Jun. 29, 2023
I personally believe that a fair market should have 100% percent transparency. There is no need to hide or obfuscate a position in the market unless it is below board. All swap positions should be reported immediately after itt is agreed on / executed. The Threshold should be a simple qualifier. Any SWAPS must be FULLY reported. Including positions, counter parties and terms of the agreement. The technology exists to allow for full monitoring by regulators which in turn will help prevent the next financial crises. SWAPS are financial weapons of mass destruction. The delayed reporting already cost us billions to trillions of dollars in the past few years and it is all avoidable and manageable (SVB, Signature bank, FTX, ETC). I am 100% for stricter reporting guidelines and am proposing that all SWAP positions be reported immediately with all information publicly reported as well. Market Transparency is crucial. Allowing positions and DATA to be hidden from market participants does not create a level playing field, it continues to promote an unfair advantage bias towards Wallstreet. ALL SWAPS NEED TO BE REPORTED In general, the Commission requests comment on the proposed Reporting Threshold Amount for each asset class (e.g., equity security-based swaps, CDS, non-CDS debt security- based swaps, etc.). Asking for threshold amounts and not having a created measurement structure already? I don't know how to create one but would say all of these need to be reported at creation. F having a threshold. That is how ppl sneak past and through cracks. With respect to each asset class, should the Reporting Threshold Amount in any final rule be higher or lower than the proposed Reporting Threshold Amount if: a. Consistent with the Proposed Rule, such final rule requires, at an interim threshold, the inclusion of the value of related securities owned by the holder of the security-based swap position in the calculation of the Reporting Threshold Amount? (This looks like to me they are allowing all securities included in the swap held outside the swap to be used in the calculation. Hedging in a sense?) b. Such final rule does not require the inclusion of related securities owned by the holder of the security-based swap position in those calculations? c. Such final rule permits offsetting of security-based swap positions with identical terms (e.g., offsetting long positions with short positions, but only if the security-based swap positions reference the same product identifier)? Positions being hedged with more positions.... NOOOOO. The example is a LONG POSITION offsetting a short position here.. GTFO. There SHOULDNT BE OFFSETTING as this complicates the swap even more making it even more dangerous imo. d. Consistent with the Proposed Rule, such final rule requires aggregation of security-based swap positions by any person (and any entity controlling, controlled by or under common control with such person) or group of persons, who through any contract, arrangement, understanding or relationship, after acquiring or selling directly or ? 6 indirectly, any security-based swap, is directly or indirectly the owner or seller of a security-based swap position that exceeds the Reporting Threshold Amount? I personally think that itemization is just as important here. Aggregation will not provide all info needed to ensure market integrity or transparency. e. Such final rule does not require aggregation of security-based swap positions across entities that are both separately legally established and capitalized (unless a guarantee exists)? This is HOW CITADEL GETS AWAY WITH THEIR HEDGEFUND/MARKET MAKER BULL! ALL SWAP DATA NEEDS TO BE PUBLIC REGARDLESS OF THE ENTITY PARTICIPATING IN THE SWAP! f. Such final rule does not require aggregation of security-based swap positions across entities that are both separately legally established and capitalized (unless a guarantee exists), unless acting as a group with a common purpose? All data needs to be immediately released. No safe havens for any SWAPS nor Participants g. Such final rule requires aggregation of security-based swap positions established by transactions effected for such person’s own account and of security-based swap positions established by transactions effected for the account of others, when that person shares in the economic risk in the other accounts or otherwise controls the account? ALL positions NEED TO BE REPORTED h. Such final rule does not require the Reporting Threshold Amount to include security-based swap positions entered into by a person with an entity or person controlling, controlled by, or under common control with that person? The reporting threshold amount should include Security based swaps regardless of the controlling entity/persons i. Such final rule requires or does not require aggregation or inclusion of transactions pursuant to any combination of the options listed in items (a) through (h) above? ALL SWAPS NEED TO BE REPORTED REGARDLESS of WHO or WHERE it was created.