May 14, 2024
Dear SEC, I am writing to express my strong support for the SEC's decision to reject the OCC's proposed rule change. This decision reflects a commitment to maintaining transparency, risk mitigation, and investor protection in our financial markets. The lack of transparency in the OCC's proposal is particularly concerning. Significant changes to margin requirements must be communicated clearly to market participants to ensure informed decision-making and market stability. Without this transparency, the proposal risks increasing uncertainty and volatility. Furthermore, adjusting margin requirements during market volatility could introduce systemic risks. These adjustments might not accurately reflect the underlying risks, potentially exacerbating market instability during stress periods. Additionally, the proposed role of the Financial Risk Management (FRM) Officer presents a conflict of interest. This dual role could compromise the objectivity needed for effective risk management, undermining investor trust and market integrity. In summary, the SEC's rejection of the OCC's proposal upholds the principles essential for a fair and stable market. I commend the SEC for its dedication to these principles and urge continued vigilance in protecting our financial system. Thank you for your attention to this matter!!! Sincerely, Jacob Nimocks