Oct. 30, 2022
October 30, 2022 To publicly disclose swap positions would aid us in avoiding situations like the Archegos which could potentially set the financial system at risk. To not know whether such risks exists in the system where I invest creates less willingness to invest and more stress regarding my investments. I as a retail investor can today not take this risk into account. However, if the proposition of daily reporting with regards to security based swaps is implemented I could include this risk in my risk management. Stress with regards to finance usually spills over into the everyday life of individuals which create a less productive and well functioning society. Disclosing swap position is likely to create more insight into the system and possible also limit the risk of bets, like the Archegos one, to happen again. This would most likely reduce stress among everyday retail investors. I agree that in order to avoid evasion of this law the definition of security based swaps must be wide enough. The rule must also be applied internationally to avoid evasion where the position is spread out to countries with no reporting obligation. The rule must also encompass small enough swap positions to avoid the possibility to divide a large position into many smaller ones in order to avoid reporting obligations. Thank you for your time and for helping us retail investors Best, Frans