Aug. 20, 2023
As I have mentioned repeatedly in prior comments on other proposals, the "price"; to be paid for the benefits of running and participating in a public-accessible securities market MUST be public access to to all relevant securities information. Any participant's stake in a publicly-traded security, whether long or short, direct or derivative, MUST be public. As you well know, these are not expert or private markets - millions of citizens' retirement accounts have been systemically invested into these securities with the support of law, and these public markets must be operated with the level of excellence that reflects this level of public trust. Opaque schemes of swaps and entitlements warp the supply and demand that underlie public markets for securities. Anything less than full disclosure of all positions in publicly traded securities should be treated no less seriously than other categories of insider trading. Accordingly, I urge the commission to move forward with this proposal in its entirety, as well as to continue with further rules to the effect of full public transparency of ALL public security based swaps, entitlements, and other instruments. Certain members among the commission may object that the level of effort, cost or work to enable such reporting is excessive or encumbers market participants. If participants find themselves unable to report on their complex derivatives, contracts or schemes, they should not be engaged in these derivatives, contracts or schemes in the first place. While I appreciate that the commission is willing to listen to and entertain arguments from all participants, we should remember that swaps came into being as essentially a tax avoidance scheme. The *least* that swap participants could do is provide transparency.