Subject: S7-32-10
From: Anonymous
Affiliation:

Aug. 19, 2023

I would like to voice my support for proposal s7-32-10. 

Regular reporting of both swaps data and of short positions is absolutely crucial to the proper functioning of the "free market". 

Given the recent collapse of Credit Suisse, and especially given the fact that the parliamentary investigation of their wrongdoings will be kept secret for 50 years, transparency regarding swaps is completely essential in avoiding catastrophic affects on the market. 

It is also laughable that cost regarding reporting disclosures is being used as an argument against the practice. Disclosure and transparency are not things that should be a choice. The efficiency of capital markets requires expediency of reporting, and for those disclosures to take place in real time to regulatory authorities. 

The tax evasion that takes place via loopholes once stocks are delisted that allow short positions to never need to be closed out, instead being used as collateral to borrow against or as margin for future transactions is something that should be looked into by regulators. 

Any entity seeking to obfuscate their data from regulators and reduce disclosures or transparency of their swaps or short positions is doing so to reduce competitiveness in the market and give themselves an unfair advantage. They also get the benefit of being overleveraged with their trades and in some cases (archegos), have such little oversight that their lack of risk management skills turns them into a massive liability to the markets themselves. It has proven time and time again that these institutional traders and hedge funds do not have the ability to self-govern, or manage their own risks appropriately. They falsify their records, misrepresent their short positions and when all else fails seek complicated derivatives agreements with counterparties as a work around to having a direct short position so the public facing data is not affected (short interest % for example). When the regulators do not have this data it makes it near impossible for them to regulate. 

It's time to actually hold these institutions responsible for their actions, and to not allow the entire integrity of the markets to be compromised for the sake of "liquidity provision". 

Regards; 
a concerned household investor. 





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