Feb. 17, 2024
To whom it may concern, As a household investor in the financial markets and a supporter of transparent, fair, and stable market practices, I am writing to express my firm opposition to the proposed rule SR-OCC-2024-001. While acknowledging the purpose of the rule to codify OCC’s process for making adjustments during high volatility periods, the lack of transparency, especially the redaction of specific details related to the calculation of parameters and margin thresholds, raises serious concerns. Transparency is essential for market participants to assess the fairness and effectiveness of risk management measures as well as a tool to prevent future financial crises caused by specific participants in the current market. The consistent use of idiosyncratic control settings, the concentration of significant decision-making authority in the hands of a single FRM Officer, and the potential systemic risks associated with frequent adjustments during high volatility are very alarming. The proposed rule, as it stands, poses a threat to reducing margin call requirements by granting the OCC extensive authority to adjust margin thresholds based on an undisclosed parameters during critical events. Furthermore, the lack of solicited comments for public input raises questions about the transparency and fairness of the rule-making process. In a regulatory environment, active engagement with stakeholders is crucial to ensure well-rounded rules that can address concerns for all parties involved.. I urge you to reconsider and revise the proposed rule SR-OCC-2024-001. My suggested improvements would include but are not limited to: Heavily strengthening and enforcing margin requirements, introducing external auditing and supervision, incorporating public input, and enhancing transparency requirements. These measures are essential to fostering trust among market participants and maintaining the stability and integrity of our financial markets. In closing, due to the above aforementioned reasons, I strongly oppose the adoption of the proposed rule SR-OCC-2024-001 in its current form and encourage a thorough reconsideration of its implications. Sincerely, Dickens Leung (209)889-2007 adickensleung@gmail.com