Feb. 2, 2024
Dear SEC, I am writing to express my concerns regarding the proposed rule change by the Options Clearing Corporation (OCC) to adjust parameters for calculating margin requirements during periods of high market volatility. In order to ensure that market participants allocate necessary capital when making risky bets, it is imperative that margin requirements remain static and not fluctuate based on certain criteria. Furthermore, I am apprehensive about the inherent conflict of interest associated with the Financial Risk Management (FRM) Officer’s role. The proposal places significant responsibility on this individual, whose primary duty is to safeguard OCC’s interests. This could lead to a situation where the FRM Officer prioritizes OCC’s interests over the broader market’s well-being. Sincerely, Anthony Gripper