Subject: SR-OCC-2024-001
From: BlakeOUHCOM
Affiliation:

Mar. 4, 2024

How can one effectively determine the merits of this rule when the methods used to calculate margin thresholds are not disclosed, and all the supporting evidence in the proposal is redacted? Why the need to keep information hidden? This rule seems like another nefarious attempt to protect large, irresponsible, overleveraged entities. In other words, this rule is just another link in the chain of cronyism that seems to be pervasive in the financial sector. Reducing margin requirements and preventing margin calls from occurring could allow bad bets to grow larger and thus create progressively larger, more serious systemic issues that could threaten the economy at large. This rule also attempts to give significant authority to the FRM which would create a serious conflict of interest; will they protect the OCC and its interests at the expense of the overall market? This rule lacks transparency and seems to be designed without retail investors in mind. Why am I not surprised?