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Comment for Proposed Rule 84 FR 3350

  • From: David R. Blinkly
    Swap Market Participant

    Comment No: 61999
    Date: 3/6/2019

    Comment Text:

    Why did Genslar stop reform at post-trade anonymity? It was simply too much for the market to bear at the time. Today however swap markets are more than able to handle this change; it does however fly in the face of some of Mr. Giancarlos “reform the reform” initiatives in his white paper 2.0. I met Mr. Giancarlo pre-2008 while he was counsel for GFI and he told me electronification of swap markets would never happen - true story! I also spoke with Mr. Giancarlo not long ago when he told me much of Genslars interpretations of Dodd-Frank was not what was statutorily intended by Congress. Clearly he was thinking post-trade anonymity wink wink...not!

    Simply put, the ONLY reason to not mandate post trade anonymity is to preserve inter dealer broker monopolies and dealer control of profits in swap markets. There’s not an argument that can be made to the contrary. For cleared swap product, anonymity would benefit the masses while dispersing monopolies controlling 95% of the swap market. Identification and disclosure is not needed for risk management, it’s only needed to ensure dealers control the market to the detriment, harm and inflated costs to non-dealers.

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