Subject: S7-32-10: WebForm Comments from Alan Ross
From: Alan Ross
Affiliation: Retail Investor

Oct. 30, 2022


October 30, 2022

 The current arrangements allow systemic risk because over leveraged positions can be taken with multiple counter parties, and these can remain hidden until the positions become unsustainable.

It is feasible for many such one to many positions to be open, therefore presenting a huge systemic risk to the whole financial system.

Transparency in swap data and adoption of this proposal will help avoid this risk.