May 10, 2024
I am writing to express my full support for the recent decision made by the Securities and Exchange Commission (SEC) to reject the proposed rule change submitted by the Office of the Comptroller of the Currency (OCC). As an active participant in the financial market, I deeply appreciate the SEC's commitment to upholding transparency, risk mitigation, and investor protection, which are vital for maintaining the integrity and fairness of our financial system. As a household investor with over 20 years of experience in the financial markets, I have witnessed firsthand the importance of transparency, stability, and fairness in maintaining investor confidence. However, I am disheartened by the current state of the markets, which is marked by a lack of transparency and increasing volatility. The proposed rule change by the OCC only exacerbates these concerns, further eroding investor trust and jeopardizing the integrity of our financial system. Therefore, I wholeheartedly support the SEC's decision to reject the proposed rule change and urge continued efforts to restore transparency, mitigate risks, and protect the interests of investors. Transparency is the cornerstone of a healthy financial market. The lack of transparency in the OCC's proposed rule change raises significant concerns regarding its potential impact on market participants and systemic stability. Without clear and comprehensive disclosure of the proposed changes, investors are left in the dark, unable to assess the risks associated with margin requirement adjustments during market volatility. Moreover, the proposed rule change fails to adequately address the potential systemic risks stemming from margin requirement adjustments during periods of market turbulence. Such adjustments have the potential to exacerbate market volatility and amplify systemic risks, posing significant threats to the stability of our financial system. By rejecting the proposed rule change, the SEC has demonstrated its commitment to mitigating systemic risks and safeguarding the interests of investors. Furthermore, the conflict of interest inherent in the role of the Financial Risk Management (FRM) Officer, as highlighted in the SEC's grounds for disapproval, raises serious questions about the integrity and independence of risk management practices within financial institutions. Allowing the FRM Officer to simultaneously serve as a member of the board of directors creates a potential conflict of interest that undermines the effectiveness of risk management oversight. By rejecting the proposed rule change, the SEC has taken a crucial step towards preserving the independence and effectiveness of risk management functions within financial institutions. In conclusion, I commend the SEC for its diligent review and decision to reject the OCC's proposed rule change. By prioritizing transparency, risk mitigation, and investor protection, the SEC has reaffirmed its commitment to maintaining a fair and orderly financial market. I urge the SEC to continue its efforts to uphold these fundamental principles and to remain vigilant in safeguarding the interests of investors and the stability of our financial system. Thank you for your attention to this matter. Sincerely, Kristofer Alt