Subject: File No. S7-32-10
From: Zaid Assemat

Dear SEC, I am writing to provide my comment on the proposed rule (S7-32-10) regarding the public disclosure of large security-based swap positions. I believe that increased transparency is vital for promoting financial stability and protecting market integrity. However, I also recognize that such disclosure requirements should balance the need for market oversight with the legitimate privacy concerns of market participants. One major benefit of public disclosure of large security-based swap positions is that it can deter manipulative or predatory trading practices. By requiring transparency for substantial positions, the rule can help prevent scenarios where a single market participant secretly amasses a large exposure, potentially putting counterparties and the broader financial system at risk. This kind of transparency would have been helpful in preventing events like the 2008 financial crisis, where opacity in derivative positions led to systemic shocks. However, it is crucial to consider the potential downsides of excessive public disclosure. Specifically, revealing detailed information about large positions could inadvertently expose proprietary trading strategies and put legitimate market participants at a competitive disadvantage. Competitors may exploit such information to engage in predatory trading practices, which would ultimately lead to reduced market liquidity. To address this concern, I recommend adopting a threshold that is both effective in achieving transparency and high enough to avoid unnecessary disclosure of smaller, non-systemic trades. I also support a phased approach to implementation. This would allow market participants to adjust their strategies and practices to comply with new requirements, minimizing potential disruptions to the market. Additionally, clear guidance on the scope of the disclosures and how sensitive information will be protected from misuse should be provided to instill confidence among market participants. In conclusion, while I support the public disclosure of large security-based swap positions to promote transparency and mitigate systemic risk, I urge the SEC to carefully consider privacy concerns, competitive impacts, and implementation processes to create a balanced framework that benefits the market as a whole. Thank you for considering my comments.