Mar. 1, 2024
Dear Sir/Madam, I am writing this email to oppose the implementation of SR-OCC-2024-001. From my understanding, allowing this rule to pass will provide the OCC and the relevant risk management officers to 'play god' as it were in order to choose who can avoid margin requirements and who is susceptible to them. The counter to this would be that if these banks/institutions etc were to go down then the whole system might collapse. I would argue that the system is already broken if these big players aren't able to meet the current requirements. It also poses a risk to the wider market allowing this rule to be implemented as the OCC will get to decide who falls and who survives. In a nefarious scenario, the OCC could put the burden of liability on... Oh I don't know, pension funds perhaps? But maybe that is just me being cynical, time will tell. Regards, PJ