May 10, 2024
I am writing today to express my opposition to the Proposed Rule Change outlined in SR-OCC-2024-001. The proposal raises significant concerns and poses a threat to the fairness and stability of our financial markets. Therefore, I support the SEC’s rejection of this proposal and support alternative solutions to waiving margin requirements for clearing members. Alternative solutions might include increasing and enforcing margin requirements to reflect the risks associated with Clearing Member positions; external auditing and supervision to assess and manage risks before they are problematic; or changing the order of loss allocation in the OCC's Loss Allocation waterfall to encourage Clearing Members to manage risk more appropriately. Of further concern is the lack of transparency that arises from the redaction of various parts of this proposal. Such opacity makes it impossible for the public to know the full ramifications of such a proposal and, as such, causes it to be impossible for the proposal to achieve public support. Thank you for your consideration and for the opportunity to comment. Sincerely, William Bloxham