Feb. 11, 2023
I am against the proposed changes in SR-OCC-2022-012. This proposal appears to be trying to diminish risk protections for the OCC by weakening risk mitigation measures (such as ignoring third-party credit rating worthiness), while simultaneously trying to alter the collateral requirements in a way that ignores long-tail risks (which are quite relevant given the manifold indicators of economic instability around the globe). Additionally, I am against any changes to legal policy that contain information redacted from public view. This proposal does not appear to be in the public's best interest, and redacting supporting exhibits (almost entirely) merely inflames the already overwhelming distrust in the fairness of American markets. Rob Doherty