Subject: SR-OCC-2024-001 34-99393
From: Harvey Nelson
Affiliation:

Feb. 15, 2024

I do not like the proposed new rules. If these are passed the OCC will lose its regulatory purpose and no longer be in charge. 
These proposals are very bad for retail investors. 
The OCC still has full power and should remain with this power. (The OCC should know that they let parties off to the tune of 20 billion.) 


These proposals, if implemented, will not lower risk. They may delay risks but if anything they will add to it over a period of time by increasing systemic risk. This would encourage bad acting not discourage it. Riskier bets will be placed because the parties doing it will think they will be saved if they get into trouble. 


It would be better to update margin requirements. Instead of the exceptional 99% shortfall it should be dropped to 15% max. or better yet collateral demands of 5-10%. 


It is debatable whether or not status quo standards have been abused in the past."meme problems". 
As a retail investor I think these proposals are pivotal. If they are implemented I would seriously think of curtailing or stopping investing in U.S. securities. 


Harvey Nelson