Jul. 27, 2023
Hello, I am submitting a comment regarding File Number S7-32-10. I am extremely concerned with the current state of swap reporting and enforcement of security-based swap reporting and compliance. It is my understanding that most, if not all swaps reporting comes in the form of SRO (self-regulating organizations), which has become a massive problem. The CFTC has enacted multiple pieces of legislation to ensure that swap reporting would be pushed well into the future. I believe that the SEC is not doing nearly enough investigation into the CFTC, Citadel Securities, and Rostin Behnam because I believe there is an extremely strong conflict of interest there. In addition, I believe that these swaps have been used for fraud, manipulation, deception, and undue influence. The SEC and it's Chief compliance officers have failed to do their duty and are not providing enough scrutiny in these markets. The fact that hedge fund managers can report their positions as "At Fair Value" shows a complete disconnect from open and free markets. These reports and filings need to be reviewed with the utmost discretion, as I believe there are billions of dollars worth of hedges, transactions, and backdoor swaps hidden in these derivative positions. I am urging you to please, please, please investigate the CDS market and REQUIRE all hedge funds, capital management firms, venture capitalists, investment firms, brokerages, and the DTCC to publicly disclose derivative-based, swap-based, collateral-based positions. All of these transactions should be made on a public ledger and open to daily audit by the SEC and Federal Government. I believe that many of these financial tools are being abused given the current market framework. I am a strong proponent of the rules in this proposal and would like to the record to show that I, Joshua Zimmerman, a retail investor, engineer, and informed market advocate am in favor of approval of rule S7-32-10. Anyone that has to comply with these Recordkeeping Burdens, has enough money to cover these fees. Hedge Funds, Capital Managers, and all those involved in financial markets shall be subject to additional scrutiny and bookkeeping measures. Prohibition Against Fraud, Manipulation, or Deception in Connection with Security-Based Swaps; Prohibition against Undue Influence over Chief Compliance Officers; Position Reporting of Large Security-Based Swap Positions