Subject: SR-OCC-2024-001 34-100009
From: trey satterlee
Affiliation:

May 16, 2024

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). As a concerned investor and advocate for financial market integrity, I commend the SEC for upholding the principles of transparency, honesty, and investor protection in its regulatory oversight.
Transparency is the cornerstone of a fair and efficient financial market. It fosters trust among investors and ensures that market participants are adequately informed to make sound investment decisions. The OCC's proposed rule change lacked the necessary transparency, failing to provide clear and comprehensive information regarding its potential impacts and the rationale behind the proposed adjustments. Without transparency, investors are left in the dark, exposed to unnecessary risks and uncertainties.
Furthermore, the proposed adjustments to margin requirements raise serious concerns about potential systemic risks, particularly during periods of market volatility. Margin requirements play a crucial role in safeguarding market stability by mitigating excessive leverage and preventing systemic risk contagion. Any hasty or ill-considered changes to these requirements could destabilize the financial system, leading to widespread market disruptions and investor losses. The SEC's decision to prioritize market stability and investor protection by scrutinizing the potential systemic implications of the OCC's proposal is commendable and in the best interest of all market participants.
Additionally, the conflict of interest inherent in the role of the Financial Risk Management (FRM) Officer raises significant ethical and regulatory concerns. The dual responsibilities of overseeing risk management functions within a financial institution while simultaneously serving as a regulatory compliance officer create an inherent conflict of interest that compromises the integrity of risk management practices. This conflict undermines the independence and objectivity required to effectively identify and mitigate systemic risks, posing a threat to the stability and fairness of the financial market.
In conclusion, I firmly believe that the SEC's decision to reject the OCC's proposed rule change is a testament to its commitment to upholding the highest standards of transparency, honesty, and investor protection in financial regulation. By prioritizing the interests of investors and the stability of the financial system, the SEC has demonstrated its unwavering dedication to maintaining a fair and resilient market environment. I urge the SEC to continue its vigilant oversight and regulatory scrutiny to ensure the integrity and stability of the financial markets for the benefit of all stakeholders.
Thank you for your attention to this matter, and I trust that the SEC will continue to uphold its mandate to safeguard the interests of investors and maintain the integrity of the financial markets.
Sincerely, USA Citizen, investor.