May 16, 2024
I am writing to express my full support for the Securities and Exchange Commission's (SEC) decision to reject the proposed rule change submitted by the Office of the Comptroller of the Currency (OCC). As an investor in our financial markets, I commend the SEC's commitment to upholding transparency, risk mitigation, and investor protection. Transparency serves as the bedrock of trust and confidence in our financial system. The lack of transparency in the OCC's proposal raises significant concerns about the potential for undisclosed risks and adverse consequences. Investors rely on clear and comprehensive information to make informed decisions, and any regulatory change must uphold this fundamental principle. Moreover, the proposed adjustments to margin requirements during market volatility pose systemic risks that cannot be ignored. Market stability depends on prudent risk management measures that safeguard against excessive leverage and speculative activities, especially during times of heightened volatility. The potential for destabilizing effects on the broader financial ecosystem necessitates a cautious approach to any regulatory changes impacting margin requirements. Furthermore, the role of the Financial Risk Management (FRM) Officer presents a clear conflict of interest that undermines the credibility and effectiveness of risk oversight. Independence and impartiality are essential attributes for individuals tasked with assessing and mitigating financial risks. The inherent conflict posed by the FRM Officer's dual responsibilities compromises the integrity of risk management practices and exposes the system to undue influence. In light of these concerns, the SEC's decision to reject the OCC's proposed rule change is a rational and necessary step to safeguard the interests of investors and preserve the integrity of our financial markets. By prioritizing transparency, risk mitigation, and investor protection, the SEC demonstrates its commitment to promoting fair and orderly markets that inspire confidence and foster long-term stability. Thank you for your diligent review and consideration of these critical issues. I stand in full support of the SEC's decision. Sincerely, An average investor.