Hello,
I am writing to express my urgent opposition to the proposed rule change by the Options Clearing Corporation (OCC) regarding margin requirements during periods of high market volatility. As regulators entrusted with maintaining the stability and fairness of our financial markets, it is essential to consider the potential consequences of this proposed rule change.
The proposed rule change favors OCC members and shields them from accountability during turbulent times, contradicts the principles of fairness and transparency that form the foundation of our financial system. When confidence is lost in the fairness of the market, investors will remove their money, simple as that.
Increasing margins is counterintuitive to the very essence of regulatory oversight. The proposed rule change fails to address the fundamental problem that OCC, as it stands, lacks the financial capacity to rescue even a single defaulting member, let alone multiple defaults simultaneously. This situation raises serious doubts about the OCC's ability to fulfill its role in protecting market integrity and stability during times of crisis.
The American people are aware of those responsible for decisions affecting their investments and the health of the markets they participate in. The proposed rule change, in its current form, risks eroding public trust in the regulatory process and is a departure from the SEC's commitment to maintaining free and fair markets.
In conclusion, I implore you, as regulators, to reconsider this proposed rule change thoroughly. The well-being of our financial markets, the trust of the American people, and the integrity of the regulatory process are at stake. This rule change, in its current state, cannot be allowed to proceed without jeopardizing the very principles it is meant to uphold.
Dana Kuehneman