Subject: SR-OCC-2024-001 34-99393
From: Robert Dudley
Affiliation:

Feb. 8, 2024

All Concerned, 


Turning back the clock and removing rules created specifically for volatile, risky markets and requirements for margin is a bad idea. The potential consequences could be devastating to the economy. Noone wants to see Lehman Brothers 2.0. If hedge funds and/or banks have overleveraged themselves, then they made their own bed, let them lay in it. Shielding their risky positions during market volatility just adds to the problem, it doesn't fix the problem. 


This is a conflict of interests inherent in the role of the Financial Risk Manager (FRM) Officer, and the lack of transparency due to redacted materials accompanying the proposal should constitute reason enough to deny this new rule. The SEC is supposed to protect the retail investor, not the institutions, and after the past three years of failures I now feel that I must get involved in these matters. 


Risk management mechanisms such as margin calls serve a necessary function. Without these mechanisms leverage could potentially get out of control, however, if recent reports of hedge funds with over 2,000% leverage are true than I would suggest things are already out of control, and the SEC must put a stop to these financial terrorists. This proposal would undermine the mechanisms put in place specifically to protect retail investors from over leveraged hedge funds and banks. 


I propose the implementation of an independent review mechanism to ensure impartial evaluation of control settings. Impartial means someone outside the banking and hedge funds financial rotating circles of personnel. We need enhanced transparency measures on the market, not redacted information for setting policies. Public input is extremely important in the decision making process, and retail investors must have a voice in this. Industry-wide standards and best practices that promote market stability must be maintained and improved upon, not torn down! 


I am now committed to fostering a financial environment that prioritizes fairness and transparency. The citizens of the United States are waking up to the corruption that occurs behind the proverbial curtain. Thank you for considering my concerns during your rule making process. 


Regards, 
Robert Dudley