Oct. 30, 2022
October 30, 2022 Re: File No. S7-32-10 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. I express substantial support for these proposed rules by the Commission. If adopted, these rules would improve market transparency, close a number of heavily abused loopholes being exploited by well funded market participants and reduce systemic risk. Case in point, Archegos. On March 26, 2021, banks offering prime brokerage services to Archegos started to liquidate billions of dollars' worth of various stocks after it had failed to meet a margin call. The stocks were reportedly tied to the total return swaps held by Archegos. The swaps were reportedly so vast that it caused two stocks to plunge twenty seven percent each, and dragging their counterparties down as well, such as Credit Suisse and Nomura. Massive losses for those unsuspecting companies and investors with no data points or filings to suggest an event such as that where an individual/group could hold such a massive unreported risky position. The events above are a mockery of our free and fair markets, suggesting that a \"shadow\" market exists, and skirting reporting regulation and undermining the rule of law. These swaps are a risk to all financial markets around the globe. I strongly implore the Commission to implement and extend these proposals internationally and swiftly.