Feb. 5, 2024
Dear [OCC/SEC Representative], I am writing to express my deep concern and opposition to Specific Release (SR) - OCC - 2024 - 001, particularly with regard to the proposed margin requirements outlined for short hedge funds and other relevant institutions. While I acknowledge the critical role of capital requirements in maintaining financial stability, I firmly believe that the current proposal falls short in adequately addressing the potential risks associated with short selling activities. Short hedge funds and institutions wield significant influence within the financial markets, and their actions can have widespread consequences. The existing regulatory framework heavily relies on capital requirements to curb excessive risk-taking, but I argue that enhanced margin requirements are equally, if not more, essential in mitigating systemic risks. As it stands, these funds operate with limited constraints, relying solely on capital requirements to dictate responsible behavior. Implementing stricter margin requirements would establish an additional layer of protection, acting as a proactive measure to deter excessive risk-taking and potential market disruptions. Therefore, I urge the OCC to carefully re-evaluate and potentially increase the proposed margin requirements for short hedge funds and institutions. This adjustment would not only create a more comprehensive risk management framework but also instill greater confidence in the overall stability of the financial system. I commend the OCC's dedication to ensuring the safety and soundness of the financial markets. I trust that my comments will be taken into careful consideration during the regulatory review process. Thank you for your time and attention to this matter. Sincerely, Todd LaBerge Media Producer / Hadleyhelps.org (309) 532-2418