Oct. 30, 2022
October 30, 2022 Hello SEC. I am writing to comment on S7-32-10 in relation to swaps. Greater transparency on swaps is of vital importance to the health and long term viability of the securities markets. It is becoming increasingly apparent that the opaque nature of swaps is being exploited by bad faith actors in the markets. The recent Archegos debacle illustrates all too vividly the need for improvements in the regulation and reporting related to swaps. I would like to say that I agree with the definition, laid out in the wording of the rule, of security-based swaps. This definition must be wide so as to minimize evasion and maximize compliance. As it stands the requirements for public disclosure of the content of swaps is woefully inadequate. It is promising to see that the SEC is bringing forward rules to address issues such as large, concentrated positions in a single issuers security. The requirements for reporting on large (above $150+ million) swap positions should be same day without exception. The technology exists for same day. We should see the implementation of same day reporting applied to all market participants. The filing should also be publicly available immediately to give the markets full confidence. The continual and repeated pushing back of the swap reporting requirements by the CFTC is frankly a blight and damages the public faith in the securities markets. Failing to address transparency and reporting rigor in swaps threatens to completely degrade international faith in the securities markets. I trust that the SEC will finalize the strictest possible interpretation of the rule with the utmost speed. Many thanks, Anon