Subject: Comments on SR-OCC-2024-001 34-99393
From: Eric Ignash
Affiliation:

Feb. 2, 2024

Once again an SRO is asking for the rules to be changed so they don't fail during "Market Volatility". I say absolutely NOT! It is time for the SEC to do its job and stand up to these Bankers who have unfathomable leverage with no way of protecting their margin if there is volatility. OCC will be on the hook for trillions yet they just want to ignore the elephant in the room and they want the SEC to approve this. 
There are very few rules left for out of control banks now. Rules prevent bad conduct from getting out of control. Getting rid of rules only causes bad behavior to get worse. Margins were meant to keep banks and other leverage users from getting too deep. The OCC has to guarantee these out of control banks when they are margin called and they know that is impossible because the derivatives market is so large the FED couldn't even cover the margin.
Banks get bailed out by the American people when they are considered too big to fail. American people are never "Too big to Fail". Bill Hwang did the same thing the Banks did then got margin called and subsequently jailed. During the same time Instinet was allowed a waiver of over 500 billion. Instinet is a member of OCC. A congressional hearing was held and Instinet was not even called to testify even though they were by far the largest defaulter of that event.
I am pretty sure there will be 2 votes supporting this proposal at the SEC and the third vote will be the swing vote which will be worth the most. On a personal note to the "Swing Vote": Understand your value and profit accordingly! The minimum you should accept for selling yourself out is a guarantee of personal wealth beyond your current status. I am sure there will be another story in the NY Times congratulating a former SEC board member on their new position with a Bank or Hedge fund.
In summary, please be aware that as regulators you are required to "Regulate" the markets and set rules to prevent market volatility. This rule change only makes the margins larger. OCC members will still get a free pass when they are in trouble because OCC can't keep enough money to save even ONE defaulting member, much less all of them when One fails. Also be advised (SEC board members) that you are employed by American People who vote, pay taxes and invest in "Free and Fair" markets. These people can see through schemes and unfair rules and they know who is responsible.
This rule change can not be allowed.