Feb. 28, 2024
Dear Al,, I hope this email finds you well. As a concerned participant in the financial markets and a supporter of transparent, fair, and stable market practices, I am writing to express my firm opposition to the proposed rule SR-OCC-2024-001. While acknowledging the purpose of the rule to codify OCC’s process for making adjustments during high volatility periods, the lack of transparency, especially the redaction of specific details related to the calculation of parameters and margin thresholds, raises serious concerns. Transparency is essential for market participants to assess the fairness and effectiveness of risk management measures. The consistent use of idiosyncratic control settings, the concentration of significant decision-making authority in the hands of a single FRM Officer, and the potential systemic risks associated with frequent adjustments during high volatility are alarming. 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. Furthermore, the lack of solicited comments for public input raises questions about the transparency and fairness of the rule-making process. In a regulatory environment, active engagement with stakeholders is crucial to ensure well-rounded rules that address potential concerns from different parties. I urge you to consider the suggested improvements, including strengthening and enforcing margin requirements, introducing external auditing and supervision, incorporating public input, and enhancing transparency requirements. These measures are essential to fostering trust among market participants and maintaining the stability and integrity of our financial markets. In closing, I strongly oppose the adoption of proposed rule SR-OCC-2024-001 in its current form and encourage a thorough reconsideration of its implications. Thank you for your attention to this matter. Sincerely, Scott Price Disclaimer The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. This email has been scanned for viruses and malware, and may have been automatically archived by Mimecast, a leader in email security and cyber resilience. Mimecast integrates email defenses with brand protection, security awareness training, web security, compliance and other essential capabilities. Mimecast helps protect large and small organizations from malicious activity, human error and technology failure; and to lead the movement toward building a more resilient world. To find out more, visit our website.