Subject: Strong Opposition to Proposed Rule SR-OCC-2024-001 - The Exposed Threat of Margin Erosion and Risk Escalation
From: Kunuunnguaq Iversen
Affiliation:

Feb. 12, 2024

Dear SEC-

I'm reaching out as someone who cares about fair and stable financial markets. I want to express my strong disagreement with the proposed rule SR-OCC-2024-001.

While I understand the aim of the rule to clarify how OCC handles things during times of high market volatility, I'm worried about the lack of transparency. It's concerning that specific details about how they calculate things like parameters and margin thresholds are kept secret. Transparency is important so that everyone involved can see if risk management measures are fair and effective.

I'm also concerned about how much power the rule gives to just one person, the FRM Officer, and the potential risks of changing things too often during volatile times.

Plus, it's troubling that there hasn't been any chance for the public to give their input on the rule. Getting feedback from different people is crucial to making sure rules are fair for everyone.

I suggest making some changes, like strengthening margin requirements, having outside auditing and oversight, asking for public input, and being more transparent about how decisions are made. These changes would help build trust among everyone involved in the markets and keep things stable and fair.

To sum up, I strongly disagree with the proposed rule SR-OCC-2024-001 as it is now, and I think it needs to be looked at again.

Thanks for listening to my concerns.

Sincerely,
Kunuunnguaq Iversen, Cand. Psych, Auth.
e-mail: kiver83@yahoo.dk
Faroe Islands