Comment Text:
Subject: Comment on 90 FR 19684 – Pre‑Enactment & Transition Swap Data Reform
To the Commission:
I submit this comment as a retail investor advocating for systemic transparency and market integrity. Pre-enactment and transition swaps have become a black box for abuse and used by hedge funds to obscure leverage and manipulate equity prices.
Total Return Swaps (TRS), such as those used by Citadel under Ken C. Griffin, enable massive synthetic short exposure without public scrutiny, undermining true price discovery in stocks like GameStop. Griffin has testified before Congress (Feb 18, 2021), denying use of payment-for-order-flow tactics, yet the opacity of swaps and dark-pool routing tell a different story. (See "GameStop")
I urge the Commission to require:
1. Real-time public reporting of all equity-linked swaps (TRS, variance swaps) at trade level.
2. Unique identifiers for underlying assets and counterparties.
3. No exemptions for pre-enactment or grandfathered instruments.
Without these, retail investors remain on a rigged battlefield. This is not an academic concern. This is a crisis in trust.
Sincerely,
Mike Trelski, retail/activist investor
