Feb. 5, 2024
Dear SEC, As I understand it, SR-OCC-2024-001 is a rule change the OCC is proposing to reduce margin requirements when there’s high volatility so that Clearing Members won’t default. The purpose of margin requirements are not to be used as flexible limits which allow members to play fast and loose with their investment decisions and avoid consequences when they make poor decisions. I liken this rule change proposal to a curfew for your teen child that they get to change the curfew any time they have a desire to not return home when they are supposed to. Passing this rule change would be equivalent to removing margin requirements altogether. If a member is under stress due to foolish decisions, this change allows them to escape the consequences of their poor decisions - this provides NO deterrent to acting irresponsibly. Clearing members acting responsibly should never need fear margin requirements. It is time for the SEC to decide what kind of "parent" they are going to be. Clearly certain members, much like certain teenaged children, NEED firm boundaries in order to develop a habit of responsible behavior. Additionally, these same members NEED to know those boundaries are real, and breaking them have real consequences. These boundaries serve a further purpose to the RESPONSIBLE Clearing Members as well. Clear and firm boundaries serve as a reminder to the members in good standing the importance of maintaining their habit of responsible behavior. It is my hope as a Household Investor that the SEC puts Wall Street on notice loudly and clearly: No more nonsense! Bad behavior has unpleasant consequences, and delinquent members will play by the rules and not change them as they go along. Only by sending a loud clear and consistent message will the problems of Wall Street be fixed. The time for Tough Love and a firm hand is long overdue. I truly hope you are up to the task. Thank You, D. Kraft -- OIIIIIIO