Feb. 2, 2024
Hello, Thank you for the opportunity to comment on SR-OCC-2024-001 34-99393, "Proposed Rule Change by The Options Clearing Corporation Concerning Its Process for Adjusting Certain Parameters in Its Proprietary System for Calculating Margin Requirements During Periods When the Products It Clears and the Markets It Serves Experience High Volatility." I do not support its approval. There is no precedent for exemption, given that the OCC has the capability of instituting wide scale regulations in a manner that would not compromise the consistent application of OCC rule compliance. The lack of transparency through circumventing public review should not allow this to move forward to begin with. This proposal does nothing more than protect Clearing Members from failing to do their jobs properly; assessing the risk in large scale trades is an essential part. Perhaps, if they were to participate in less risky trade, there would be fewer potential consequences-- the only argument against is greed. Do better. Maryn O'Brien