Feb. 29, 2024
Dear SEC, I trust this message reaches you in good spirits. As someone deeply invested in the financial realm and an advocate for equitable and transparent market practices, I am compelled to voice my staunch disapproval of the proposed regulation SR-OCC-2024-001. While acknowledging the intent behind this regulation to formalize OCC’s protocols for adjustments during periods of heightened market volatility, I am deeply troubled by the opacity surrounding crucial details, particularly regarding the calculation of parameters and margin thresholds. Transparency stands as a cornerstone for market participants to gauge the fairness and efficacy of risk management measures. The consistent utilization of unique control settings, the centralization of significant decision-making authority in a singular FRM Officer, and the potential systemic ramifications linked with frequent adjustments during volatile periods are deeply concerning. As it stands, the proposed regulation poses a substantial risk by potentially reducing margin call requirements through granting the OCC broad discretion to adjust margin thresholds based on undisclosed parameters during pivotal market events. Moreover, the absence of solicited feedback for public scrutiny raises doubts regarding the transparency and equity of the regulatory process. In the regulatory landscape, active engagement with stakeholders is imperative to craft comprehensive regulations that address diverse concerns from various parties. I implore you to contemplate the proposed enhancements, including fortifying and enforcing margin requirements, instituting external auditing and oversight mechanisms, incorporating public feedback, and bolstering transparency mandates. These steps are indispensable in fostering confidence among market participants and upholding the stability and credibility of our financial markets. In conclusion, I vehemently oppose the adoption of proposed regulation SR-OCC-2024-001 in its current iteration and urge a thorough reassessment of its implications. Thank you for your attention to this pressing matter. Warm regards, Denis Kovacevic Switzerland