Jul. 21, 2023
Dear Members of the Securities and Exchange Commission, I am writing to express my wholehearted support for Rule S7-32-10, which, in my view, is a crucial and necessary step towards enhancing the transparency and stability of the financial markets. Additionally, I strongly advocate for the inclusion of the provision mandating position reporting of large security-based swap positions, as this measure would bring added accountability and risk mitigation to the market. The financial crisis of the past has underscored the importance of maintaining effective oversight and regulation to protect investors and ensure the integrity of our financial system. Rule S7-32-10, with its focus on high-frequency trading and algorithmic trading, represents a significant leap forward in addressing some of the potential risks associated with these practices. I applaud the Commission's commitment to fostering fair, orderly, and efficient markets, which is evident in the formulation of this rule. In conjunction with the rule's emphasis on high-frequency trading, I urge the Securities and Exchange Commission to also enforce the reporting of large security-based swap positions. This additional requirement is essential in providing regulators with a comprehensive view of market participants' activities and risk exposure. By mandating the reporting of such positions, the Commission will gain valuable insights into potential systemic risks and can act preemptively to prevent market manipulation or abuse. The reporting of large security-based swap positions is not only critical for market stability but also instrumental in safeguarding the interests of individual investors and the broader economy. Transparent position reporting can help detect excessive speculation, prevent market disruptions, and ensure that market participants are held accountable for their actions. Furthermore, this data can contribute to a more informed decision-making process for investors, allowing them to make well-informed choices based on a comprehensive understanding of market conditions. I firmly believe that Rule S7-32-10, with the inclusion of position reporting of large security-based swap positions, will create a robust regulatory framework that will serve the interests of all stakeholders. By enacting this rule, the Commission demonstrates its commitment to maintaining fair and efficient financial markets that inspire confidence and trust. In conclusion, I urge the Securities and Exchange Commission to proceed with the implementation of Rule S7-32-10, accompanied by the provision for position reporting of large security-based swap positions. As a responsible and informed citizen, I am confident that this step will contribute significantly to the long-term stability and prosperity of our financial markets. Thank you for your dedication and diligence in crafting regulations that protect investors and uphold the integrity of our financial system. Your tireless efforts are deeply appreciated. Sincerely, Lee Flemm