Feb. 4, 2024
Dear Securities and Exchange Commission, I hope this letter finds you well. I am writing to express my profound concerns 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 invested in the integrity and stability of our financial markets, I believe it is imperative to address several critical issues inherent in the proposed amendment. First and foremost, the potential impact on market stability is of paramount concern. While the OCC may intend to enhance risk management practices through these adjustments, the ramifications of such changes during periods of heightened volatility could exacerbate systemic risks and amplify market uncertainties. As demonstrated by historical precedents, abrupt alterations to margin requirements can catalyze cascading effects, triggering panic-driven sell-offs and destabilizing market dynamics. Therefore, it is imperative that any modifications to margin parameters be meticulously scrutinized and predicated upon comprehensive risk assessments to safeguard against unintended consequences. Furthermore, the lack of transparency surrounding certain redacted materials pertinent to the proposed rule change raises significant apprehensions regarding procedural integrity and stakeholder inclusivity. As stakeholders, we are entitled to access transparent and comprehensible information to facilitate informed decision-making and ensure regulatory accountability. Regrettably, the opacity surrounding redacted materials undermines the principles of transparency and fosters an environment of uncertainty, thereby impeding constructive dialogue and inhibiting meaningful engagement with affected stakeholders. Additionally, the inherent conflict of interest associated with the role of the Financial Risk Management (FRM) Officer necessitates a reevaluation of the proposed rule change. While the FRM Officer is entrusted with overseeing risk management protocols, the confluence of regulatory oversight and operational responsibilities presents a potential conflict of interest that may compromise the efficacy of risk management frameworks. To mitigate such conflicts and uphold regulatory integrity, it is imperative to establish robust governance mechanisms and delineate clear lines of accountability to safeguard against undue influence and ensure the impartiality of risk management decisions. In light of the aforementioned concerns, I urge [SEC/Relevant Regulatory Body] to undertake a thorough reconsideration of the proposed rule change and solicit broader stakeholder input to foster transparency, enhance risk mitigation practices, and uphold the integrity of our financial markets. By prioritizing transparency, promoting stakeholder engagement, and adhering to rigorous risk management standards, we can collectively fortify the resilience of our financial ecosystem and safeguard against systemic vulnerabilities. Thank you for considering my concerns and advocating for the broader market's well-being. I remain committed to constructive dialogue and collaborative efforts aimed at promoting regulatory accountability and advancing the interests of all stakeholders. Sincerely, Chad Storer