Mar. 3, 2024
Hi, Thank you for the opportunity to comment on rule: SR-OCC-2024-001 I strongly oppose this rule, whereby the OCC can waive margin requirements. Not only are these requirements in place to protect the financial system. They should be a line for financial entities to not cross. This rule would also increase the probability of financial collapse massively. It would open opportunity to abuse an already abused and outdated financial system. High volatility is not a reason to turn a blind eye or allow entities a free pass. We should be questioning why this volatility arises, not looking for ways to allow it or make it worse. I believe too many entities run extremely high risk strategies, these practices put our markets at breaking point. Passing this rule will not only allow higher risk entities more freedom, it will also open up the high possibility of the biggest collapse and depression there has ever been. Not to mention undisclosed margin requirements is yet another transparency issue. While I wouldn’t agree with any entity having the power to move margin requirements, due to obvious avenues for foul play. Hundreds of idiosyncratic choices in a few years makes me question there ability to make the right choices. This along with global control settings indicates a proactive risk approach. We should be concentrating on strengthening and enforcing margin requirements, not weakening them. There should be extra measures put in place to make sure margin requirements adequately protect. An independent external body carrying out audits would add an extra measure. This would also make it much harder for abusing of these margin requirements to happen. It is obvious that relaxing requirements, which in essence this rule is. It’s hiding transparency and open to abuse. Everything should be scrutinised making everything clear and transparent to everyone as to make sure our markets best interests are paramount. Thanks again for the opportunity to comment and I hope this rule is seen for what it is. An attempt to relax margin requirements for some regardless of risks Involved. Kind regards Colin Riordan