Jan. 29, 2024
To whom this may concern, Introduction: The proposed rule change will only help financial institutions not properly operating to safeguard their financial standing, to keep operating as before. It will a shield risky positions during volatile market conditions, which taxpayers should not subsidy. There is a significant conflict of interest inherent in the role of the Financial Risk Management (FRM) Officer. There is a very apparent lack of transparency due to redacted materials accompanying the proposal. Evaluation of Risk Management Mechanism: Margin calls maintain market stability. The proposal has the potential to undermine these mechanisms, leading to unchecked risk exposure. We need to adjust parameters in a way that balances risk management with broader market interests. Specific Recommendations: Recommend a reassessment of the loss allocation framework to prioritise Clearing Fund deposits over the OCC's pre-funded resources. Propose the implementation of an independent review mechanism to ensure impartial evaluation of control settings. Additional Safeguards and Modifications: Advocate for enhanced transparency measures, such as providing non-confidential summaries of redacted materials. Suggest strengthening oversight mechanisms and incorporating public input in decision-making processes. Emphasize the importance of industry-wide standards and best practices to promote market stability. Industry-Wide Standards and Best Practices: Stress the importance of collaboration with stakeholders to establish industry-wide standards and best practices. Highlight the value of public accessibility to stress testing results to demonstrate the effectiveness of risk management measures. Conclusion: There is a commitment to fostering a financial environment that prioritizes fairness and transparency. Express confidence in the SEC's ability to thoroughly consider the concerns raised during the rulemaking process. Please take the above into account when considering the OCC referenced in the subject line. Thank you, Dan Carp [REDACTED]