May 11, 2024
Dear Gary Gensler & Securities and Exchange Commission, I am writing to express my full support for the recent decision by the Securities and Exchange Commission (SEC) to reject the proposed rule change submitted by the Office of the Comptroller of the Currency (OCC). This decision reflects a commitment to transparency, risk mitigation, and investor protection, all essential elements for maintaining a fair and robust financial market. Transparency is a cornerstone of market integrity and investor confidence. The lack of transparency in the OCC's proposed rule change raises significant concerns regarding its potential impact on market participants and overall market stability. Without clear and comprehensive disclosure of the proposed changes, investors are left without the necessary information to make informed decisions, thereby undermining the fundamental principles of fair market participation. Moreover, the proposed adjustments to margin requirements during times of market volatility pose inherent systemic risks. Market volatility can amplify the impact of margin calls, leading to cascading effects throughout the financial system. By rejecting the OCC's proposal, the SEC has demonstrated a prudent approach to risk management, prioritizing the stability of the financial markets and safeguarding against potential systemic disruptions. In conclusion, I commend the SEC for its diligence in evaluating the OCC's proposed rule change and for prioritizing the principles of transparency, risk mitigation, and investor protection. Upholding these principles is essential for fostering trust and confidence in our financial markets and ensuring their long-term stability and resilience. Thank you for considering my perspective on this matter. I trust that the SEC's decision will contribute to the continued integrity and fairness of our financial markets. Sincerely, Brent Feurer