Feb. 7, 2024
Dear Members of the SEC, I am writing to express my vehement opposition to SR-OCC-2024-001, particularly concerning the proposed margin requirements for short hedge funds and other institutions. While I recognize the importance of capital requirements in upholding financial stability, I am deeply concerned that the current proposal falls short of establishing sufficiently robust measures, especially for entities engaged in short-selling activities. Short hedge funds and institutions wield significant influence in the financial markets, and the potential ramifications of their activities cannot be underestimated. The existing regulatory framework heavily relies on capital requirements to safeguard against excessive risk-taking. However, I contend that the current proposal neglects the imperative of imposing heightened margin requirements, which are equally, if not more, essential in mitigating systemic risks. The current situation creates an environment where these funds may operate with minimal checks and balances, relying solely on capital requirements to ensure responsible conduct. Elevating margin requirements would serve as a proactive deterrent against reckless risk-taking and potential disruptions to the market. I firmly propose that the OCC critically reevaluates and amplifies the proposed margin requirements for short hedge funds and institutions. This adjustment would not only establish a more comprehensive risk management framework but also foster greater confidence in the overall stability of the financial system. It is disheartening to witness a regulatory landscape that appears to favor a select few at the potential expense of market fairness. The SEC has a duty to uphold the principles of an equitable market, and the current proposal seems to fall short of fulfilling that obligation. I implore the OCC to reassert its commitment to market integrity and take immediate action to rectify the perceived inadequacies in the proposed rule change. I trust that my comments will be accorded the attention they deserve during the crucial regulatory review process. Sincerely, Matthew G Household Investor