Jul. 20, 2023
To whom it may concern, I am commenting on this because I believe in a fair and open market. If that is the case, then we need true transparency and honesty in them. I strongly support this proposal and praise the effort in preventing evasion of the reporting rule. I strongly support transparency and the PUBLIC disclosure of this data. I am concerned that excessively large swaps are a threat to financial and national stability. Please look into Archegos Capital Management and other potential hidden threats that are in the derivatives market. I hope to see more rules like this in the future. I request that the threshold be lowered to S100 million / $200 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 (e.g. 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. I also support applying this rule internationally so funds and firms cannot use borders to evade the rules of the market. I suggest looking at the entire swap portfolio to determine reporting requirements, not just parts: *The Commission should follow the precedent in Rule 13h-1, which identifies "large traders" using the trader's entire position in all National Market System securities. The overall picture of a trader's 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 Commission's prior rulemaking. The Security-Based Swap Position includes 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. I agree with the definition of security-based swaps and it must be appropriately wide to minimize evasion. I am worried about the future of our economy. Fraud is rampant to an extent that will cause something to break. The working class feels like, and they are angry. If you want to hold any hope for a bright future, it must come from good people standing up for something. If money can buy the destruction of others, then we are no better than the worst of this world. Let's not allow "fines" to be a pass for evil and illegal activity. Do something to stop abusive swap positions from choking out the soul of our markets. Trusting you to do what is right, -- Todd LaBerge Media Producer / Hadleyhelps.org (309) 532-2418