Feb. 5, 2024
Dear Securities and Exchange Commission, I am writing to express my concerns regarding the proposed rule change SR-OCC-2024-001 by the Options Clearing Corporation (OCC) to adjust parameters for calculating margin requirements during periods of high market volatility. The American Dream is built upon the principles of democratic representation, basic rights, liberty, and equality. It is the principle of equality that appears to be at risk with the proposed rule change SR-OCC-2024-001. In situations where an investor, like myself, is obliged to promptly rectify a lack of margin for an imbalanced options position or face liquidation, questions arise about the integrity and fairness of rule SR-OCC-2024-001. This is because the Options Clearing Corporation (OCC) would possess the ability to bypass its standard margin requirements through recalculations giving the OCC’s members an unfair advantage over the average investor. Margin requirements exist to safeguard counterparties and the overall market from excessive risk and over-leveraging. Rule SR-OCC-2024-001 appears to dismantle this safety net precisely when it is most needed to hold the OCC and its members accountable for their actions. The proposed rule change could inadvertently incentivize the OCC and its members to take on greater risks, thereby undermining the very foundation of our market. In the interest of upholding the principles of fairness and maintaining the integrity of our financial markets, I respectfully request that the SEC rejects the proposed rule change SR-OCC-2024-001. Thank you for your time and consideration. Sincerely, Michael Logan