May 17, 2024
I am writing to express my strong support for the Securities and Exchange Commission's (SEC) decision to reject the proposed rule change submitted by the OCC. This decision underscores the critical importance of transparency, risk mitigation, and investor protection in maintaining the integrity of our financial markets. The concerns raised regarding the lack of transparency in the OCC's proposal are deeply troubling. Transparency is the bedrock of a fair and efficient financial system, enabling market participants to make informed decisions. The absence of sufficient disclosure regarding the potential impact on market participants and systemic risks posed by the proposed adjustments to margin requirements is alarming. Without transparent information, we the investors are left vulnerable to unforeseen risks and market disruptions. Furthermore, the potential systemic risks posed by margin requirement adjustments during market volatility cannot be overstated. Margin requirements are pivotal in managing risk and ensuring the stability of financial institutions. Any modifications to these requirements must undergo rigorous evaluation to mitigate the potential for systemic risk contagion and to safeguard the broader financial system. Moreover, the conflict of interest inherent in the role of the Financial Risk Management (FRM) Officer raises significant concerns. The OCC's proposal inadequately addresses this conflict, which could compromise the independence and objectivity of risk management practices within financial institutions. Effective risk management necessitates impartial oversight and decision-making to mitigate conflicts that may undermine the integrity of the process. The SEC's decision to reject the OCC's proposed rule change is a testament to its commitment to preserving transparency, mitigating risks, and safeguarding investor interests. By prioritizing these principles, the SEC upholds the integrity of our financial markets and ensures a level playing field for all participants. I wholeheartedly support the SEC's decision to reject the OCC's proposed rule change and commend their unwavering dedication to maintaining a fair, transparent, and resilient financial market. Thank you for your attention to this matter. Warm regards, A Concerned Household Investor