Subject: sr-occ-2022-001
From: Philip Phipps
Affiliation:

Feb. 23, 2022

Do not let this rule pass. It does not help retail. This rule only helps the OCC and the members in higher standings. They will lower the margins when it is convenient or when the member in favor at the time needs it to be lowered. It is a rule that will be taken advantage of to avoid margin calls. I believe something similar happened to Robinhood and others in January of 2021. 


On top of that, this would also give the OCC a way to adjust margins in favor of larger members over smaller ones. Seems like it could be a way to weed out some members. 


It’s just a rule that would give them more leeway to get around other rules they dislike, all in the name of helping retail, but really just helping themselves.