Feb. 14, 2024
As a concerned participant in the financial markets and a supporter of transparent, fair, and stable market practices, I am writing to express my firm opposition to the proposal rule SR-OCC-2024-001. While acknowledging the purpose of the rule to codify OCC’s process for making adjustments during high volatility periods, the lack of transparency, especially the redaction of specific details related to the calculation of parameters in margin thresholds, raise serious concerns. Transparency is essential for market participants to assess the fairness and effectiveness of risk management measures. The consistent use of idiosyncratic control settings, the concentration of significant decision-making authority in the hands of a single FRM Officer, and the potential systemic risks associated with frequent adjustments during high volatility are alarming. The proposed rule, as it stands, poses a threat to reducing margin requirements by granting the OCC extensive authority to adjust margin threshold based on undisclosed parameters during critical events. Also the lack of solicited comments for public input raises questions about the transparency and fairness of the rule-making process. In a regulatory environment, active engagement with stakeholders is crucial to ensure well rounded rules that address potential concerns from different parties. I urge you to consider the suggested improvements, including strengthening, and enforcing margin requirements, introducing external auditing and supervision, incorporating public input, and enhancing transparency requirements. These measures are essential to fostering trust among market participants and maintaining the stability and integrity of our financial markets. I strongly oppose the adoption of proposed rule SR-OCC-2024-001 in its current form and encourage thorough reconsideration of its implications. Ryan Millar McCormack Contact info: Email: ryanmccormack96@gmail.com