Feb. 3, 2024
Dear SEC, I strongly oppose the OCC's proposed margin rule change (SR-OCC-2024-001). My concerns include: Limited Transparency: Extensive redactions hinder public review and raise accountability concerns. Risk Shifting: Reduced margins protect Clearing Members but increase risk for the OCC and broader market. Too Big to Fail: Repeated margin relief creates an uneven playing field and potentially makes poorly managed Clearing Members "Too Big to Fail." Conflicted Risk Management: The FRM Officer's dual role managing both OCC and at-risk Clearing Member interests raises potential conflicts. Proposed Modifications: Increase and enforce risk-based margin requirements. Introduce external auditing and public reporting for proactive risk management. Modify the Loss Allocation waterfall to prioritize non-defaulting member deposits. These changes address transparency, risk management, and fairness concerns, contributing to a more stable market environment. Please thoroughly reconsider this proposal and its potential impact. Sincerely, Jim Carlile