Oct. 30, 2022
Vanessa A. Countryman Secretary, Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 Re: Release No. 34-93784; File No. S7-32-10] RIN 3235-AK77 Prohibition Against Fraud, Manipulation, or Deception in Connection with Security-Based Swaps; Prohibition against Undue Influence over Chief Compliance Officers; Position Reporting of Large Security-Based Swap Positions Dear Secretary Countryman: I firmly support the purposed rule: File Number S7-32-10 I also join the 18 Attorneys General who on the 24th October 2022 called on the Commission to extend the reopened comment periods for a minimum of 60 days for all rulemaking releases affected by the technological error in the Commission’s internet comment form. In any event, regarding the rule change: To the SEC, timely and accurate reporting of all positions is paramount to the success of a trader. We use this information daily to assess the markets and to formulate strategies. We need more data to accurately predict market movements. We need the markets to provide us with as much accurate and timely data as possible. Traders will process the position data as needed. We operate in a 21st century marketplace, competing with organisations who spend billions to tilt the tables in their favour, exploiting latency arbitrage, diverting and front running retail orders, sending them to dark pools, and lobbying congress to pass laws that only benefit them and allow them to obfuscate and confuse casual observers so they can continue their illicit practices. Swaps need transparency because they can be used to hide short positions and skirt collateral requirements. Transaction-by-transaction reporting should be implemented because financial matters should be fully auditable - aggregates should not be used as data can be hidden this way, which is the opposite of transparency. Aggregate data can always be constructed from the raw source, provided it is complete and accurate. YOU need to enforce reporting rules and punish reporting malfeasance. By getting the abusive institutions who are a blight on the markets to become transparent and end the era of Market Makers basically running “an exchange but without the regulatory oversight” it should level the playing field, and afford you the visibility so that you can clamp down on FTDs - the abusive Ponzi scheme of the modern day which has robbed Main St of so many trillions of dollars, and is a principle cause of inflation contributing to the current day cost of living crisis. There are some excellent books by Michael Lewis regarding these matters, some of which have been made into feature films - may I recommend ‘Flash Boys’ and ‘The Big Short’ so that you understand how dangerously leveraged the whole system has become, by virtue of allowing these bad actors to run amok The fact that prevention of fraud and manipulation is even up for discussion is worrying to say the least. This should be passed and even more importantly enforced, ASAP. Thank you Kevin Grant