Subject: File No. SR-OCC-2024-001
From: Cornelius Martin

After thoroughly examining the specifics of rule SR-OCC-2024-001, it's apparent that the regulation, aiming to manage systemic risk in periods of high market volatility, could inadvertently prioritize the stability of Clearing Members over ensuring transparency and fairness in the broader market. By utilizing "idiosyncratic" and "global" control settings for adjusting margin requirements, the rule introduces a discretionary element favoring larger, sophisticated market participants, potentially encouraging riskier trading strategies with an assumed safety net provided by the OCC in times of market turbulence. Such discretionary adjustments to margin requirements raise significant concerns about equity in the market. Retail investors and smaller entities, lacking similar resources to navigate these adjustments, are placed at a disadvantage, undermining the principle of market discipline where entities should bear the consequences of their risk management decisions. The rule's strategy to mitigate financial crises through margin adjustments seems to conflict with ensuring all market participants are equally accountable and transparent in managing risks. Incorporating the idea of raising margin requirements could mitigate these concerns by compelling Clearing Members to maintain higher levels of capital against their positions, reducing the risk of defaults that could trigger systemic issues. This approach promotes prudent risk management, encouraging more conservative trading strategies and better risk assessment. Higher margin requirements act as a buffer against volatility, providing a substantial safety net and reducing the market's susceptibility to cascading defaults. Moreover, higher margin requirements could level the playing field, diminishing the leverage larger entities have by absorbing market shocks, ensuring all market participants meet the same risk management standards. This democratization fosters a competitive and fair market environment, enhancing market transparency and confidence. Investors knowing that Clearing Members hold more capital can trust the financial system's resilience, encouraging participation and investment, which is crucial for economic growth and stability. In sum, integrating higher margin requirements into SR-OCC-2024-001 would not only address systemic risks but also promote a more equitable, transparent, and robust financial market. This approach safeguards against future crises, ensuring all market participants are adequately prepared to withstand financial storms, thereby protecting the broader economy​​​​. Lastly, being seen as a means to profit rather than a partner for a stronger economy and country is akin to being fiscal chattel. It sucks.