisions.
Lastly, I demand more enforcement of rules and stronger fines/punishment for those who disregard them. Fines CANNOT be \"cost of business\" for Wallstreet.

Please finalize and enforce the proposed rule as soon as possible. It is vital to the health of financial markets.

PS: (the attached phone number is made up as the website will not let me enter my actual German phone number, you should definitely allow foreign numbers)

Greetings,
Max Kittner