May 18, 2024
Travis Beck Household Investor Securities Exchange Comission, I am writing to express my full support for the decision to reject the proposed rule change by the Office of the Comptroller of the Currency (OCC), as outlined in File No. SR-OCC-202X-XX. This decision reflects a commitment to transparency, risk mitigation, and investor protection, which are vital for maintaining the integrity and fairness of our financial markets. Recent events, such as the GameStop short squeeze in early 2021 and the Archegos Capital Management debacle, have highlighted the critical importance of robust risk management and regulatory oversight in our financial markets. The Archegos failure, in particular, exposed significant vulnerabilities in the financial system, including the risks associated with excessive leverage and concentrated positions. In the aftermath of these events, it is imperative that regulatory authorities remain vigilant in identifying and addressing systemic risks to ensure the stability and resilience of our financial system. Transparency is fundamental to market integrity and investor confidence. The lack of transparency in the OCC's proposed rule change raised serious concerns about the potential for market manipulation and unfair practices. In the wake of the Archegos collapse, there was heightened scrutiny of the opacity surrounding certain market activities, underscoring the need for greater transparency and disclosure requirements. By rejecting the OCC's proposal, the SEC has reaffirmed its commitment to transparency and ensured that market participants have access to the information necessary to make informed decisions. Furthermore, the proposed adjustments to margin requirements during times of market volatility could have exacerbated systemic risks and amplified market instability. Margin requirements serve as a crucial risk management tool, and any changes to these requirements must be carefully evaluated to avoid unintended consequences. The SEC's decision to reject the OCC's proposal reflects a prudent approach to risk management and underscores the importance of maintaining stability in our financial markets, particularly in the face of heightened volatility and uncertainty, as evidenced by the Archegos debacle. In addition, the conflict of interest inherent in the role of the Financial Risk Management (FRM) Officer raised significant concerns about the independence and impartiality of regulatory oversight. Effective regulation requires unbiased decision-making and the avoidance of conflicts of interest that could compromise regulatory objectives. By rejecting the OCC's proposal, the SEC has demonstrated a commitment to ensuring that regulatory decisions are made in the best interest of investors and the broader public, free from undue influence or conflicts of interest. In conclusion, I commend the SEC for its decisive action in rejecting the OCC's proposed rule change. By prioritizing transparency, risk mitigation, and investor protection, the SEC has taken a critical step toward safeguarding the integrity and stability of our financial markets. In light of recent events, including the Archegos failure and the GameStop short squeeze, it is essential that regulatory authorities remain vigilant in addressing systemic risks and ensuring the fair and orderly functioning of our financial system. I stand in full support of the SEC's decision and urge continued vigilance in protecting the interests of investors and the broader economy. Thank you for your attention to this matter. Sincerely, Travis Beck Household Investor