Aug. 17, 2023
Dear Sir/Madam, Good morning. The letter sent in opposition by a few individuals of Congress angers me. They hold an essential position in forming our nation's policies. It is of most extreme significance that you simply prioritize the well-being of household investors and guarantee fair markets, instead of catering to the interests of the 0.1%. The recent reaction from a few individuals of Congress against the proposed changes in detailing necessities is concerning. By contradicting this crucial change, they are not aligned with the interests of household investors or their wellbeing in a fair market. Their position raises questions almost their commitment to shielding the judgment and soundness of our financial framework. I am the silent majority that has been pushed too far by their response. It is vital that we implement stricter reporting controls, as illustrated by the recent Archegos Capital debacle, can lead to systemic failure. We cannot manage to disregard the lessons learned from such disastrous events. The proposed changes seeks to address loopholes and vulnerabilities that allow high-risk practices and concealment of assets. By contradicting these changes, a few individuals of Congress are inadvertently permitting the continuation of practices that jeopardize the financial well-being of ordinary investors and citizens alike whom are not involved in our markets. I support your position on security based swaps, and security loans, and stand immovably in support of straightforward markets and the interests of independent household investors. The proposed reforms aim to level the playing field, diminish the potential for market manipulation, and ensure greater accountability for financial institutions. By supporting for stricter reporting requirements and effectively working to implement these changes, you've got the opportunity to restore confidence in our financial system. Usually not as it were pivotal for the well-being of individual investors but also for the overall soundness and success of our economy. As we all know, participants in the financial system employ highly qualified workers and very complex and powerful computer systems and networks connected to dozens of formal and informal exchanges (crypto, digital asset exchanges). For the reporting threshold sum memorandum analysis, which indicates that the minimum reported exchange is USD 70, the minimum reporting requirement for an asset or liability or position is USD 0 or any other legal currency used. According to the law, the daily reporting of all posts should have been automatically ensured daily years ago. The fact that such positions are held by either parent or subsidiary companies should not create exemptions from the laws related to the daily reporting of assets, exchange or liability positions. All companies and their subsidiaries should be required by law to report all positions, regardless of the domicile of subsidiaries or legal entities, when they operate on US soil in regulated or unregulated markets/exchanges. Both traditional assets should be exclusively reported together with positions in digital assets. All cash positions, whether positive or negative, should be reported separately, both long and short, to avoid loopholes or technicalities hiding high-risk assets with zero-balance positions through subsidiaries, shell or shelf companies. Today, players in the global financial system make dubious reports and fraud/security laws through so-called offshore safe havens. Any changes in position size, whether positive or negative, should be automatically reported by the end of the trading day. As mentioned earlier, with computer systems, high-speed trading and networks almost everything is automated, filing EDGAR reports at the end of the trading day should have been required by law a year ago. Any complaints about the number of hours lost processing these events should be considered false. In particular, the trick should be the cost calculation based on hours used, where the entire system automation counts the person doing the work, and only a fraction of the cost of implementing new basic functions is considered. As most financial participants employ their own IT departments, these costs to implement reporting requirements should be considered as "cost of doing business." As they make hundreds of millions and billions of profit per year and are more happily paying millions of fines regarding financial malpractice, as defined by FINRA rules then spend a fraction on abiding the law set forward in this rule by implementing some new computer code. The Commission must take a zero position against non-declaration of both positive and negative traditional or digital financial assets. All positions, without exception, must be submitted separately by legal entity/owner. Considering all the new rules designed to make the financial system more transparent and fairer for ALL market participants, this reporting rule should be established without a threshold and at the end of each banking day when a position is opened, modified or closed. Also, the penalties for violating these rules should be increased to at least ten times the value of the unreported position per violation and should be made public so that all participants can do business in the United States with trusted intermediaries or partners. restore confidence in the financial system. The Commission should also take the opportunity to assist and/or guide financial regulators in other countries to help them create more open and fair markets, as the problem is not limited to the United States. We encourage you to prioritize the best interests of household investors over the concerns of a select few. Grasp this opportunity to illustrate your commitment to a fair and transparent financial system that protects the livelihoods and investments of everyday Americans. Together, let us work towards a future where systemic failures are avoided, market fraud and abuse are curtailed, and household investors can believe in the integrity of our financial markets. Best Regard, Norman