May 12, 2024
I commend the SEC's effort to consider a rejection of this proposal. This proposal should definitely be rejected due to the following reasons: Exhibits 3 and 5 are significantly redacted. This prevents investors from making an informed decision about the validity of the proposal Instead of offering margin reductions to defaulting clearing members, the OCC needs to enhance its margin collection procedures to prevent defaults altogether OCC is encouraging systemic risks by offering to reduce margin requirements in times of stress. These are the exact times when OCC should be chomping at the bit to issue and enforce margin calls OCC is offering to waive margin calls instead of executing mandatory buy-ins. This is a moral hazard OCC is prioritizing the clearing members over itself. This goes against its fiduciary duty to ALL investors. ALL investors can be treated fairly only if defaulting members are either forced to put up margin or default OCC is encouraging clearing members to make riskier bets at the expense of all other investors in the market