Feb. 2, 2024
Geraldo Hernandez Firefighter Hernandez Subject: Concerns Regarding Proposed Rule Change on Margin Requirement Calculation Parameters Dear SEC I trust this letter finds you well. I am writing to express my concerns about the recent proposal by the Options Clearing Corporation (OCC) to adjust parameters for calculating margin requirements during periods of high market volatility. As a concerned participant in the financial markets, I believe it is crucial to voice apprehensions regarding potential repercussions on market stability and risk management. Firstly, the proposed rule change raises significant worries about its impact on market stability. Given the unpredictable nature of high market volatility, adjusting margin requirements may inadvertently exacerbate risks and lead to unforeseen consequences. I urge thorough consideration of the potential destabilizing effects on the broader financial ecosystem. Furthermore, the lack of transparency in redacted material within the proposal is disconcerting. Transparency is fundamental for market participants to make informed decisions and maintain confidence in the regulatory framework. I request a more comprehensive disclosure of pertinent information to ensure a fair and transparent market environment. In addition, the role of Financial Risk Management (FRM) officers introduces an inherent conflict of interest. The proposed changes involve financial risk management, and it is essential to scrutinize potential conflicts to maintain the integrity of risk assessment processes. Clear delineation of responsibilities and impartial decision-making are imperative to foster trust in the regulatory apparatus. I respectfully urge [SEC/Relevant Regulatory Body] to reconsider the proposed rule change, emphasizing the importance of transparency, robust risk mitigation, and the overall well-being of the broader market. Striking a balance between adaptability to market conditions and preserving stability is paramount for the sustainability of our financial markets. Thank you for your attention to this matter. I am confident that a thorough reconsideration, taking into account the concerns raised, will contribute to the continued resilience and trustworthiness of our financial system. Sincerely, Geraldo Hernandez Sent from Yahoo Mail for iPhone