Feb. 3, 2024
Good morning, I am writing today to voice my strong opposition to the newly proposed OCC-2024-001. I can’t believe this needs to be said. Instead of reducing margin requirements to prevent systemic/counterparty risk, how about the OCC participants just reduce their risk profiles to be in line with margin requirements? So simple and obvious. By reducing margin requirements and waiving them during times of volatility, this proposal seeks to legalize and encourage excessive risk taking among market participants. This doesn’t reduce systemic risk, but increases systemic risk by allowing the parties to take on even more risk. As an individual investor I am appalled that exhibits attached to this proposal have been redacted. How can the public possibly comment on proposed rules when supporting documents are withheld? In a free and fair market, when participants make bad bets, they lose money. This is the way that natural, free and fair markets punish reckless and bad behavior. To reduce/waive margin requirements in times of market volatility means that shares which have been bought and paid for will not be delivered in a timely manner. It means that large players who make bad bets will be incentivized to manipulate markets to push the NBBO to a price that their position needs the price to be at, and gives them the time to perform the manipulation to push the price there. I would hope the SEC is watching this closely and taking effective action to protect our capital markets integrity. Thank you, and have a great day. Andrew Sent from my iPhone