Feb. 2, 2024
Dear SEC, I hope this letter finds you well. I am writing to express my deep 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, as outlined in the recent publication [Reference Document/Notice]. I believe that this proposed rule change has the potential to adversely impact market stability, lacks transparency in certain redacted materials, and raises concerns about the inherent conflict of interest associated with the Financial Risk Management (FRM) Officer's role. First and foremost, I am apprehensive about the potential consequences of adjusting margin requirements during periods of high market volatility. While I understand the need for risk management measures, there is a delicate balance between safeguarding against excessive risk and ensuring market stability. The proposed changes may inadvertently contribute to increased market fragility by amplifying the impact of market downturns, potentially exacerbating systemic risks. Additionally, the redacted materials within the proposal have raised significant concerns about the lack of transparency in the decision-making process. Transparent communication is vital for market participants to fully comprehend the implications of the proposed rule change and make informed decisions. I urge [SEC/Relevant Regulatory Body] to require the OCC to provide unredacted information, ensuring that all stakeholders have access to the necessary details to assess the proposal's potential impact comprehensively. Furthermore, I would like to draw attention to the inherent conflict of interest associated with the role of the Financial Risk Management (FRM) Officer in the decision-making process. The FRM Officer, as a key figure in risk management, holds a pivotal position that demands objectivity and independence. However, the potential conflict of interest, whether real or perceived, requires careful consideration to maintain the integrity of the decision-making process. In light of these concerns, I respectfully advocate for a thorough reconsideration of the proposed rule change by [SEC/Relevant Regulatory Body]. It is imperative to prioritize transparency, risk mitigation, and the broader market's well-being. I request that [SEC/Relevant Regulatory Body] conducts a comprehensive review, including a thorough examination of the potential market impact, the transparency of the proposal, and the effectiveness of risk management strategies. Thank you for your attention to this matter. I trust that [SEC/Relevant Regulatory Body] will carefully evaluate the concerns raised and take appropriate actions to ensure the continued stability and integrity of our financial markets. Sincerely, Will Tran Concerned American Citizen