May 17, 2024
I appreciate the opportunity to provide input on SR-OCC-2024-001, concerning adjustments to margin requirements during high volatility. I oppose the proposed rule change, due to lack of transparency and potential systemic risks. I argue that the proposal favors Clearing Members over other market participants, creating an unfair marketplace. The ability to waive margin requirements with impunity favors only a select few individuals, which increases risks to the financial system. Additionally, I criticize the proposed rule for not safeguarding securities and funds, prioritizing Clearing Members' safety over the clearing agency, and shifting costs of defaults to non-bank liquidity facilities. I suggest alternative measures to mitigate risks, such as increasing margin requirements and enhancing external auditing and supervision. I urge the SEC to reject the proposal and address systemic issues in the financial system. -Nate Gulizia