May 18, 2024
I do not support this proposal. The main issues in this proposal are: If a clearing house fails to accomplish their task of meeting their financial obligations, reducing margin requirements will not solve the issue. This would only delay their collapse and allow that financial burden to fall to another entity. Not only ignoring the issue but risking the chances of it happening again in the future. The role of the Financial Risk Management Officer should not also include regulation of the Clearing Members and the agency as well. This presents an ethical risk of hiding actions taken by all involved parties involved while also not sharing this information with the public. As a comparison: If a restaurant were to fail a health inspection and ask for the inspector to fundamentally change what it means to fail, this would immediately raise concern about that establishment. This restaurant deserves to be shut down due to poor planning and management. Thank you, Citizen