Feb. 4, 2024
Dear SEC, I hope this letter finds you well. I am writing to express my concerns and reservations 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 a concerned stakeholder in the financial markets, I believe it is crucial to address certain aspects of the proposed rule change that, in my opinion, pose potential risks to market stability and transparency. Firstly, I would like to express my apprehension about the potential impact that the proposed adjustments may have on market stability. While I understand the necessity of adapting to changing market conditions, there is a need for a thorough examination of the proposed changes' potential ramifications. Sudden and drastic adjustments to margin requirements during periods of high volatility may exacerbate market fluctuations and contribute to increased systemic risk. I urge the Options Clearing Corporation to conduct a comprehensive risk assessment to ensure that the proposed changes align with the overarching goal of market stability. Secondly, I am concerned about the lack of transparency in the redacted materials associated with the proposed rule change. Transparency is paramount in maintaining trust and confidence in financial markets. Redacted information raises questions about the openness and accessibility of key details that stakeholders need to make informed decisions. I respectfully request that the OCC reconsider the redaction of materials and provide stakeholders with a complete and unambiguous understanding of the proposed changes. Furthermore, I would like to draw attention to the inherent conflict of interest associated with the role of the Financial Risk Management (FRM) Officer. While the FRM Officer plays a crucial role in risk management, the potential for conflicts of interest must be carefully addressed and mitigated. It is imperative that the OCC reviews and discloses measures in place to manage conflicts of interest within its organizational structure to uphold the highest standards of integrity. In advocating for a reconsideration of the proposed rule change, I urge the OCC to prioritize transparency, risk mitigation, and the broader market's well-being. I believe that a thorough and open discussion with relevant stakeholders, including the [SEC/Relevant Regulatory Body], is essential to ensure that the proposed changes are in the best interest of the market and its participants. I appreciate your attention to these concerns and trust that the OCC will take the necessary steps to address them. I look forward to a constructive dialogue and a careful reconsideration of the proposed rule change. Thank you for your time and consideration. Sincerely, A concerned Retail Investor