Jul. 27, 2023
Dear Sir/Madam, I am in full support of this proposal to prevent the evasion of the reporting rule. As a proponent of transparency, I believe the public disclosure of this data is essential in order to ensure financial and national stability. The recent Archegos Capital Management scandal is a prime example of the potential harm that can be caused by unchecked swaps, and I urge the SEC to investigate any other potential hidden surprises that may be lurking in the shadows. To further prevent evasion, I suggest that the threshold be lowered to $100 million range gross. Additionally, I would like to see this rule applied internationally so funds and firms cannot use borders to avoid its regulations. Furthermore, I believe the Commission should look at the entire swap portfolio of a trader in order to form an accurate picture of their risk appetite, rather than just parts. This will ensure that large traders cannot circumvent the rule by manipulating it in any way. Lastly, I am in favor of daily reporting and the public release of the data, as it gives citizens the opportunity to protect themselves and the companies they own from hostile actors. I implore the Commission to finalize this rule as soon as possible in order to keep our markets safe and secure. Thank you for your consideration, ZK.