Subject: SR-OCC-2024-001 34-99393
From: Joseph Dries
Affiliation:

Feb. 9, 2024

This rule proposal codifies an inherent conflict of interest for the Financial Risk Management (FRM) Officer. While the FRM Officer’s position is allegedly to protect OCC’s interests, the situation outlined by the OCC proposal where a Clearing Member failure exposes the OCC to financial risk necessarily requires the FRM Officer to protect the Clearing Member from failure to protect the OCC. 


Sincerely Joseph Dries