Feb. 4, 2024
Dear SEC, I am writing to express my opposition to the proposed rule change by the OCC regarding the adjustment of parameters for calculating margin requirements during periods of high market volatility. As a concerned european who is also a participant in the U.S. stock market, I believe that the proposed changes may have significant implications for market stability, transparency, and the broader financial ecosystem. Firstly, I am apprehensive about the potential impact of the proposed rule change on market stability. The proposed adjustments may inadvertently exacerbate volatility by inadequately accounting for the risks associated with increased market fluctuations. It is essential to ensure that margin requirements adequately reflect the true risks to prevent market disruptions and protect the interests of all market participants. Secondly, my concern extends to the lack of transparency in the redacted materials associated with the proposed rule change. Transparency is fundamental to maintaining trust in the financial markets and ensuring that all stakeholders have access to the information necessary to make informed decisions. Furthermore, I am troubled by the potential conflict of interest associated with the role of the FRM Officers in the decision-making process. As they play a pivotal role in shaping risk management policies, it is imperative to ensure that there is no perceived or actual conflict of interest that could compromise the objectivity and fairness of the decision-making process. I urge you to conduct a thorough review of the governance structure at OCC to address any potential conflicts and ensure the independence of decision-making. I appreciate your commitment to ensuring fair and efficient markets, and I trust that your thorough evaluation of these concerns will lead to a well-informed decision. Thank you for your attention to this matter, and I look forward to a transparent and comprehensive assessment of the proposed rule change. Sincerely, Ömer Yildiz