Feb. 8, 2024
SUBJECT: SR-OCC-2024-001 FROM: Mark Seeds AFFILIATION: Feb 8, 2024 I vote no to this rule proposal because it does not help in any risk control, it just temporarily contains it and increases risk in the long-term. This encourages bad behavior, and incentivizes more people to live in the risk area because they know if the criteria is met, they will be saved and they will play riskier bets. Down the road this causes more future programs and it creates a greater systemic risk in the future. Instead of this rule, update margin requirements to need more collateral. There is currently a 99% expected shortfall, to drop that lower from 99% to 5%-10%, you should be required to deposit more collateral to lower this expected shortfall amount. Hedge Funds should not be let off the hook, because they have too much expected shortfall and they made a bad decision and took too much risk and overleveraged themselves. The OCC in the past has shown that they have not abused this authority, in the current guidelines, they have not been an abusive tool so there is no reason to make the change. This changes the OCC’s ability on when and where to implement global settings only when it is ethically appropriate and necessary. Respectfully, Mark Seeds