Feb. 7, 2024
I firmly object to the OCC's rule proposal, highlighting my concerns regarding transparency, unfair treatment, and systemic risk. I contend that the proposal, which aims to lower margin requirements for Clearing Members, fosters an unfair marketplace and encourages excessive risk-taking. Moreover, the proposal inadequately tackles conflicts of interest and potential liquidity problems. In my view, it is imperative to reject the proposal, increase margin requirements, and enforce more rigorous risk management practices to safeguard against systemic risk and guarantee equitable treatment within the financial system.