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Comment for Public Information Collection 87 FR 64205

  • From: Mark Williams
    Organization(s):
    Government of Canada

    Comment No: 70981
    Date: 12/14/2022

    Comment Text:

    The ability for institutions and individual investors to assess the solvency and financial condition of a potential fiduciary, broker or bank is critical to proper risk assessment and hedging. Increased transparency into the swap and derivative exposure of market participants and market makers is a critical step in providing a proper view into this risk class. The requirement to provide timely and accurate reporting and the timely dissemination of this information to the investing public is a small burden compared to the potential systemic risk of these positions remaining hidden from the market.

    In the technological age we find ourselves, there is no need for paper however the need for transparency has become ever more present as obfuscation of information is happening far too frequently. Delays in providing information becomes a bureaucratic process instead of a technological one; The year is 2022. We have just landed on the Moon several times, transferred the entirety of information through the internet in a literal second, and are making strides towards fusion reactors. We have cars that run entirely on electricity, and rockets that land themselves.

    There is no reason that any reporting of any kind needs to take more than a day or two at most, especially considering the entities that wish not to reveal this information are often the ones who most need to.

    It is fundamental that swaps reporting be as quick, transparent, and as detailed as possible for a variety of reasons. There is no valid excuse NOT to report this information from a technical perspective.

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