May 17, 2024
I support the SEC's decision to reject the proposed rule change by the OCC on SR-OCC-2024-001 to reduce margin call requirements by adjusting margin thresholds during periods of high market volatility. Firstly, the mechanisms by which the margin reduction is carried out is unknown and hidden behind a great wall of redacted text. The best rules should be simple and clear, and apply equally to all. Secondly, the ability to shift goal posts gives an impression that rules don't matter, which casts a bad impression on the US capital markets. Thirdly, these leeways encourage OCC clearing members to take up risks beyond their financial means, which poses a systemic risk to financial markets. Bad behaviour should not be let off easily. The OCC is a Systemically important financial market utility. It is my hope that they will work towards ensuring compliance and good behaviour from their members to manage risks Regards, International Invester