Feb. 4, 2024
Dear Securities and Exchange Commission, I'm writing to express concerns about the Options Clearing Corporation (OCC) proposal to adjust margin requirements in volatile markets. As a dedicated investor, I value market stability and fairness and wish to highlight several issues. The proposed rule may protect risky positions by limiting margin calls during volatility, potentially undermining risk management and market stability. The reliance on the Financial Risk Management (FRM) Officer and the conflict of interest it presents, along with the proposal's lack of transparency, could harm trust and market integrity. I suggest reconsidering the OCC's loss allocation framework to prioritize Clearing Members' contributions over OCC's resources, promoting equity and resilience. Additionally, implementing safeguards like an independent review mechanism and enhancing transparency could address potential conflicts and improve regulatory accountability. Further recommendations include increasing transparency, enhancing oversight, encouraging public input, and establishing industry standards. These changes aim to ensure fair and transparent market practices. I trust the SEC will consider these points to maintain market integrity and protect all participants. Sincerely, Best regards Paul Müller - - - - - - - - - - - This e-mail (and/or attachments) is confidential and may be privileged. Use or disclosure of it by anyone other than a designated addressee is unauthorized. If you are not an intended recipient, please delete this e-mail from the computer on which you received it. We thank you for notifying us immediately.