Feb. 11, 2023
The changes proposed reflect only that which benefits the OCC. The change from utilizing Monte-Carlo/STANS, in use since 2006 to one which does not take into account periods of high volatility and ignore significant risks, especially given the current economic uncertainty we see today. Moving to Fixed Collateral Haircuts again ignores the risks of a 2008 type event, which we should well consider a possibility, not only given current yield curve inversions, but as well what can only be described as an oncoming freight train Lehman moment with Credit Suisse. Any thought to reducing or removing transparency, auditing, credit worthiness requirements will introduce additional risk at the current time and will so no purpose at a later one, other than to introduce further risk and potential abuse. Finally, when proposals have significant redactions, which prevent the public from fully analyzing and understanding the scope of the change, they cannot be reliably put to the test of possible outcomes, or potential abuse. As such, the proposal should not be considered. Regards,