Jul. 22, 2023
Dear SEC, I agree with this proposal. I work with data and reporting. Accurate data helps people make better informed decisions, see trends, and understand what is happening. A very important part of reporting is if bad data has been inputted, then bad reporting is the result. There are organizations that “accidentally” mark shorts as long and use (in my opinion) shady accounting practices. The SEC wants to “require any person with a security-based swap position that exceeds a certain threshold to promptly file with the Commission a schedule disclosing certain information related to its security-based swap position”. What is to prevent an organization from not disclosing information because it isn’t a person? It is important to have auditing and accountability to people and/or organizations that purposely provide bad data or “fail to deliver” disclosure. The fines must be much larger and the accountability must be stricter. Organizations that historically have and continue to cheat, steal, and lie cannot get away with “cost of business” fines and slaps on the wrist. Thank you for taking the time to read my comments. Sincerely, Edwin