Feb. 3, 2024
Hello dear reader, The OCC is proposing a rule change (SR-OCC-2024-001). In brief summary, this rule change will decrease margin requirements during periods of high market volatility to prevent clearing members from defaulting. My understanding is that this is in the name of stability, however, to assume that this would have any positive effect on our markets as a whole is an egregious oversight. Decreasing margin requirements will absolutely not deter risky behavior from firms and clearing houses. There is no incentive for them to take increased care. This removes the one risk that these entities have. The SEC cannot afford to further debilitate themselves. If you truly care about the security of our financial system, if you truly care about positive change, if you truly care about the millions of Americans who are punished by these rule changes, you will not pass this proposal. In the event of increased market volatility, margin requirements must go UP. To increase the stability and security of our financial system, margin requirements must go UP. It is utterly ridiculous to assume that LESS cash on hand, would INCREASE stability. Perhaps this is an opportunity for you to finally take charge, and prove you have the ability to accomplish the task at hand. We're all waiting on you. Mitchell.