Feb. 4, 2024
Dear Honorary Members of the Securities and Exchange Commission, I write to you this day to express my deepest concerns over the proposed rule change by the Options Clearing Corporation (OCC) encompassing an adjustment of parameters used during calculating margin requirements during periods of high market volatility. As an avid long-term, household investor in our fine markets it is with great interest to myself and other household investors that our markets express fairness and stability across each participant, regardless of status or investment capability. This proposed rule, in its current iteration, appears to offer additional aid to risky financial positions during periods of high market volatility through undermining the very basis of the current protective measure already set into place for this very reason. Altering the parameters behind a margin call will further imbalance the market structure allowing certain participants to avoid the additional collateral requirements to maintain their risky market positions. Without this risk management mechanism in place for each of its participants, I fear our markets will be further exposed to an implicit unfairness which will further endanger our reputation with the rest of the world and any and all future participants. This new rule also threatens the deeper stability of out markets, allowing some participants to "change the rules" whenever their positions, and their positions alone, have gone underwater from their own risky behavior. A resilient, financial ecosystem requires a foundation of trust and transparency in each of its participants. This foundation can only be built on an implicit fairness across the broader market, where everyone plays by the same rules regardless of times of volatility. Please consider the long-term effects of these rule changes, as I and many other household investors are unsure of the future consequences if the rest of the world (and my fellow Americans) begin to perceive our markets as a "rigged casino." As a scientist for over two decades, I have found that integrity is very difficult to recover once its been lost. I trust the SEC will consider everyone's deeper concerns during the rule making process, and I personally wish you each the strength necessary for the Herculean task of upholding the integrity of the greatest financial market in the world. Godspeed, Derek C. Sent with Proton Mail secure email.