Subject: Comment for SR-OCC-2024-OO1
From: Andrew Wooddell
Affiliation:

Feb. 4, 2024

Good Morning,

I am writing to address the suggestion made by this recently proposed rule change to address market volatility.

This proposal is being put forth because of the fear of certain market participants facing the risk of bankruptcy, their argument that they are being ‘too big to fail.’ If these entities are indeed ‘too big to fail,’ then in turn they should be ‘too big to be so reckless.’ Any risk of bankruptcy these companies face as a result of unpredicted (or well-known but postponed) movements in the market means they are taking risks they shouldn’t be. They are at risk because there is no transparency about their positions, about how over-leveraged they are.

Large financial institutions have a fiduciary duty to their customers, safeguarding the capital that is invested with them. If these institutions fail in their duty, then they deserve to suffer the consequences for their risky behaviors. Bail outs should be for the customers whose money has been fleeced by these bad players. Tax-payer money should not be used to prop up criminal lenders/traders.

We sit at the precipice of where this rule change is being considered because of wanton greed and a complete disregard for fairness and honesty. Had Wallstreet been forced to be more transparent with their reporting, this situation could have more easily been averted. We should not be passing rules and laws to continue to allow people to operate in the shadows, doing whatever they want with other people’s money. If market volatility cause them to fail, then they deserve to fail for the risks they took. That is capitalism.

You have a chance to do the right thing, to be on the right side of history. You have the opportunity to restore faith in the system that was destroyed in 2008. You have a chance to demonstrate that the interests of the American people outweigh the interest of a few.

Thank you for your time and consideration.