May 17, 2024
Dear Chairman Gensler, I am writing to express my wholehearted support for the U.S. Securities and Exchange Commission's recent decision to reject the proposed rule change submitted by the Office of the Comptroller of the Currency (OCC). As a stakeholder deeply committed to the integrity and stability of the financial markets, I commend the SEC for upholding the principles of transparency, risk mitigation, and investor protection, which are essential pillars of a fair and equitable financial ecosystem. One of the primary concerns surrounding the OCC's proposed rule change is the lack of transparency inherent in its framework. Transparency is not merely a buzzword but a fundamental prerequisite for fostering trust and confidence among market participants. By failing to provide sufficient clarity and disclosure regarding the proposed adjustments to margin requirements, the OCC's proposal could potentially expose investors to unnecessary risks and undermine market integrity. Moreover, the proposed rule change raises significant concerns regarding systemic risks, particularly during periods of market volatility. Margin requirements play a crucial role in safeguarding against excessive leverage and preventing the amplification of market downturns. Any abrupt adjustments to these requirements, especially without adequate safeguards and risk assessments, could exacerbate market instability and pose systemic threats to the financial system as a whole. Furthermore, the potential conflict of interest inherent in the role of the Financial Risk Management (FRM) Officer raises legitimate apprehensions about the impartiality and integrity of the regulatory process. As stewards of the financial system, regulatory bodies must uphold the highest standards of governance and accountability to ensure fair and equitable treatment for all market participants. Allowing individuals with potential conflicts of interest to oversee critical regulatory decisions undermines public trust and compromises the integrity of the regulatory framework. In light of these concerns, I believe that the SEC's decision to reject the OCC's proposed rule change is not only justified but imperative for safeguarding the integrity and stability of the financial markets. By prioritizing transparency, risk mitigation, and investor protection, the SEC demonstrates its unwavering commitment to upholding the core principles that underpin a fair and efficient market environment. In conclusion, I commend the SEC for its diligence and prudence in reviewing the OCC's proposed rule change and for prioritizing the interests of investors and market integrity above all else. As we continue to navigate the complexities of the financial landscape, I remain confident that the SEC's steadfast commitment to regulatory excellence will serve as a beacon of stability and trust for market participants around the world. Thank you for your unwavering dedication to safeguarding the integrity of our financial markets. Sincerely, Munib Mian