Feb. 15, 2024
Dear SEC members, I hope this email finds you well. I am concerned about the implications of the proposed rule, SR-OCC-2024-001. I am a participant in the financial markets and a supporter of transparent, fair, and stable market practices, and I am writing to express my firm opposition to this rule. The lack of transparency, especially the redaction of specific details related to the calculation of parameters and margin thresholds, raises serious concerns. We need more transparency in our markets, not less. Giving significant decision-making authority to a single officer (the FRM Officer), poses significant risk due to the possibility of conflicts of interest and potential for abuse of power. The proposed rule, as it stands, poses a threat to reducing margin call requirements by granting the OCC extensive authority to adjust margin thresholds based on undisclosed parameters during critical events. Furthermore, 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 adding 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. In closing, I strongly oppose the adoption of proposed rule SR-OCC-2024-001 in its current form and encourage a thorough reconsideration of its implications. Thank you for your attention to this matter Sincerely, Seth Jordan