Aug. 19, 2023
To whom it concerns: I want to show my continued support for this rule in response to the letter submitted to the Commission by the ICI. I want to take a second to first state that I fully support the immediate implementation of this rule with a 0 dollar reporting threshold. All swaps must be fully disclosed publicly with no exception. I believe investigations of the associations and entities commenting against this proposal is a absolute minimum. Continuing to obfuscate data is at heart another form of market abuse and manipulation. Trying to control what someone sees by obfuscating data so that the entities playing in the dark can continue to skirt regulation and skim profits from unsuspecting market participants due to these disadvantages they deploy should be labeled what it is: criminal. Longs are disclosed as should all other positions ( shorts need to be disclosed and the data should not be aggregated. It is quite clear that WS does a piss poor job at risk management). This is about market integrity and transparency. This is NOT a time to focus on market participant profits. They employ and deploy the most capable and in their opinion the smartest people available in their fields. It is absurd that these entities are trying to state the commission lacks understanding regarding this rule when the commission itself has not been provided the full scope of data by these same participants! This gives a “i want my cake and eat it too spoiled vibe from the participants. This obstruction of duty must be eliminated along with regulatory capture. The ICI states on in their mission statement that they are working toward the benefit of Long Term Holders. Their objection to this rule shows at a minimum the group is misrepresenting itself to its customers. This should be viewed as manipulative, deceptive, and unacceptable. I urge the commission to again, disregard and investigate participant responses focused on the continuation of an uneven playing field. Presenting a massive AUM to try to influence a regulator in itself does not make any sense. AUM is just money being held that IS NOT THEIRS! Look to the retail investors supporting this rule and its immediate implementation with a 0 dollar public reporting threshold. These retail investors make up the Touted AUMs being thrown around by these associations and funds yer, you are seeing a stark contrast between what the Retail public(owners of the assets being “claimed to manage”) comments, and the entities that are pretending to assist, protect, or work with retail investors. We are at a turning point where the need for these rules and enforcement is so important that the lack of these rules being passed will most likely cause a mass exit from the equity markets and brokerage firms, over to transfer agents. Not only will this remove the middlemen in the equation, their AUMs will be destroyed and they will be shown naked without the assets they tout to garner and influenced power. It is the commissions duty to listen to the long investors as they are being abused by market participants. Thank you for your time Anonymous Ps. Ban PFOF, short selling, arbitrage, FTDs, off exchange trading(must trade on national exchange no exceptions) 1938 short selling rule also needs to be amended and the option to FTD needs to be removed. Secondly, the rule needs to close positions, not cover them. Please review the proposed amendments to the 1938 amendment short sell rule sent separately.