Subject: Comments on SR-OCC-2024-001 34-100009
From: S W
Affiliation:

May 17, 2024

Hello, 


I appreciate the opportunity to contribute to the rulemaking process to protect all investors in a fair, orderly, and efficient market. Today, I am writing to support the SEC's grounds for disapproval, as the rule effectuates a market with less risk mitigation, responsibility, and fairness overall. 



Large financial institutions are meant to be regulated so that their risk does not cause potential global failure to the markets in the event of an unforeseen event. Regardless, investment banks, such as Goldman Sachs, have taken out margin leverages as high as x100 times their collateral. If the OCC is so concerned about meeting its obligations, perhaps it should propose regulations related to risk mitigation and further oversight of the institutions that pose systematic risk. On the other hand, this rule allows flagrant and brazen risk-taking with investors' money while aiming to avoid the responsibility of "picking up the bill" when things go south. 


If anything, the OCC's margin requirements should be raised. The OCC might be incentivized to advocate for regulation of the root of the problem: reckless risk-taking by huge financial institutions. If the OCC is so concerned about default, it is logical to adjust clearinghouse resources, margins, member contributions, and insurance as required. 

Thank you for the opportunity to comment. 


Sincerely, 
A concerned household investor