Feb. 21, 2024
To whom it may concern, As an engaged member of the financial markets with a commitment to clear, equitable, and stable market operations, I am reaching out to voice my strong disapproval of the proposed regulation SR-OCC-2024-001. I recognize the intention behind the rule to establish a formal procedure for the OCC to adjust in times of significant market volatility. However, the proposal's lack of clear communication, particularly concerning the omission of vital details on how parameters and margin levels are determined, is troubling. For participants in the market, understanding the rationale behind risk management practices is crucial for evaluating their fairness and effectiveness. The routine employment of unique control measures, the concentration of excessive authority in a single FRM Officer, and the systemic risks posed by regular modifications in volatile periods are concerning. The rule, in its proposed format, risks undermining margin call requirements by allowing the OCC to alter margin levels based on non-transparent criteria during pivotal moments. Additionally, the absence of a call for public feedback on the proposal questions the openness and equity of the rule-making process. Engaging with all stakeholders is vital in a regulatory context to develop comprehensive regulations that consider the perspectives and concerns of all affected parties. I implore you to take into account the recommendations for enhancement, such as reinforcing margin requirements, implementing independent audits and oversight, involving public consultation, and improving transparency standards. These steps are crucial for building confidence among market participants and ensuring the resilience and integrity of our financial system. To conclude, I am firmly against the enactment of proposed rule SR-OCC-2024-001 as it is currently outlined and recommend a detailed review of its potential effects. Thank you for considering my views on this important issue. Best regards, Simon Chapman Blainroe, Ireland