Oct. 31, 2022
October 31, 2022 I absolutely support the transparency and public disclosure of swaps reporting information. The only way we will prevent another worldwide financial catastrophe is by sharing information, it's as simple as that. If there had been transparency before 2008, the massive baskets of mortgage-backed-securities and the credit default swaps bought to insure them would have come to public light and members of our legislative bodies could have been warned. Instead, the opacity continued until it was far too late and our elected legislature were forced to use the collective money of our entire country to settle the gambler's debts. Lives were ruined. We have now an opportunity, and I believe the SEC is making the right decision in using what authority they have to enact rules which require the type of transparency which could help prevent another global financial crisis. I would request the threshold for reporting be lowered to $100 million, there are so many ways swaps can be categorized and broken down into smaller swaps to avoid the new requirement. We cannot allow that to happen or it will negate the benefit of the regulation entirely. The United States of America should be setting the example for other nations. If we want our country to be the golden standard, we must hold the companies and financial institutions operating within our borders to a higher standard. Profits won through taking advantage of a lack of transparency or regulatory exceptions built into the market structure lay the groundwork stoking fraud, criminal activity, and eventually stakes so high that our government must again weigh the decision to intervene to prevent full-scale societal collapse. This can all be avoided by simply increasing transparency. 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 to tal 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 rules established. I agree with the definition of security-based-swaps. I agree with daily reporting and praise the Commission's public release of data. This is what must be done, I applaud the current administration for taking this action and fully support it.