May 13, 2024
Chairman/Chairwoman/Commissioner Securities and Exchange Commission 100 F Street NE Washington, DC 20549 Dear SEC, I am writing to express my wholehearted support for the Securities and Exchange Commission's (SEC) recent decision to reject the proposed rule change by the Office of the Comptroller of the Currency (OCC). The decision underscores the critical importance of transparency, risk mitigation, and investor protection in preserving the integrity of our financial markets. Transparency lies at the core of any well-functioning financial system. The lack of transparency in the OCC's proposal raised significant concerns about its potential impact on market dynamics and investor confidence. By rejecting the proposal, the SEC upholds the principle that market participants deserve clear and comprehensive information to make informed decisions. Moreover, the proposed rule change posed inherent risks to market stability, particularly during times of volatility. Adjustments to margin requirements without adequate safeguards could exacerbate systemic risks and contribute to market disruptions. The SEC's decision reflects a commitment to prudently manage risk and maintain market stability, thereby safeguarding the interests of investors and the broader economy. Furthermore, the conflict of interest inherent in the role of the Financial Risk Management (FRM) Officer was a cause for alarm. The dual responsibilities of overseeing risk management functions while also serving the interests of the institution raised questions about the impartiality and effectiveness of risk oversight. By rejecting the proposed rule change, the SEC demonstrates its unwavering dedication to ensuring that regulatory frameworks prioritize the interests of investors and the public good over institutional interests. In light of these considerations, I commend the SEC for its diligent review and prudent decision-making process. By upholding rigorous standards of transparency, risk mitigation, and investor protection, the SEC plays a pivotal role in fostering trust and confidence in our financial markets. I stand in full support of the SEC's decision and urge continued vigilance in safeguarding the integrity and fairness of our financial system. Thank you for your unwavering commitment to regulatory excellence and public interest. Sincerely, Ted