Subject: S7-32-10: Webform Comments from Kenneth D. Máyoman
From: Kenneth D. Máyoman
Affiliation: financial analyst and private jet enthusiast

Aug. 5, 2023

Dear Ms. Countryman,

I appreciate the opportunity to leave a comment to this rulemaking
proposal, S7-32-10.

If the SEC further increases transparency requirements for serious and
professional investors, those financial institutions will simply have
to resort to different measures in order to make money consistently
using the means provided by the DTCC, NSCC, CFTC, and other C's.

One such measure could be to run the price of certain stonks, such as
GameStop, for instance, up during trading hours to artificially
increase the price for registrars such as Computershare and household
investors using such registrars to direct register stonks in their own
name, rather than in street name, and then run the price down again
after the registrar has finished acquiring said stonks. Such price
run-ups could for example occur between 10:41 am ET (that's 7:41
am PT) and 11:11am ET.

Then, the SEC returns in 3 years, saying 'we have determined that
there were in fact buys and sells during that time period,'
because this is how long it takes the SEC to obtain data from and
determine fraudulent market activity by 'Self-Regulating
Organizations' (SROs).

So, please reconsider being so strict with short hedge funds and
market makers and other financial organizations that trade in swaps
and swaps-related securities, as this might backfire severely and it
might hamper any of the SEC's staff members to obtain a lucrative
senior position on Wall Street later on.

Sincerely,
Kenneth D. Máyoman