May 11, 2024
I strongly reject this proposal as adjusting margin requirements during times of "volatility" is the anthesis of a healthy market. Margin requirements are safeguards and need to be enforced as it prevents excessive, market threatening risk and potential bailouts costing the American taxpayer tens of billions and more inflation. The most ridiculous part of this proposal is that the information that they are basing margin threshold calculations on is redacted? Are we supposed to just take their word for it? Also the fact that the OCC wants to give significant authority to the role of FRM (Financial Risk Management) makes me very uncomfortable. That position has a conflict of interest as they are required to safeguard both the OCC and at risk clearing members. They may be tempted to allow excessive risk for members to avoid the OCC having to make shareholders whole after a firm implodes. The proposal should be rejected as it does nothing to strengthen market protections and would actually erode them if implemented. Thank you Charles Ladd