May 7, 2024
I am pleased to have read that the Commission is "providing notice of the grounds for disapproval under consideration" for the proposed rule change by the OCC. As I have mentioned before, under 34-99393, the OCC's position appears to be wishing to grant themselves the ability to reduce margin requirements for their clearing members during volatile markets; they also seem to have redacted the mechanisms behind their proposed rule change. This would grant them the extraordinary ability to keep avoiding a default on a liability they themselves are responsible for; and once said liability would grow to sizes large enough to be deemed an idiosyncratic risk for the entire financial sector, I can only assume the end goal would be to shift responsibility from themselves, and unto me, the taxpayer. Please summarily reject the OCC's proposal, and enforce, if not increase, margin requirements to dissuade irresponsible behavior by clearing members in order to foster healthy, transparent, and fair markets. Thank you.