Feb. 21, 2024
Hello, I am reaching out to express my deep concern regarding the proposed rule SR-OCC-2024-001 as a participant in the financial markets who values transparency, fairness, and stability. While I understand the intent behind the rule to establish OCC’s protocol for making adjustments during periods of heightened volatility, I find the lack of transparency troubling. The redaction of specific details regarding parameter calculations and margin thresholds raises serious concerns as transparency is crucial for market participants to evaluate the effectiveness and fairness of risk management measures. The reliance on idiosyncratic control settings, the concentration of decision-making authority in a single FRM Officer, and the potential systemic risks associated with frequent adjustments during volatile periods are all causes for alarm. The proposed rule grants the OCC extensive authority to adjust margin thresholds based on undisclosed parameters - this poses the threat of reducing margin call requirements without sufficient oversight. Moreover, the absence of solicited comments for public input raises doubts about the transparency and fairness of the rule-making process. In regulatory matters, engaging with stakeholders is vital to crafting comprehensive rules that address concerns from various perspectives. I urge you to consider implementing improvements such as strengthening margin requirements, instituting external auditing and supervision, incorporating public input, and enhancing transparency requirements. These measures are essential for fostering trust among market participants and upholding the stability and integrity of our financial markets. In conclusion, I strongly oppose the adoption of proposed rule SR-OCC-2024-001 in its current state and urge a thorough reconsideration of its implications. Thank you for your attention to this important matter. Logan Huacuja logan.huacuja@proton.me