Subject: Comments regarding proposed rule change SR-OCC-2024-001 34-99393
From: d c
Affiliation:

Feb. 2, 2024

Hello Big Wigs at the Securities and Exchange Commission, 


Listen please because while you may get a ton of requests, this matters. The health of this countries financial markets is in your hands, and it is your obligation to at least consider the repercussions here. I want to express my concerns about this proposed rule change by the Options Clearing Corporation (OCC) to adjust parameters for calculating margin requirements during periods of high market volatility. I appreciate the ability to add my input on this matter because, as a member of the financial community, I believe it is crucial to thoroughly examine the potential impact of this change on market stability, transparency, and the inherent conflict of interest associated with the Financial Risk Management (FRM) Officer's role. 


Firstly, I would like to address the inherent conflict of interest associated with the FRM Officer's role. As the OCC's Financial Risk Management Officer is responsible for setting margin requirements, there is a potential conflict of interest that could lead to decisions favoring the OCC's interests over those of the broader market. This conflict of interest should be carefully considered and addressed before any rule changes are implemented. 


I am very concerned about the potential impact of this rule change on market stability. The OCC's proposal to adjust parameters for calculating margin requirements during high market volatility could create a cascade effect, leading to increased volatility and potential market instability. This is particularly alarming given the current state of financial markets, which have already experienced significant fluctuations due to various economic factors. 


I am also extremely bothered by the lack of transparency in the redacted materials provided by the OCC. It is essential for regulators and market participants to have access to clear and comprehensive information regarding proposed rule changes. The redaction of certain materials makes it impossible to assess the potential effects of this rule change on the financial markets and individual market participants. 


In light of these concerns, I urge you the big bad SEC to reconsider the proposed rule change with transparency, risk mitigation, and the well-being of the broader market in mind. Let's not mess with our financial markets, okay? 


Thanks for taking this matter seriously. I believe a thorough review and reconsideration of the proposed rule change will help maintain the trust and confidence of market participants and the general public in our financial markets. 


But let's be real, here. Don't you think it's high time we stop playing games with our financial markets? It's clear that the OCC is trying to pull a fast one here all this rule change, and it's your responsibility to call them out on their BS. Please do what's right – and that means being honest, transparent, and focused on the greater good. 


Best regards, 


Derek Clary