Mar. 5, 2024
Sirs and Madams of the SEC, I am writing to express my concern regarding SR-OCC-2024-001. The suggested rule widens the information gap between institutional and household investors. It seems to me this rule can be enforced at the whim of one individual or group of individuals that would constitute a risk of conflicts of interest in relation to risk management and market fairness. Household participants cannot invoke “temporary exceptions” to financial liability because it would suit them. Just as the proposed calculations on VAR are hidden from the general public, this suggested rule further obfuscates the liability of OCC members while also allowing a synthetic allocation of liquidity in times when market assets are volatile - which is perpetually risky and/or unfair should liabilities be protected against liquidity allocation during certain market conditions. I implore you to deny the implementation of SR-OCC-2024-001. Respectfully, Johan Roosberg