May 15, 2024
To Whom it May Concern, I am writing in support of the SEC's grounds for disapproval of the proposed rule change in question (SR-OCC-2024-001). Larger firms' indulgence in leveraged trading has proven disastrous numerous times in recent history, with deleterious effects on systemic market stability and overall effectiveness of capital markets. It is neither sensible nor legally well-founded to change margin requirements as indicated in the proposal. Indeed, the possibility of volatile conditions in the markets are one of the primary reasons for margin requirements, and appropriate risk-management must take them into account with some foresight. Moreover, the indicated proposal suffers from a conflict of interest in the role of the FRM Officer, which is clearly functionally untenable, and contrary to existing policy: The role of the FRM is to protect the OCC from the member's financial risk, yet in contradiction to this the proposal would compel the FRM to reduce margin requirements in favor of the Clearing Member's solvency. In effect, this puts the solvency of the Clearing Member in a more primary position to that of the OCC, which is exactly backwards to the intent of the FRM position. This codifies the idea of "too big to fail" in a very dangerous and legally contradictory manner. This level of legal permissiveness of moral hazard is unnecessary, dangerous, and cannot be adopted under current rules and procedures. Many further reasons to reject the proposal exist, including glaring issues of transparency, investor protection, and fairness of capital markets. But to list them all would result in this comment being prohibitively long. In light of the proposed rule's lack of necessity, disturbing implications, and incompatibility with primary rules and procedures, I simply urge disapproval of the proposed change by all concerned parties, and state my support of the SEC in their correct decision to disapprove it. Thank you for the opportunity to comment on this matter, and for the commission's correct choice to reject the proposal, in favor of the protection of our capital markets and those who invest in them. With grave sincerity, Bryce C. One Concerned Citizen and Investor