Feb. 7, 2024
To whom it may concern, I trust this message finds you well. As an active participant in the financial markets and a staunch advocate for transparency and stability within our market framework, I am compelled to voice my profound opposition to the proposed rule SR-OCC-2024-001. While I acknowledge the intended aim of the rule to formalize OCC’s protocol for adjusting during periods of heightened volatility, the evident lack of transparency, particularly the redaction of crucial details concerning parameter calculations and margin thresholds, presents grave concerns. Transparency stands as the cornerstone for market participants to gauge the equity and efficacy of risk management protocols. The consistent utilization of obscure control settings, the centralization of significant decision-making powers within a solitary FRM Officer, and the potential systemic risks associated with frequent alterations during volatile periods are deeply troubling. The proposed rule, in its current iteration, poses a distinct hazard by potentially diminishing margin call prerequisites, granting the OCC sweeping authority to amend margin thresholds based on undisclosed criteria during pivotal junctures. Moreover, the absence of solicited commentary for public deliberation casts doubt upon the transparency and impartiality of the rule-formulation process. In a regulatory context, active engagement with stakeholders is imperative to craft comprehensive regulations that address potential apprehensions from diverse factions. I implore you to contemplate the proposed enhancements, including fortifying and enforcing margin requisites, implementing external audits and oversight, incorporating public feedback, and augmenting transparency standards. These measures are indispensable for nurturing confidence among market participants and upholding the stability and integrity of our financial markets. In conclusion, I vehemently oppose the adoption of the proposed rule SR-OCC-2024-001 in its current guise and advocate for a thorough reassessment of its ramifications. Thank you for your earnest consideration of this matter. Warm regards, Urko Barroso urkobarroso@gmail.com