Subject: SR-OCC-2024-001 34-100009
From: Nou Moua
Affiliation:

May 7, 2024

This proposed rule change by the Choices Clearing Organization (OCC) 
is an absolutely horrifying attack against fair and methodical 
business sectors that should be passionately dismissed. It is 
equivalent to institutionalizing fraud and moral hazard on a systemic 
scale by allowing the OCC to unilaterally reduce margin requirements 
for clearing members who are at risk of default. The absence of 
straightforwardness alone, with huge areas of basic data redacted, is 
as of now adequate justification for excusing this proposition 
altogether. There can be neither a meaningful review nor 
accountability without full public disclosure. This obscure conspiring 
in secret definitively fills public doubt in the manipulated monetary 
situation. Yet, the considerable subtleties that have been uncovered 
are significantly seriously cursing. The OCC is glaringly faulting 
controllers for not permitting it to disintegrate its own gamble 
controls enough, incredibly arguing for consent to uncover itself and 
the whole framework to expanded disappointments. This is the counter 
proposition of a self-administrative association intended to protect 
market respectability. The proposed capacity to randomly defer edge 
calls for undercapitalized clearing individuals is a shameless 
endeavor to privatize benefits while mingling misfortunes. 
Unyieldingly dismissing risk models that work out higher necessities 
is monetary negligence. Clearing individuals putting down careless 
wagers that jeopardize their dissolvability ought to be power to 
acknowledge the outcomes, not have risk helpfully stretchered away 
more than 200 times in less than 4 years as the OCC proposes. In 
essence, this rule enshrined a ridiculous "rules for thee, but not for 
me" philosophy that was in complete opposition to the SEC's mission. 
Safeguarding cleaning individuals off of edge calls powers different 
financial backers to unreasonably endure the worst part of long-tail 
gambles the favored can essentially wish away with some private cabin 
procedural distortions. Much more detestable is the express 
confirmation that a solitary clearing part default could start a 
fundamental outpouring risking the whole OCC. This highlights that 
these organizations are perilously overleveraged and undercapitalized. 
As opposed to address that center weakness, the OCC rather proposes 
offer itself considerably more space to twist risk boundaries for its 
brokenness individuals. The "too big to fail" doctrine, which 
destroyed public trust after 2008, is toxically maintained in this 
manner. The reasoning that diminishing edges could forestall a default 
disregards that appropriately overseeing openness is a clearing part's 
only liability. Arranging moral peril so deplorably clashes with the 
OCC's very order as aSystemicallyImportant Monetary Market Utility 
expected to maintain security. This proposition straightforwardly 
sabotages monetary strength by plan. Correspondingly pretentious is 
the new "dog in the fight" capital commitment the OCC foisted on 
itself following the GameStop furor demonstrated its models were 
deficient. Presently this substance purposely pursuing bankruptcy risk 
requests much looser protections, in a pessimistic ploy to drive 
liquidity stopping boards from benefits and guarantors. In a desperate 
attempt to privatize profits while socializing losses, this erroneous 
rulemaking ventures into criminal territory and threatens millions of 
dollars' worth of savings. There are no sensible reason for the SEC to 
support such a shameless permit to intensify foundational danger. It 
destroys all prudential obligations requested of a SIFMU, neglects to 
safeguard financial backers, dismisses public interests, disregards 
straightforward administration, and ridicules misfortune bearing 
prerequisites. This proposition represents everything spoiled and 
broken about current money's dependence on moral danger and mingled 
risk-taking. Regulators need to make it clear that they will not allow 
this shameful neglect: Order higher edge prerequisites really similar 
to the dangers clearing individuals bring about. Subject the OCC to 
restricting outside reviews and oversight as a genuine fourth line of 
safeguard. Shift the OCC's misfortune bearing liabilities beneath 
clearing individuals' dog in the fight. Instate a sound cycle for 
quickly covering wiped out clearing individuals before harmfulness 
spreads. A decentralized market structure without single points of 
failure can disperse systemic vulnerability. In a moral framework, 
unsafe wagers should be upheld by proportionate capital - not pampered 
by private cabin waivers that wool people in general. This proposition 
is a criminal relinquishment of administrative obligation that merits 
just unequivocal renouncement. The SEC should maintain its standards 
by dismissing it by and large and diagramming a course toward really 
responsible business sectors.