Feb. 9, 2024
I have several concerns about the OCC rule proposal, I highly oppose the proposal and do not support it's approval!! I'm concerned about the lack of transparency in our financial system as evidence by this rule and comment on this proposal, amongst others. The details of this proposal along with the supporting information are significantly redacted which prevents public review making it impossible for the public to meaningfully review and comment on this proposal, and should be rejected on that basis alone. These rules create an unfair marketplace for market participants, especially retail investors, who are forced to face the consequences of long tail risks while the OCC repeatedly waives margin calls for for CLRARING MEMBERS by repeatedly reducing their margin requirements. For this reason, this rule proposal should be rejected and Clearing Members should be subject to strictly defined margin requirements as other investors are. Bottom line, increase and enforce margin requirements commensurate with risks associated with Clearing Member positions instead of reducing margin requirements . Clearing Members should be encouraged to position their portfolios to account for market stressed conditions and long-taled risks. This rule proposal currently encourages Clearing Members to become to Big to Fail in order to pressure the OCC with excessive risk and leverage into implementing idiosyncratic controls more often to privatize profits and socialize losses.