Subject: SR-OCC-2023-008
From: Mary Smith
Affiliation:

Jan. 10, 2024

Every submission the Options Clearing Corporation submits belittles the severity of the proposed changes which increases risks to market participants. From reducing their “continuous” responsibility to “market trading hours,” “more broadly describe,” reducing automation (page 7) and end-of-day requirements (page 8). “Daily monitoring requirement are no longer necessary.” And similarly monthly. Eliminating otherwise required liquidations (page 14) of bad actors, allowing the risk to run, due to their more subjective “considerations.” Mostly, as stated on page 33, this entire document is an attempt to “exercise its discretion” rather than rules, making the Exchange Act less transparent and enforceable (page 35).