Subject: S7-32-10: WebForm Comments from Graeme
From: Graeme
Affiliation:

Oct. 30, 2022



October 30, 2022

 I support any and all efforts of making SWAP data public record and released on an immediate basis. SWAPs have been theorized to collect large groups of stocks and move them in uniosn, manipulating the price, stock market and discovery.
Large SWAP positions have already proven to be catastrophic to stock market integrity, re: archegos and potentially even Credit Suisse.
SWAP position reporting should be of a sufficiently low value, 50 million to 100 million so that large, market threatening positions cannot be broken up to evade reporting requirements.
I agree that the definition of swaps should be extremely broad in order to capture all possible positions for reporting and include all forms of financial instruments
The fact that the CFTC has seen fit to delay any and all reporting until 2025 should be enough of an indicator that SWAPs may pose an existential risk to the world wide markets.
All firms, international and domestic should be subject to these rules, and they should be implemented immediately.