Comments on SR-OCC-2023-007 Dear Securities and Exchange Commission (SEC), Thank you for the opportunity to provide feedback on the proposed rule changes. It is a privilege to engage in a dialogue that shapes the future of our financial markets, ensuring they remain robust, transparent, and fair for all participants. The introduction of new regulatory measures is a testament to the SEC's commitment to maintaining market integrity and protecting investors. However, the proposal at hand raises significant concerns that necessitate a thorough review to avoid unintended consequences, particularly in safeguarding against risky financial positions during volatile market conditions. The potential for these changes to inadvertently obscure the risks taken by market participants underscores the need for a careful balance between innovation and stability. One of the most pressing issues is the conflict of interest inherent in the role of Financial Risk Management (FRM) Officers. Their pivotal decisions could be influenced by the interests of their institutions, potentially at the expense of the wider market. This concern is compounded by the lack of transparency resulting from redacted materials accompanying the proposal, hindering a comprehensive understanding of its implications. Risk management mechanisms, such as margin calls, are vital in maintaining market stability. They ensure that entities engaged in financial transactions hold sufficient reserves to cover potential losses, thereby protecting the market from systemic risks. The proposal's potential to undermine these mechanisms by allowing unchecked risk exposure is alarming. It emphasizes the importance of adjusting risk management parameters to balance safeguarding market stability with accommodating the interests of various market participants. To address these issues, we recommend a reassessment of the loss allocation framework to prioritize Clearing Fund deposits over the OCC's pre-funded resources. This approach would enhance market resilience against unexpected volatilities and ensure a fair distribution of risk. Furthermore, implementing an independent review mechanism would guarantee an impartial evaluation of control settings, reinforcing the integrity of our financial systems. Enhanced transparency measures are crucial for fostering trust and accountability within the financial markets. Providing non-confidential summaries of the redacted materials would greatly contribute to this end. Additionally, strengthening oversight mechanisms and incorporating public input into the decision-making process would ensure that proposed changes reflect the collective interest of the financial community. The establishment of industry-wide standards and best practices, developed in collaboration with stakeholders, is essential for a stable and efficient market. Public accessibility to stress testing results would demonstrate the effectiveness of risk management measures, further promoting transparency and trust. In conclusion, while we appreciate the intentions behind the proposed rule changes, it is imperative that we proceed with caution, ensuring that our efforts to enhance the financial market's infrastructure do not inadvertently introduce new risks. We are confident in the SEC's ability to thoroughly consider these concerns and are committed to supporting a regulatory environment that prioritizes fairness, transparency, and the collective well-being of the financial markets. Thank you for considering our perspective on this matter. We look forward to contributing to a dialogue that ensures the continued strength and integrity of our financial system. Sincerely, Greg Englebert