March 21, 2022
Vanessa Countryman, Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-1090

Re: Notice of Proposed Rulemaking on the Prohibition Against Fraud, Manipulation, or Deception in Connection with Security-Based Swaps; Prohibition Against Undue Influence over Chief Compliance Officers;
Position Reporting of Large Security-Based Swap Positions (File No. S7-32-10)

Dear Ms. Countryman:

The Institute of International Bankers (“IIB”), the International Swaps and Derivatives Association (“ISDA”), and the Securities Industry and Financial Markets Association (“SIFMA”) (together, the “Associations”)1 appreciate the opportunity to provide comments to the Securities and Exchange Commission (the “Commission” or “SEC”) on the security-based swap (“SBS”) position reporting requirements set forth in Proposed Rule 10B-1 under the Securities Exchange Act of 1934 (the “Exchange Act”) and proposed Schedule 10B, as reflected in the above-captioned proposed rulemaking (the “Proposed Rule”).2

INTRODUCTION AND EXECUTIVE SUMMARY

We support transparency reforms that are properly calibrated to make markets more efficient and competitive. We also believe it is appropriate for the Commission and other regulatory authorities to obtain such information about market activity as is necessary to monitor for risks to financial stability or market integrity. Regulation SBSR3 is already intended to achieve these objectives through comprehensive reporting and public dissemination of SBS transactions. Regulation SBSR complements a comprehensive set of SBS market reforms, including margin requirements.

1 Descriptions of the Associations are included in the attached Appendix.

2 SEC Release No. 34-93784 (December 15, 2021), 87 Fed. Reg. 6652 (February 4, 2022).

3 17 C.F.R. § 242.900 et seq.