May 8, 2024
SEC - I am writing in support of your decision to disapprove this rule. As a self regulating body, the OCC is responsible for having clear and concise rulesets for their regulation. This rule would allow for loose and vague behaviors that lend themselves to supporting corruption depending on the nature of those choosing to execute the responsibilities of the OCC. The points outlined in the disapproval statement are absolutely pertinent, especially in the language as follows: - "...the rules of a clearing agency are designed to promote the prompt and accurate clearance and settlement of securities transactions and derivative agreements, contracts, and transactions..." - "...the Exchange Act ... requires that a covered clearing agency provide for governance arrangements that, among other things, specify clear and direct lines of responsibility..." You've nailed the problem on the head and it's codified in law as you've quoted. If the nature of our markets requires this rule, then these laws need to first be changed to reflect a need to have a vague and ill enforced regulatory regime rather than our current goal of transparent and reliable market mechanics. I applaud the sobriety of your interpretation on this rule suggestion and, again, support your decision to disapprove this rule. Many Thanks, - Noah