Feb. 4, 2024
Dear SEC The purpose of this letter is to urge the SEC to reconsider the proposed rule, taking into account its potential implications on market participants and the broader financial system. Here’s a breakdown of the key points: Opposition to the Rule Change: The writer opposes the OCC’s proposed rule change, which pertains to adjusting parameters for calculating margin requirements during periods of high market volatility. Concerns about Transparency and Accountability: The writer criticizes the extensive redaction of details in the proposal, arguing that it hinders public review and comment. Risk to the Financial System: The proposed reduction in margin requirements is seen as potentially increasing risks for the OCC and the broader financial system. Uneven Playing Field: The writer argues that the rules create an uneven playing field, benefiting Clearing Members at the expense of other market participants. Role of the FRM Officer: The concentration of responsibility in the role of the Financial Risk Management (FRM) Officer is seen as problematic, raising questions about impartial risk assessment and management. M.Browne