May 17, 2024
Dear SEC, I agree with the rejection of SR-OCC-2024-001 - and support the reasons for the dismissal as outlined on pages 4-5 of the Federal Register. I appreciate the opportunity to provide input on this matter. However, I cannot support the approval of this proposal due to several reasons: Lack of Transparency: The proposal contains significant redactions, preventing meaningful public review and comment. Systemic Risk: The OCC's proposal to reduce margin requirements for Clearing Members poses increased risk to the stability of our financial system. If clearing members cannot meet their financial obligations - they must close their bets. Conflict of Interest: The role of the Financial Risk Management Officer has an inherent conflict of interest to oversee both the well-being of Clearing Members as well as the agency itself. Moral Hazard: The proposal shifts the costs of Clearing Member defaults to the non-bank liquidity facility, creating a moral hazard and perpetuating an unfair marketplace. Inadequate Risk Management: The proposal fails to properly manage liquidity risk and increases systemic risk, as evidenced by the OCC's reliance on reducing margin requirements. With note and appreciation to the rejection reasons as put forward by the SEC in the dismissal of this rule: Failure to promote prompt and accurate clearance and settlement of securities transactions and safeguard securities and funds. Lack of clear and direct lines of responsibility in governance arrangements. Inadequate policies and procedures to cover credit exposures to participants and insufficient margin calculation to cover potential future exposure. In conclusion, I support the SEC in their rejection of this proposed rule change - to ensure the protection of all investors and the integrity of our financial markets. Thank you for considering my concerns and for your continued help to protect our markets, Sincerely, Household investor. Angelo Loto Disclaimer The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. This email has been scanned for viruses and malware, and may have been automatically archived by Mimecast, a leader in email security and cyber resilience. Mimecast integrates email defenses with brand protection, security awareness training, web security, compliance and other essential capabilities. Mimecast helps protect large and small organizations from malicious activity, human error and technology failure; and to lead the movement toward building a more resilient world. To find out more, visit our website.