Subject: public comment on rule SR-OCC-2024-001 34-100009
From: David Caughell
Affiliation:

May 16, 2024

This is poorly organized. Sorry about that. I'm from Canada and I only have US investments, because I believe in American business. I am writing to you to ask you to dismiss the above rule entirely, or reject it. 



It's impossible to comment on a rule when everything is redacted, but I'm going to try anyways. In principle, I would support rejecting the rule entirely, dismissing it if that's the right term, based on the redactions alone. 



Please remember that the world is watching here, and that there are alternatives to the US market for investment. The integrity of the US markets depends upon your actions here. In Canada there is preferential treatment towards dividends from Canadian companies, as well as some legitimate concern over the future of the strength of the US dollar. Despite this, I feel as though my best opportunities for capital appreciation lie in American equities markets. 



The main thing that I want to ensure is that (2) below is followed, that there is always enough cash to cover the liquidation of a position/member when it becomes necessary to do so. If this isn't the absolute rock bottom for margin then the market isn't safe. 



As a side note here. I believe that there are people right now engaged in market manipulation that will later be found to be fraudulent, and it boils my blood to watch those people flying around the world, attending sporting events, and putting their money into Florida real estate. When the time comes for them to pay for their crimes, my hope is that their lifestyle while they were enjoying the proceeds of said crimes is taken into consideration when determining their punishment. 


Thank you for the work that you're doing. I think the proper running of equity markets is an important aspect of civilization in general and it's important for our species, because it determines so much of our behavior at a macro level. It's possible that critical medicines have been affected by some of the decisions of the people in support of this rule. The decision you make on this issue may very well end up impacting younger generations for a long time. 



Rule 17Ad-22(e)(6) of the Exchange Act, which requires that a covered clearing agency establish, implement, maintain, and enforce written policies and procedures reasonably designed to cover, if the covered clearing agency provides central counterparty services, its credit exposures to its participants by establishing a risk-based margin system that, among other things, (1) considers, and produces margin levels commensurate with, the risks and particular attributes of each relevant product, portfolio, and market, and (2) calculates sufficient margin to cover its potential future exposure to participants in the interval between the last margin collection and the close out of positions following a participant default. [Refer to 17 CFR § 240.17Ad-22(e)(6)]