Feb. 4, 2024
Dear Members of the Securities and Exchange Commission, I trust this email 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. While I recognize the need for periodic reassessment of regulatory frameworks, I am concerned about the potential consequences of the proposed changes on market stability, the lack of transparency in redacted materials, and the clear conflict of interest associated with the role of the Financial Risk Management (FRM) Officer. Firstly, my primary concern is the potential impact on market stability. The proposed adjustments to margin requirements, particularly during times of heightened volatility, could inadvertently amplify systemic risks. Striking a balance between accommodating market dynamics and ensuring the stability and integrity of our financial markets is crucial. I urge the Securities and Exchange Commission to thoroughly assess the potential repercussions on market participants and overall stability before endorsing the proposed rule change. Secondly, the redacted materials accompanying the proposal raise deep concerns about transparency. A lack of transparency can undermine investor confidence and hinder the market's ability to function effectively. I request the SEC to scrutinize these redacted materials closely and ensure that market participants have access to comprehensive information to make informed decisions. Transparency is fundamental to maintaining a fair and well-functioning financial system. Lastly, the role of the Financial Risk Management (FRM) Officer introduces an inherent conflict of interest. It is imperative that the SEC carefully examines the potential conflicts associated with this role to safeguard the market's integrity. A thorough evaluation of the proposed rule change should include an assessment of the governance structure and potential conflicts, ensuring that risk management decisions are made with the utmost objectivity and in the best interest of the broader market. In advocating for a reconsideration of the proposed rule change, I emphasize the importance of transparency, risk mitigation, and the well-being of the broader market. A robust regulatory framework is essential to maintaining market integrity and protecting the interests of all stakeholders. I appreciate the SEC's commitment to ensuring fair and efficient markets and trust that a careful evaluation of these concerns will guide a decision that prioritizes the stability and transparency of our financial system. Thank you for your attention to this matter, and I look forward to a thorough examination of the concerns raised. Sincerely, Joshua Cyr Get Outlook for Android