Subject: S7-32-10: WebForm Comments from Carleton Monster
From: Carleton Monster
Affiliation:

Oct. 30, 2022



October 30, 2022

 I am in support of this. I believe the swap data that this rule effects should be public. And increased transparency is only a good thing for the entire system.

I also think the reporting requirement should be lowered to as low as is feasible. And I hope that the enforcement of this rule is effective against potential evasions to it. And would support actions by the SEC to bolster this rule against such evasions. I hope that this rule is resilient against complex financial instruments and would support the SEC's ability to apply this rule to complex financial instruments.

I also think this rule should also apply to international funds and firms.

And I think this rule should be applied to a fund or firms entire swap portfolio not just individual positions.

I agree with the definition of security based swaps in this rule and think it should be a broad enough term to capture anything resembling a security based swap.

Finally, I agree with daily reporting and that it be public.

Thank you very much,
Carleton Monster