Feb. 21, 2024
Hello, and thank you for taking the time to read this comment. As an active participant in financial markets who values transparency, fairness, and stability within our market framework, I am compelled to share my firm stance against the proposed regulation SR-OCC-2024-001. While I understand the intent behind this regulation—to establish a framework for the OCC to adjust operations during periods of heightened market volatility—I am troubled by the lack of transparency, particularly regarding the redaction of specific details pertaining to parameter calculations and margin thresholds. Transparency plays a vital role in allowing market participants to gauge the equity and efficacy of risk management protocols. The consistent utilization of unique control settings, the concentration of significant decision-making authority within a single FRM Officer, and the potential systemic risks associated with frequent adjustments during volatile periods are causes for concern. As it stands, the proposed regulation raises the specter of reducing margin call requirements by granting the OCC broad discretion to modify margin thresholds based on undisclosed parameters during critical junctures. Additionally, the absence of solicited feedback for public scrutiny calls into question the transparency and fairness of the rule-making process. In regulatory contexts, active engagement with stakeholders is paramount to crafting well-informed regulations that address the concerns of various parties. I implore you to consider implementing suggested enhancements, such as reinforcing and enforcing margin requirements, instituting external auditing and oversight mechanisms, incorporating public feedback, and augmenting transparency mandates. These measures are indispensable for fostering confidence among market participants and upholding the stability and credibility of our financial markets. In conclusion, I staunchly oppose the adoption of regulation SR-OCC-2024-001 in its current iteration and urge a comprehensive reassessment of its implications. Furthermore, I have sent my strong opposition to this proposed rule to my local representatives Alex Padilla, Dianne Feinstein, Linda Sanchez, Young Kim, Michelle Steel, Lou Correa, Katie Porter and Mike Levin. Thank you again for your time. Sincerely, Armon Rohani, (619) 512-8077