Oct. 31, 2022
October 31, 2022 Re. File Number: S7-32-10 I agree with this proposed rule and would like to thank those who helped write it. Good job Gary Gensler and staff. Lack of transparency in swaps is partly why the US financial system has become so dangerously volatile and risks larger events than Archegos when in reality if positions were reported publicly these tinderboxes could be defused earlier. I think the threshold for reporting swaps should be lowered to 50 million gross. While the rule prohibits things like spreading a large swap position out to evade the threshold, this will be done and the SEC may or may not be in a position to detect it. By providing the public with more data, and slightly lowering the threshold, more of this fraud may be detected. It is important that the rule be hardened against evasion (eg by multiple actors colluding to build a large position through separately acquiring smaller positions that evade reporting requirements). We do not want to see the rule watered down in practice. This rule should be applied to international swaps too. The Commission should follow the precedent in Rule 13h-1, which identifies large traders using the traders entire position in all NMS securities. The overall picture of a traders appetite for excessive risk can only be formed by looking at their total swap position. Allowing large traders to take on excessive risk via swaps in many different individual securities while avoiding reporting requirements is against the spirit of the rule, and goes against the Commissions prior rulemaking. Security-Based Swap Position should include all security-based swaps based on the same underlying security or reference entity, regardless of whether they are debt (including CDS) or equity-based, so that funds and firms cannot evade reporting requirements by using different types of complex financial instruments. Daily reporting would be very much appreciated to thwart volatile mismanagement of swap activity. I hope this rule will be finalized as soon as possible to help reduce the risk that hidden swaps present to the financial system. Erwin Korsakov Retail Investor