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Comment for Public Information Collection 87 FR 37839

  • From: Brian Herrmann
    Organization(s):
    NA

    Comment No: 69555
    Date: 8/23/2022

    Comment Text:

    I understand that this is a push for increased efficiency. While I hope that in the long run, a blockchain type solution would be optimal in a situation like this, what is presented is harmful to the public.

    Getting rid of reporting requirements makes it much harder to investigate dishonesty and makes it much easier for unethical decisions to be made - whether intentional or not.

    The figures being reported are already calculated for internal processes, reporting them is not an undue cost. Transparency must be paramount in the digital age when dark pools, swaps, and the internalization of orders by a few colossal players puts the wellbeing of the public, and their retirement accounts, at risk.

    Requesting this reporting change at this time in such a tumultuous market raises questions as to the motive. Why now? Why make public accounting more difficult right after the largest stimulus packages in American & global history?

    I firmly think this is a bad change and it should be rejected.

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