Feb. 8, 2024
I'm concerned about the lack of transparency in our financial system as evidenced by this rule proposal. I Highly Disapprove and Do Not Support its approval. The details of this proposal have been heavily redacted such as Exhibit 5, which cannot be reviewed by the public. Basically, a systemic risk exists because Clearing Members as a whole are insufficiently capitalized and/or over-leveraged. Clearing Members should not be allowed to continue to make highly risky bets and risk more than they can afford to lose. The OCC's rule proposal attempts to avoid triggering a systemic financial crisis by reducing margin requirements using "global" control settings. Fundamentally, these rules create an unfair marketplace for other market participants, including household investors, who are forced to face the consequences of long-tailed risks while the OCC repeatedly waives margin calls for Clearing Members by reducing their margin requirements yet again. Clearing Members should be subject to strictly defined margin requirements as other investors are. Clearing Member failure is a natural disincentive against excessive leverage and insufficient capitalization. As such, this proposal should be rejected. A couple of modifications that will help: 1) External auditing and supervision 2) Increase and enforce margin requirements Thank you. Sincerely, Concerned Investor