Aug. 12, 2023
I support S7-32-10. Given the complexity of today's financial environment, I want to stress the significance of evolving reporting thresholds. I've observed that many esteemed financial participants employ top-tier talent and utilize advanced computational systems connected to both established and emergent exchanges. In my recent review of the Reporting Threshold Amount memorandum, I found that the smallest reported swap was $70 USD. I firmly believe that the threshold for reporting any asset or debt-based swap or position should be set to $0 USD or its equivalent in any active fiat currency. It's evident to me that a daily reporting obligation for all such positions should have been legally established a long time ago. Ownership structures, whether parent or subsidiary, should not provide any exemptions from daily reporting requirements. All companies and their respective subsidiaries operating within the U.S. should adhere to these reporting standards, which include both traditional and digital assets. Every position, irrespective of its monetary value, must be distinctly reported to clearly identify both long and short stances. This would prevent potential misuse of loopholes, such as hiding high-risk assets in offshore regions with lax regulations. Given the prevalent automation and the rapid pace of transactions, end-of-day EDGAR filings should have been mandatory by now. Any objections related to the time or resources needed for these filings are likely unfounded, especially considering the automated tools at our disposal. Given the hefty profits many financial entities generate, the costs associated with updating reporting systems should be considered a routine operational expense. I recommend the commission adopt a strict approach to non-disclosure of financial assets. Every position should be transparently reported per legal entity or owner. New regulations aim to bolster transparency and fairness in the financial sector, and I believe reporting requirements should enforce end-of-day disclosures for all position activities. Moreover, penalties for non-compliance should be substantially increased, correlated with at least ten times the undisclosed position's value, and publicly documented to promote trust. In conclusion, while my primary focus remains on the U.S., I suggest the commission collaborate with international regulatory bodies. The challenges we face aren't limited to our nation, and cultivating a transparent, equitable financial environment is a global endeavor.