Feb. 5, 2024
To the honorable Gary Gensler and SEC staff, I AM AGAINST THIS RULE CHANGE. Mr. Gensler, I'm sure you are aware that hedge funds and certain select banks are losing capital FAST. No financial institution should want a margin call. It would seem prudent, to most CFOs and senior executives, to INCREASE deposit funds into their brokerage accounts to meet increased margin requirements thus forestalling a margin call. The market has worked this way since before you and I were born. However, it seems a difficult task to achieve considering some "shaky" financial institutions are already hemorrhaging money. This rule change, SR-OCC-2024-001 is fraught with peril. In essence, this newly proposed rule recommends a REDUCTION in margin requirements when there’s high market volatility - effectively allowing Wall Street to avoid things such as MARGIN CALLS on "shaky" financial institutions and banks. This will allow "shaky" financial institutions to "kick the can down the road" - culminating in a potential market collapse. I understand that a "Failure To Comply" with margin calls can lead to forced liquidation of positions by a brokerage or bank to cover the outstanding margin debt. Most CFOs and senior executives do not consider failure, in any business aspect, as acceptable. Yet this rule allows CFO and senior executives to skate past the consequences of a short fall brokerage deposit and invites market lawlessness on a monumental scale. I recommend to you, Sir, that this new rule be withdrawn and enforce the INCREASE of "safety net deposit funds" for brokerages and banks so as to prevent a large-scale Market Calamity. Regards, William Melvin James, Jr. Independent Retired Investor and Small Business Owner