Feb. 4, 2024
Dear SEC, I am writing to express concerns about the Options Clearing Corporation's (OCC) proposed rule change on margin requirements during high market volatility. (SR-OCC-2024-001 34-99393) The proposed rule may unintentionally shield risky positions from standard risk management mechanisms, potentially leading to unchecked growth in risky positions and threatening long-term market stability. The role of the Financial Risk Management (FRM) Officer raises concerns due to a potential conflict of interest. The lack of transparency in redacted materials limits our ability to evaluate the proposed rule effectively. To address these concerns, I recommend prioritizing transparency, reconsidering the loss allocation framework, and implementing an independent review mechanism. These measures aim to ensure fairness, accountability, and market integrity. I trust the SEC will thoroughly consider these concerns during the rule-making process. Sincerely, Robert D’alessandro Sent from my iPhone