May 16, 2024
As a retail investor, I support the SEC's grounds for disapproval of SR-OCC-2024-001. The proposal lacks transparency due to significant redactions, preventing meaningful public review. It unfairly shifts risks from Clearing Members to the OCC, increasing systemic risk. The proposal reduces margin requirements during high volatility, which could lead to Clearing Member defaults, posing financial risks to the OCC and the broader financial system. The OCC’s repeated margin reductions favor Clearing Members and undermine market stability. For these reasons, the SEC should reject this rule proposal to ensure a fair, transparent, and resilient market for all investors. Thank you for the opportunity to comment. By and with the best regards Jesse