Aug. 13, 2023
I am writing in support of this proposal - at a minimum - but penalties for violations should be stronger. The punishments do not go far enough to prevent violations and simply make the fines a "cost of doing business" to prevent a greater loss. Since the rule is covering fraudulent behavior and failing to prevent the fraudulent behavior undermines the integrity of the entire market, these rules should have strong consequences. I suggest that first time violators become restricted from swaps (SBS) for a period of time (1 year) and the swaps that were performed in violation are reversed (so that they, in essence, never happened). Allowing the SBS allows the very activity that this rule is attempting to prevent. Also, since the perpetrators are capable of subsecond transactions and algorithmic trading, there is no reason that the reporting shouldn't be the "same day" as the transaction.