May 15, 2024
Dear SEC, I am writing to express my wholehearted support for the recent decision by the U.S. Securities and Exchange Commission (SEC) to reject the proposed rule change by the Office of the Comptroller of the Currency (OCC). This decision underscores the paramount importance of transparency, risk mitigation, and investor protection in maintaining a fair and robust financial market. Transparency serves as the bedrock of investor confidence and market integrity. The lack of transparency in the OCC's proposed rule change raises significant concerns regarding its potential impact on market dynamics. Investors and market participants rely on clear and accessible information to make informed decisions. By failing to provide adequate transparency in its proposal, the OCC risks undermining market trust and exacerbating uncertainty, which could have far-reaching consequences for market stability. Moreover, the proposed rule change by the OCC poses potential systemic risks, particularly during periods of market volatility. Margin requirement adjustments play a critical role in managing risk and ensuring the stability of the financial system. However, implementing changes to margin requirements without sufficient scrutiny and transparency could lead to unintended consequences, including increased market fragility and heightened systemic risks. The SEC's decision to prioritize risk mitigation and stability aligns with the broader goal of safeguarding the financial system against destabilizing factors. Additionally, the conflict of interest inherent in the role of the Financial Risk Management (FRM) Officer raises significant ethical and regulatory concerns. The OCC's proposal fails to adequately address these conflicts, potentially exposing investors to undue risks and impairing market fairness. By rejecting the proposed rule change, the SEC upholds its commitment to ensuring that regulatory frameworks prioritize the interests of investors and the integrity of the market above all else. In conclusion, I commend the SEC for its diligent review and decisive action in rejecting the OCC's proposed rule change. Upholding principles of transparency, risk mitigation, and investor protection is essential for maintaining a fair and efficient financial market. By rejecting proposals that fall short of these standards, the SEC demonstrates its unwavering dedication to preserving market integrity and safeguarding the interests of investors. Thank you for your attention to this matter. I remain confident in the SEC's continued commitment to fostering a financial environment that prioritizes fairness, transparency, and stability. Sincerely, Owen Yuen