Feb. 8, 2024
Chair Gensler and Commissioners, Greetings and salutations. I trust this message finds all who read it well. I appreciate the opportunity to comment on the proposed rule change SR-OCC-2024-001, concerning adjustments to parameters in calculating margin requirements during periods of high volatility. As a concerned retail investor, I want to express several key concerns and recommendations. As a concerned private citizen, I want to express an opinion on the state of affairs and a desire for a brighter future. Overview of Concerns: The proposed rule change, aiming to reduce margin requirements during high volatility, raises serious concerns about unintended consequences. The redacted materials accompanying the proposal hinder transparency, making it challenging for the public to meaningfully review and comment on its implications. Moreover, revising the calculus of STANS in order to assist failing members, who might I add are failing due to bad bets, risky instruments, and in some (most) cases outright fraud and crime, does nothing to lessen the recurrence of future events nor does it dissuade recidivism by these criminals. Evaluation of Risk Management Mechanism: Risk management mechanisms, especially margin calls, are crucial for maintaining market stability. The proposal's potential to undermine these mechanisms and shield risky positions during volatile conditions poses a significant risk to market integrity. Adjusting parameters should strike a balance between risk management and broader market interests. The image of a failing day trader comes to mind and when I think about whether a broker-dealer would hesitate to liquidate their portfolio to mitigate losses on broker’s part the answer is a stark no! No hesitation. If individual investors plow into penny stocks at the behest of clowns on TV and go short and blow their accounts that’s the end for them. There’s no bailout. No rewrite of the rules. Yet time and time again we see these entities get pass after pass after taxpayer funded pass. As if it wasn’t already bad enough OCC gets to burn through pensions/insurance before having to touch member funds, now they are attempting to codify not having to touch member collateral by lowering margin requirements? Come again for big fudge? This is unacceptable. I am sick and tired of paying for these crooks to continually get bailed out at my expense while they reap every single reward from the sweat of my brow. No more. Pay up. You made the bad bets, it’s time to pay up. You played the game, poorly might I add, and lost and now it’s time to pay up. No rewrites, no backdoor deals, no more collusion, no more offshoring massive naked short positions so FINRA doesn’t have to count it, no more kicking the can on SWAP disclosures (CFTC looking at you! Tsk, tsk Behnam. Have you no shame?), no more cellar boxing, no more convertible debt spirals, you’ve lost. FYPM. Specific Recommendations: I recommend reassessing the loss allocation framework to prioritize Clearing Fund deposits over the OCC's pre-funded resources. Additionally, establishing an independent review mechanism can ensure impartial evaluations of control settings, enhancing the credibility of risk management measures. Let the members lose their capital first. They made the bad bets, let them lose. Stop privatizing the gains and socializing the losses. I’m sick of paying for corporate greed. Additional Safeguards and Modifications: Enhanced transparency measures, such as providing non-confidential summaries of redacted materials, should be implemented. Strengthening oversight mechanisms and incorporating public input in decision-making processes will foster accountability and public trust. Emphasizing industry-wide standards and best practices is essential for promoting market stability. Stop redacting the bulk of a rule change. It’s a slap in the face. And it will be remembered by history how little SROs (hahahahahaha) actually did to save the system and not just the corrupt participants. Industry-Wide Standards and Best Practices: Collaboration with stakeholders to establish industry-wide standards and best practices is crucial. Public accessibility to stress testing results would demonstrate the effectiveness of risk management measures and contribute to a more informed and resilient financial environment. Mostly, stop abusing the system. Stop creating loopholes and then ramming loads of illgotten gains offshore. Pay up. It’s time. Conclusion: In conclusion, I believe these recommendations will contribute to fostering a financial environment that prioritizes fairness, transparency, and market stability. I trust that the SEC will thoroughly consider these concerns during the rulemaking process and I hope OCC is ready for what the books will say after all is said and done. Thank you for your attention to this matter. May you all have peace and may you spend time with those you love. Blessings to you and yours and please do and be well. Have a lovely day! Except for Hester and Mark. Y’all can have a just okay day, bless y’all’s hearts. Jesus still loves you. Even if I don’t. Peace! Respectfully Sent, A Concerned Retail Investor References: \[https://www.federalregister.gov/d/2024-01386/p-11](https://www.federalregister.gov/d/2024-01386/p-11) \[https://www.federalregister.gov/d/2024-01386/p-8](https://www.federalregister.gov/d/2024-01386/p-8) \[https://www.federalregister.gov/d/2024-01386/p-7](https://www.federalregister.gov/d/2024-01386/p-7) \[https://www.federalregister.gov/d/2024-01386/p-50](https://www.federalregister.gov/d/2024-01386/p-50) \[https://www.federalregister.gov/d/2024-01386/p-51](https://www.federalregister.gov/d/2024-01386/p-51) \[https://en.wikipedia.org/wiki/Long\_tail](https://en.wikipedia.org/wiki/Long_tail) \[https://www.federalregister.gov/d/2024-01386/p-45](https://www.federalregister.gov/d/2024-01386/p-45) \[https://www.federalregister.gov/d/2024-01386/p-79](https://www.federalregister.gov/d/2024-01386/p-79) \[https://www.theocc.com/getmedia/e8792e3c-8802-4f5d-bef2-ada408ed1d96/default-rules-and-procedures.pdf](https://www.theocc.com/getmedia/e8792e3c-8802-4f5d-bef2-ada408ed1d96/default-rules-and-procedures.pdf), which is publicly available and linked to from the OCC’s web page on Default Rules & Procedures at [https://www.theocc.com/risk-management/default-rules-and-procedures](https://www.theocc.com/risk-management/default-rules-and-procedures) \[https://www.federalregister.gov/documents/2021/04/12/2021-07454/self-regulatory-organizations-the-options-clearing-corporation-notice-of-no-objection-to-advance](https://www.federalregister.gov/documents/2021/04/12/2021-07454/self-regulatory-organizations-the-options-clearing-corporation-notice-of-no-objection-to-advance) \[https://www.federalregister.gov/d/2024-01386/p-16](https://www.federalregister.gov/d/2024-01386/p-16) \[https://www.bis.org/fsi/fsipapers11.pdf](https://www.bis.org/fsi/fsipapers11.pdf)