Subject: Comments on SR-OCC-2024-001 34-99393
From: Adam Krieger
Affiliation:

Feb. 2, 2024

I oppose this rule. 

What's the point in having rules if you're going to make exceptions for the riskiest members anytime they break them. You're enabling the exact behavior you're supposed to police by not enforcing rules for transparency and fairness in the markets. These same members already experience an advantage of additional information through payment for order flow, delayed reporting and a general lack of transparency. 
If market participants decide to make risky bets with all of that additional information they should not be given a free pass when those bets don't turn out in their favor. 
There are two sides to every trade and protecting one side not to pay out on a bad trade leaves the other side of the trade cheated. Market volatility is an aspect of the market that people make trades on daily including market makers. It's completely corrupt to allow market participants to make money on volatility trades every day throughout the year and then protect those same participants on certain days when it doesn't work in their favor. You can't have rules for some and not others, either margin calls are a part of the market for everyone or they're part of the market for no one. You're creating a two-tier system, where those with money have exceptions to the rules and not pay on their bad bets but those was very little money have to follow the rules and pay. 


Adam Krieger