Feb. 21, 2023
To Whom it may concern, I am against this proposal in its entirety: SR-OCC-2022-012 I am against changing rules to accommodate market participants that hedge their extremely risky investments by relying on SEC to change rules to provide them safe harbor. The changes in this rule allow for too much lenience in the business process for managing risk. One cannot cherry pick time frames for financial modeling on an ad-hoc, situational basis. That is the definition of coddling the risk takers. Removing audit and credit ratings as a means to test the veracity of a market participants' inherent riskiness is demonstrably weak in terms of ensuring orderly market functions. It emboldens risk takers, provides a means for them to flourish, and sets a negative precedent overall. The SEC can and should do better than this to protect the American People from those that would leverage their power and influence to make our financial system cater to their needs. This wreaks of corporate banker influence on the SRO activities of the SEC and I, as an impacted consumer, am resoundingly against SR-OCC-2022-012. It's both a sham and shameful. Thank You, Christopher Durand