Subject: SR-OCC-2024-001 (opposition to implementation)
From: Jeffrey Scott
Affiliation:

Mar. 2, 2024

Dear Sir/Madam, 


I am writing this email to express my opposition to the implementation of SR-OCC-2024-001. 


Based on my understanding, if this rule is passed, it would grant the OCC and the relevant risk management officers the power to determine who can bypass margin requirements and who must adhere to them. Essentially, they would have the authority to make decisions akin to playing god. 


On the contrary, some may argue that if these banks or institutions were to fail, it could lead to the collapse of the entire system. However, I believe that if these major players are unable to meet the current requirements, it indicates that the system is already flawed. 


Furthermore, implementing this rule poses a risk to the broader market, as the OCC would have the discretion to decide which entities survive and which face potential downfall. In a worst-case scenario, the OCC might shift the burden of liability onto pension funds, for instance. However, this could just be my cynical perspective, and only time will reveal the true consequences. 

Best regards, 








Jeffrey Scott 
Agent 
Ca License # 4183576 
777 Westchester Avenue 
White Plains, Ny 10604 
M 914-309-4826 
jscott05@ft.newyorklife.com 


https://www.newyorklife.com/agent/jscott05 







If you do not wish to receive email communications from New York Life, please reply to this email using the words "Opt out" in the subject line. Please copy email_optout@newyorklife.com.