Oct. 29, 2022
Hi,
I am in full support of a rule requiring daily reporting of large swap positions and the public disclosure of this data. I have major concerns that excessively large swaps are a threat to financial and national stability e.g. Archegos and other potential hidden lurking swap positions that could destabilize markets. I also request that the threshold be lowered to $50 million / $100 million gross. This rule should be applied internationally so funds and firms cannot use borders to evade the rules of the US market. I suggest that the rule be expanded to look at the entire swap portfolio to determine reporting requirements i.e. not just parts. I agree with the definition of security-based swaps (it should be appropriately wide to minimize evasion/fraud). Please finalize and implement this rule ASAP. Finally, the SEC should be given more authority and regulatory powers to go after the fraud committers criminally and place heavy fines on the firms/funds and executives who commit fraud.
To be clear, I support more transparency, public disclosure of as much data as possible as often as possible, and harsher penalties (both for the firm and individual executives) of fines and criminal prison time, and, more generally, T+0 settling, banning PFOF, banning dark pools, and banning FTDs. Thank you for your time.
Best,
Brandon Smith, PhD
Sandia National Laboratories