Aug. 13, 2023
To Whom It May Concern, I am writing to express my firm endorsement for the prompt adoption of Rule S7-32-10, mandating the public disclosure of all positions in security-based swaps (SBS). I firmly believe that this regulation is vital in averting potential future financial crises and in establishing an equitable and open market environment. In my personal opinion, a just market hinges on complete transparency. Concealing or clouding market positions serves no purpose unless there are questionable motives involved. Every swap position must be promptly disclosed immediately following its agreement or execution. The criteria for disclosure should be straightforward – all swaps must be comprehensively reported. This includes detailing positions, counterparties, and the terms of the agreement. Modern technology facilitates thorough supervision by regulatory bodies, thereby proactively preventing forthcoming financial turmoil. Swaps are akin to financial instruments of massive impact. The delayed reporting has already incurred substantial financial losses running into billions to trillions of dollars over recent years, and this is entirely preventable and manageable (examples: SVB, Signature Bank, FTX, etc.). I am wholeheartedly in favor of stricter reporting protocols and advocate for immediate public reporting of all swap positions along with complete accompanying information. Transparency in the market is of utmost importance. Concealing positions and data from market participants only perpetuates an uneven field, fostering an unjust advantage that leans towards Wall Street. The Managed Fund Association's (MFA) alternative proposal is merely another endeavor to shield their risky misconduct from public scrutiny. I firmly hold that all SBS positions, irrespective of size, should be openly disclosed without any exceptions to this directive. This move would significantly enhance both investor and regulator comprehension of market risks, thereby preventing the sort of market manipulation that culminated in the 2008 financial crisis. Lastly, I am of the belief that the penalties for breaching this regulation should be substantial. I recommend that transgressors be compelled to liquidate their positions, have their licenses revoked, and face a lifelong prohibition from engaging in the financial industry. This would unequivocally convey the SEC's earnest commitment to enforcing this rule and its zero tolerance for market manipulation. I beseech the SEC to promptly enact Rule S7-32-10 and fortify it to the utmost extent possible. This rule is indispensable in safeguarding investors and fostering a fair and transparent marketplace. Yours sincerely, A concerned Household Investor