Feb. 8, 2024
I vote NO to this rule proposal because it does not help any risk control. It temporarily contains it but adds to it in the long term. It creates a greater systemic risk in the future. This also encourages bad behavior. It encourages high risk leverages because they know if the criteria is met, they will be saved on their riskier bets. Instead of this rule, update margin requirements to be increased. In your own document it states that you would expect a 99% shortfall! The effort should be to lower your shortfall risk by increasing margin requirements so your shortfall risk would be lowered to 5-10%. You should be required to deposit more collateral to lower this expected shortfall amount. If you are currently expecting a shortfall amount of 99% in times of volatility, how can you NOT raise margin requirements? What you need to raise is transparency in the markets. These types of proposals and rules are the very things that make investors distrust wallstreet. This tells the investors that you will NOT hold the bad actors accountable for their actions. They got away with the Gamestop/memestock pulling the buy button once before by not giving a margin call, and now you are trying to permanently protect the very people who are overleveraging and creating systematic risk by making that the rule. I absolutely oppose this rule and DO NOT SUPPORT IT'S APPROVAL! Leanne Packard