Sep. 10, 2023
I am in support of the Commission's desire to promote and encourage greater transparency around the use of equity swaps in capital markets with the implementation of a rule that would require prompt reporting of information related to security-based swaps positions. It is my opinion and recommendation to the Commission that reporting should be daily, at a minimum, for positions that exceed at least $10 million of the face value of a derivatives position. For further transparency, counterparties in swaps positions--whether facilitated by master netting, bilateral netting, or other means--should also need to adhere to further reporting requirements. I believe that once armed with timely and accurate information regarding equity swaps, the Commission will be better prepared to fulfill their mandate of protecting investors, maintaining fair, orderly, and efficient markets, and facilitating capital formation; for everyone. I believe it is impossible for the Commission to fully effect and enact their mandate without this time sensitive and crucial information. In closing, I would like to add that when persons, parties, or entities do not promptly file with the Commission a schedule disclosing certain information related to their security-based swap position, a fine should be applied of at least half of and/or equal to the threshold. It is my experience that the Commission's past and current fines are so insignificant, that those being fined do not take them seriously, and fines are just a & cost of doing business By effectively penalizing those who do not comply, I believe the Commissions ruling will hold greater enforcement ability, as well as serve as a deterrent to those who would not promptly report, or make a habit of not promptly reporting. Thank you for the opportunity to comment.