Feb. 4, 2024
To whom it may concern, I am writing to express my deep concerns about the proposed rule change by the Options Clearing Corporation (OCC), specifically the adjustments to parameters for calculating margin requirements during periods of high market volatility. As a concerned stakeholder in the financial markets, I believe that the proposed changes warrant thorough reconsideration due to potential adverse effects on market stability, issues of transparency, and concerns related to the Financial Risk Management (FRM) Officer's role. Market Stability: One of my primary concerns revolves around the potential impact on market stability as a result of the proposed adjustments to margin requirements during periods of heightened volatility. While recognizing the need for risk management measures, I am apprehensive that the proposed changes might exacerbate market fluctuations rather than mitigate them. This could lead to increased systemic risk and may adversely affect market participants, including investors, brokers, and other stakeholders. Transparency Issues: Another area of concern is the apparent lack of transparency in redacted materials associated with the proposed rule change. The absence of detailed information makes it challenging for stakeholders to fully comprehend the implications of the adjustments, hindering our ability to provide constructive feedback. I respectfully request that the SEC ensures a higher level of transparency, allowing stakeholders access to comprehensive information to facilitate a more informed and meaningful review of the proposed rule. Conflict of Interest Concerns: The role of the Financial Risk Management (FRM) Officer in overseeing risk management practices is crucial for maintaining market integrity. However, it is essential to address the potential conflict of interest associated with this role, given that the FRM Officer may be tasked with both monitoring risk and advocating for rule changes that impact risk management. To ensure impartiality and safeguard the interests of market participants, it is imperative that the SEC thoroughly examines and addresses any perceived conflicts of interest in the proposed rule change. Advocacy for Reconsideration: In advocating for a thorough reconsideration of the proposed rule change, I urge the SEC to prioritize transparency, risk mitigation, and the broader market's well-being. It is crucial to strike a balance between effective risk management and market stability, ensuring that changes are implemented with a comprehensive understanding of their potential impact on various stakeholders. I appreciate the SEC's dedication to maintaining the integrity of our financial markets, and I trust that your careful consideration of these concerns will contribute to the development of a more robust and balanced regulatory framework. Thank you for your attention to this matter, and I am hopeful that our collective efforts will result in a financial ecosystem that prioritizes transparency, fairness, and stability. Sincerely, Steffen Knoche steffen.knoche@gmail.com