Subject: S7-32-10: Webform Comments from Zachary Kolansky
From: Zachary Kolansky
Affiliation:

Aug. 3, 2023

All swaps need to be transparent. Arguably the practice
needs to be banned, because it magnifies the total risk of the
financial system to a value that is greater than the value of the
market itself. Swap risk should be calculated as if you have to pay
the full amount, (not net), and this amount should not be able to be
greater than average liquidity available at the firm. This means your
swaps go [REDACTED], they can cover the full expense without having a
fire sale on your assets. Once someone has a fire sale and decreases
the price of assets, it imperils over-leveraged margin positions and
then the system all comes down like a house of cards. [REDACTED]
for everyone who uses stocks and bonds as their retirement....

Using swaps to manage risk is creates a convoluted system of whack
mole that decreases the stability of financial system. Ensure
positions are a manageable size and no one creates a billion small
positions to hide a larger position