Subject: SR-OCC-2024-001: Webform Comments from Kevin OBrien
From: Kevin OBrien
Affiliation:

Feb. 2, 2024

The OCC should not have the ability to adjust certain
parameters for calculating margin requirements during periods of high
volatility. It would seem that these adjustments could be made to save
an member from being margin called if they could not meet the margin
requirements. If they default and great stress is put on other
clearing members, then they have not properly accounted for risk and
should be penalized instead of waiving/adjusting the requirements. It
could lead to market manipulation if these and other members know that
they will not be margin called. If the OCC has the ability to change
parameters to prevent these events from happening, members will
continue to increase risk. The proposal is requesting a change to the
Margin Policy when this policy has worked effectively sets well
established guide rails for members. If this Margin Policy is to
change, it will most likely lower the chance of a member from being
margin called and that would lead to others increasing their risk as
well. This would decrease market stability instead of the proposed
increase in market stability this proposal claims.