Jan. 31, 2024
Greetings! As a individual investor, I have been increasingly alarmed at the evident instability inherent in our financial market systems yet artfully concealed from the broader public. I also applaud opportunities like this to share insights in public comments in order to show that not everyone is blind to the shenanigans of Wall Street. One recent example of Wall Street seeking its own interests over that of the broader markets and retail investors is the proposed rule SR-OCC-2024-001. This rule is a clear attempt by the OCC to avoid the obligations of its members to follow strict risk management protocols and thus continue allowing members most at risk during volatile instability avoid being responsible for their bad investment choices. In addition, I have concerns regarding the proposed usage of a Financial Risk Management (FRM) Officer. When such person's primary duty is to safeguard the OCC's interests and thus preserve and protect members from margin calls that exist to manage risk, how then are the markets supposed to regulate? The fact of the matter is when investments are clearly going south and have crossed way beyond safe risk territory into bad, then the number one priority of Wall Street should be to exit the risky positions, NOT to shield the individuals or firms or organizations from margin calls. Another area of concern in this proposed rule has to do with the OCC's loss allocation. Clearing Fund deposits of non-defaulting firms are evidently fourth in line during market stress events, after the OCC's own pool of funds. A better plan would be to shift this around such that Clearing Fund deposits come before the OCC's pool, which would make the contributions of Clearing Fund members have a more immediate role in covering losses. This is a good idea to align with principles of equity and transparency in the OCC's risk management structure. In summary, as an keenly interested investor, I applaud attempts by the SEC to foster a financial environment that prioritizes fairness, transparency, and the continued smooth well-being of all market participants and vigorously object to attempts such as this proposed rule to promote Wall Street advantages at the expense of others. Sent with Proton Mail secure email.