Feb. 6, 2024
Subject: Urgent: Strong Opposition to Proposed Rule SR-OCC-2024-001 - Unacceptable Lack of Transparency To Whom It May Concern: I trust this email reaches you in a state of urgency and awareness. I am writing to vehemently express my unyielding opposition to the proposed rule SR-OCC-2024-001, and my frustration at the blatant lack of transparency evident in this proposal. The redaction of specific details, especially those pertaining to the calculation of parameters and margin thresholds, is utterly unacceptable. How are market participants expected to make informed decisions when crucial information is withheld? The opacity surrounding this rule is a glaring red flag, and it reeks of a disconcerting lack of openness and accountability. The consistent use of idiosyncratic control settings, coupled with the concentration of decision-making authority in a single FRM Officer, poses an egregious risk. This level of unchecked authority is a recipe for conflicts of interest and potential abuse of power. It is inconceivable that a single individual can wield such power without robust checks and balances. Furthermore, the absence of solicited comments for public input is a slap in the face to the principles of transparency and fairness. Engaging with stakeholders is not just a nicety; it is a fundamental necessity in ensuring that rules are comprehensive, representative, and consider the diverse perspectives of those affected. I implore you to consider the suggested improvements seriously. Strengthening margin requirements, incorporating external auditing, engaging in public consultations, and enhancing transparency are not optional; they are imperatives. The current state of this proposed rule undermines the very foundations of a fair and stable financial market. In conclusion, I am asking for a reevaluation of proposed rule SR-OCC-2024-001, with immediate attention to addressing the glaring deficiencies in transparency and accountability. The financial well-being and confidence of market participants are at stake, and this matter cannot be taken lightly. Thank you for your prompt attention to this urgent matter. Sincerely, Luke Gerald