Subject: S7-32-10: Webform Comments from Sam William
From: Sam William
Affiliation:

Aug. 20, 2023

U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 205499–1090

Thank you for extending the opportunity to comment on S7-32-10
entitled "Prohibition Against Fraud, Manipulation, and Deception
in Connection with Security-Based Swaps" as a household investor.

I am in support of the proposed rules encapsulated in S7-32-10. First,
Rule 9j-1: this rule will dispel the current obfuscation of security
based swaps to avoid liability. There is a troubling lack of rules
related to swap based obfuscation of data and it lends to incalculable
risk taking opportunity; most prominently for institutional investors
commanding billions of capitol. Second, Rule 15Fh-4(c): an opportunity
to protect the CCO from any actions meant to deter independent and
objective decision making. An example, mitigating SBS related risk.
Third, Rule 10B-1: shining light on the largest SBS positions
potentially containing idiosyncratic levels of risk that could put the
entire market in grave danger.

Thank you for your attention and consideration.
Sam W.