Oct. 31, 2022
October 31, 2022 Dear Chair Gensler, I hope this comment finds you well. I would like to take this moment to thank you and your Agency for proposing the changes in the position reporting Security-Based Swaps. The willingness of your agency to propose a more transparent and open market by allowing the swap data to be made public is helping to level the playing field between your average investor and Wall Street. On a more serious topic, very large quantities of hidden swaps can be detrimental to the financial and national security of the United States in being the World Reserve Currency. These perpetrators use swaps to conceal how over-leveraged they are on positions that they can be allowed to trade quantities of currency that is only a fraction of what they actually carry. This is evident in recent light of the house of cards that was Archegos. Think of all of the other potential perpetrators that could be masquerading in the dark that are hazardous to financial stability. In addition, I ask that you consider lowering the threshold to a quantity to that of $100.000.000 to ensure that there is not a collusion of multiple smaller parties that would otherwise not meet the proposed threshold. Along with this swap reporting, the entire portfolio should be examined as to ensure reporting requirements as opposed to looking at parts of their investment. Similarly, the position should include the underlying security as well as any reference entity regardless of whether they are equity or debt based so that the complete picture may be gathered and reduce obscurity through complex financial instruments. Along the topic of clarity, the definition of 'Security-Based Swap' should be wide enough to encompass any tactic they may use so as to oppose similarity to their alleged function. This proposal should extend internationally so that entities could not use borders to further obscure their reporting and ensure fairness and equality everywhere.