AFREF sent a comment to the Securities and Exchange Commission calling for the agency to close long-running loopholes that have enable certain hedge funds to use swaps and derivatives to avoid disclosing large positions which in turn lead can unnecessary lead to coordinated attacks on companies and unnecessary volatility in the underlying prices of certain companies’ stocks. The implosion of family office Archegos Capital is emblematic of such a problem as its use of certain derivatives to build over an over 10% position of a company’s outstanding shares were never revealed until after it was forced to unwind and leading Globally Systemically Important Banks (G-SIBs) to take over $10 billion in losses as a result.

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