February 7, 2022
In order to benefit their members the Options Clearing Corporation is using mostly confidential information without exhibiting their formulas. That will inevitably negatively impact direct participants without membership simply to, reduce the likelihood that OCCs models would produce extreme, overreactive margin requirements that could strain the ability of certain Clearing Members to meet their daily margin requirements (the current calculation).
If the Securities and Exchange Commission allows the increased risk to the financial markets that this change will facilitate, the Options Clearing Corporation members will be enabled to have such little margin set aside that it all but ensures some will fail and the expenses will be unwittingly borne by the direct investors the Securities and Exchange Commission intends to protect solely because the Options Clearing Corporation wants to decrease their members margin requirements and thereby increase their profits.
The margin requirements as they exist currently are safer and more protective. Please dont permit this change that increases the whole financial markets risk solely to advantage the few extremely large financial corporations.