Feb. 5, 2024
Dear SEC, I trust this letter finds you well. I am writing to express my deep concerns regarding the proposed rule change by the Options Clearing Corporation (OCC) pertaining to the adjustment of parameters for calculating margin requirements during periods of high market volatility. Firstly, my apprehensions primarily revolve around the potential impact this rule change may have on market stability. The proposed adjustments, as outlined in the redacted materials, raise uncertainties about their implications for risk management and the overall health of the financial markets. The lack of transparency in these materials is a significant cause for concern, as it hinders market participants' ability to fully comprehend the potential risks and make informed decisions. Moreover, the inherent conflict of interest associated with the role of the Financial Risk Management (FRM) Officer raises questions about the objectivity of the proposed rule change. The potential for conflicting interests may compromise the effectiveness of risk management measures and erode market participants' trust in the regulatory framework. It is crucial that the regulatory body ensures the independence and impartiality of key decision-makers to maintain the integrity of the financial system. I urge the SEC to thoroughly reconsider the proposed rule change in light of these concerns. Transparency is paramount in fostering a robust and resilient financial market. Therefore, I advocate for a more comprehensive disclosure of the redacted materials to allow market participants to assess the proposed changes thoroughly. Additionally, it is essential to prioritise risk mitigation strategies that not only protect market participants but also contribute to the broader market's well-being. A comprehensive and transparent review of the proposed rule change will contribute to instilling confidence in the financial markets and ensuring their stability during times of heightened volatility. In conclusion, I appreciate the work of the SEC in safeguarding the interests of household investors and maintaining a fair and efficient marketplace. I trust that your thorough reconsideration of the proposed rule change will prioritise transparency, risk mitigation, and the overall stability of the financial markets. Thank you for your attention to this matter, and I look forward to a positive resolution that upholds the highest standards of market integrity. Sincerely, Abdul L