Feb. 21, 2024
Hello, As an active member of the financial industry and an advocate for open, equitable, and consistent market operations, I am compelled to voice my strong objection to the suggested regulation SR-OCC-2024-001. I recognize the rule's intention to formalize OCC’s procedures for adjustments in times of market turbulence. However, the opacity of this rule, particularly its vague descriptions concerning the computation of parameters and margin levels, is quite troubling. For market players, clarity is crucial to evaluate the equitableness and efficacy of risk control strategies. The rule's frequent reliance on unique control mechanisms, the centralization of considerable power in a single FRM Officer, and the inherent systemic risks posed by regular adjustments in volatile periods are disconcerting. In its current state, this regulation risks lowering margin call requirements by allowing the OCC disproportionate power to modify margin levels based on non-public parameters during crucial moments. Moreover, the absence of a public comment period for this rule raises doubts about its openness and fairness. In regulatory settings, proactive stakeholder involvement is vital to develop comprehensive regulations that acknowledge and address concerns from various perspectives. I propose critical enhancements, including reinforcing margin prerequisites, implementing external audits and oversight, integrating stakeholder feedback, and improving transparency mandates. These steps are vital for building trust among market participants and safeguarding the stability and integrity of our financial markets. In conclusion, I firmly stand against the implementation of SR-OCC-2024-001 as it is presently proposed and suggest a detailed review of its potential effects. I appreciate your consideration of these points. Kind regards, Christopher Robles