Feb. 11, 2023
To the SEC, As a retail investor who has been utilizing our capital markets for most of my adult life, these changes go against the very premise of what our markets were built on: TRANSPARENCY. Let’s start with the foremost problem in this suggested rule change, that is attempting to ‘prevent cascading margin calls’: This proposal contains significant redactions which hampers public review & comments. On these grounds alone, the proposal should be rejected immediately. But let’s move on to a close second: ANY proposal that suggests LOWERING and/or REMOVING third party credit rating requirements, significantly increases the overall risk to the OCC… this is common sense. Why on earth your offices would propose such a blatantly ridiculous rule change, when our markets are more volatile than ever, is seriously beyond me. Please do what is right and protect the individuals you’ve sworn to protect as a US Regulator. Regards, Michael Jorgensen