Feb. 7, 2024
I strongly oppose the OCC's proposal on margin requirements during high volatility. It lacks transparency and unfairly benefits Clearing Members at the expense of other investors. This proposal codifies a conflict of interest for the Financial Risk Management Officer and undermines market stability. The OCC's concern about potential liquidity issues for non-defaulting Clearing Members contradicts its primary protection mechanism, making the proposal illogical. If approved, this proposal would reduce the OCC's protection against market risks. Instead, margin requirements should be increased and enforced to encourage responsible risk management. Please consider modifying the proposal to address these concerns. E-MAIL CONFIDENTIALITY NOTICE: The information transmitted in this e-mail and any attachments are for the sole use of the above individual(s) or entities to which it is addressed, and may contain proprietary, PRIVILEGED and/or highly CONFIDENTIAL information and exempt from disclosure under applicable law. Any unauthorized dissemination, review, distribution or copying of these communications is strictly prohibited. If this e-mail has been transmitted to you in error, please notify the sender immediately and delete the original message from your system. You are prohibited from copying, distributing, or using the information. Thank you for your cooperation. 1633709699