Feb. 27, 2024
Dear SEC, Thank you for the opportunity to participate in advocating for greater market transparency and accountability. I am writing to express my firm opposition to proposed rule SR-OCC-2024-001. I am very concerned with the lack of transparency and redacted details related to the calculation of parameters and margin thresholds. Transparency is essential for market participants to assess fairness and effectiveness of risk management measures. The consistent use of idiosyncratic control settings and the concentration of decision making authority in the hands of a single FRM officer is both alarming and a potential moral hazard to keeping Clearing Members accountable to managing appropriate risk models. 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. Greater transparency is needed to maintain trust and keep this process from being abused. Again, I want to strongly state my opposition to the adoption of proposed rule SR-OCC-2024-001 and thank you for the opportunity to advocate for greater transparency. Sincerely, Concerned Household Investor Get Outlook for iOS