May 10, 2024
Dear Securities and Exchange Commission I am writing to express my full support for the recent decision made by the U.S. Securities and Exchange Commission (SEC) to reject the proposed rule change by the Office of the Comptroller of the Currency (OCC). The decision aligns with crucial principles of transparency, risk mitigation, and investor protection, which are paramount in maintaining the integrity and fairness of our financial markets. Transparency is the cornerstone of any well-functioning financial system. The lack of transparency inherent in the OCC's proposal raises significant concerns about the potential for market distortions and unfair advantages for certain market participants. Investors rely on transparent and reliable information to make informed decisions, and any deviation from this standard undermines market confidence and efficiency. Furthermore, the proposed adjustments to margin requirements, particularly during times of market volatility, pose substantial systemic risks. Margin requirements play a vital role in ensuring the stability and resilience of financial institutions and markets. Any abrupt changes to these requirements could amplify market fluctuations, exacerbate systemic vulnerabilities, and ultimately jeopardize the financial well-being of investors and the broader economy. Equally troubling is the perceived conflict of interest inherent in the role of the Financial Risk Management (FRM) Officer. The potential for conflicts of interest undermines the objectivity and effectiveness of risk management practices, ultimately putting investors at risk. Maintaining clear and robust governance structures, free from conflicts of interest, is essential for fostering trust and confidence in our financial markets. The SEC's decision to reject the OCC's proposed rule change reflects a commitment to upholding the highest standards of market integrity, transparency, and investor protection. By prioritizing these fundamental principles, the SEC reinforces its role as a vigilant guardian of the public interest and ensures the stability and fairness of our financial system. In conclusion, I commend the SEC for its diligent review and thoughtful consideration of the OCC's proposal. Upholding the principles of transparency, risk mitigation, and investor protection is essential for fostering fair and efficient financial markets that serve the interests of all stakeholders. I wholeheartedly support the SEC's decision to reject the proposed rule change and urge continued vigilance in safeguarding the integrity of our financial system. Thank you for your attention to this matter. Sincerely, Karl Jones