Aug. 13, 2023
Dear Sir/Madam, I hope you're well. I'd like to discuss the Reporting Threshold Amount, which currently requires reporting for swaps above a specific value. To promote transparency and fairness in finance, I propose removing this minimum requirement. I believe that all transactions, no matter their size, should be openly reported. To achieve this, I suggest implementing daily reporting for all positions, applying to both major corporations and smaller entities. This reporting principle should cover all types of positions, including traditional and digital assets. To prevent hiding high-risk assets, it's crucial to introduce separate reporting for all positions involving financial stakes, regardless of gains or losses. This measure will effectively counter any attempts to obscure risky assets. Changes in position size, whether involving gains or losses, should be automatically reported daily. Given today's technological capabilities, adopting daily reporting is both practical and beneficial. To improve efficiency, the focus should be on leveraging technology rather than relying solely on manual efforts. Leading financial entities should comply with regulations and update their systems, eliminating the need for fines. Reporting all financial assets, no matter the size, is of utmost importance. For fairness, mandatory reporting should apply daily, regardless of the transaction's value, whenever a position is modified. To ensure accountability, penalties for non-compliance should be significant and proportionate to the unreported position's size. This information should be made public. This approach will foster confidence in the financial system and encourage collaboration with reliable partners, ultimately rebuilding market trust. I urge the Commission to champion transparency and fairness in finance, both nationally and globally, by guiding other countries in their efforts to enhance market integrity. Best regards, Rider, Confer, Squires Families