Subject: S7-32-10: WebForm Comments from Robert Frank
From: Robert Frank
Affiliation:

Oct. 31, 2022


 October 31, 2022

 Im in in full favor of the transparency and public disclosure of the swap data proposed.
Some key reasons this will improve the fairness of the market include preventing evasion of marketing reporting, and excessively large swaps may bring risk to financial and national stability. I also want to voice my concern to lower the minimum reporting requirement for swap positions to $100m, and extend the reporting requirements internationally as many US firms have international branches and daughter companies.
The definitions of a security based swap in the proposal should be left appropriately wide to minimize possible evasion.
Lastly, the daily reporting and public release of the data from the commission empowers the citizens to protect themselves from excessive risks.
I believe it is in the best interest of a fair and free market that this proposal be finalized and put into effect immediately.