Feb. 4, 2024
Dear Securities and Exchange Commission, I write to express concerns about the OCC’s proposed rule change on margin requirements during market volatility. As a long-term investor from Germany, I’m troubled that the current proposal might inadvertently shield risky positions, posing potential threats to market stability. The lack of transparency, particularly in redacted materials, hampers our ability to fully evaluate the proposal’s effectiveness. Additionally, the heavy reliance on the Financial Risk Management Officer raises concerns about a conflict of interest. To address these issues, I suggest prioritizing Clearing Fund deposits over OCC’s pre-funded resources and incorporating an independent review mechanism for unbiased evaluation. Strengthening transparency, oversight mechanisms, public input, and industry-wide standards can enhance risk management practices. As a dedicated investor, I trust the SEC will consider these concerns to craft a rule that ensures robust risk management and upholds market integrity. Sincerely Sarigul