May 9, 2024
I support the Commission in their plan to fully implement a Consolidated Audit Trail (CAT) system on May 30th. CAT will encourage greater transparency around the use of equity swaps in capital markets by requiring prompt reporting of information related to security-based swaps positions. For added transparency, counterparties in swaps positions whether facilitated by master netting, bilateral netting, or other means should also adhere to these reporting requirements. Any failure to do so should be enforced swiftly with heavy fine, the SEC has a history of charging low fines that do not act as a deterrent. Such leniency not only undermines the integrity of the financial markets but also erodes public trust in our institutions. The enforcement of rules needs to be stringent enough that violations aren't merely brushed off as "the cost of doing business. It is my 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. Thank you for the opportunity to comment, Sincerely household investor, Nicholas Brand