Subject: Comments on SR-OCC-2024-001 34-99393
From: Boris DaBoris
Affiliation:

Feb. 4, 2024

As I understand, the copy/pasted response I have sent previously may not actually be counted in the comments to this proposed rule change even though it is very detailed and explains my standing much better than I can do with my own words. So, I would like to re-contact the commission in regards to the mentioned proposed rule change. 



I am sternly against the proposed rule. I don't believe that the OCC needs further reductions in margin requirements, especially when they already waive the margin requirements will nilly. At least 200 times over the previous 4 years, the OCC has waived margin requirements for failing members in times of high volatility. 


As a simple retail investor, it doesn't make any sense how they are already able to do this already, and it also doesn't make any sense for them to be asking for even further reductions in transparencies. When I don't have money in the bank, the bank slams me with even further fees for overdrafting. Yet when OCC's members don't have enough money in their accounts, the OCC simply hand waves the whole thing away as if it is a simple thing that nobody should be concerned about. And those members' accounts are much larger than mine. 


In fact, not only am I against the proposed ruling, I believe the OCC needs to have further pressure put on them to actually enforce their margin requirements as they stand. The "Too Big to Fail" scenario should not apply here when the members themselves are taking on bigger and riskier bets simply by the OCC's current stance of waiving margin requirements. Further de-regulation would lead to even bigger and even riskier bets coming from the same members. 


Additionally, I believe that external auditing and supervision should be taking place with enhanced public reporting to ensure that risks are identified and managed before they become systemically significant. 


Sincerely, 
I would like to remain anonymous