Oct. 29, 2022
October 29, 2022 I am commenting to voice my support for the proposed rule outlined in S7-32-10. Large swap transactions that are not fully transparant can pose systemic risks to the existing market structure. They may also allow institutional players to artificially control price, eliminating organic price discovery, and upsetting the basic underlying premise of a free and open market. It has not been lost on many investors that the CFTC and other regulatory agencies have prevented the disclosure of swaps until 2023, and many of the most recent potentially market disrupting events such as the archegos debacle, prominently featured swaps as a main tool used to conceal large positions. As we witnessed this ultimately lead to serious problems as the situation unraveled. I would also recommend that the SEC limit the swap threshold rule to 100 million or 200 million gross. While it would not stop every bad actor, lowering the threshold would make it more difficult to conduct swaps easily without breaking up the transactions into smaller amounts which may prove prohibitively costly. I also would support expanding this rule internationally so that boarders would not be able to be used to get around this ruling. This rule would help to reaffirm that the SEC is trying to maintain a fair and transparant market for all investors.