Feb. 5, 2024
Hey SEC team, Hope this note finds you well. Just wanted to drop a line about the whole Options Clearing Corporation (OCC) rule change thing on margin requirements during market craziness. As someone who's in it for the long haul and all about market stability, I thought it's worth sharing my two cents on this proposal (SR-OCC-2024-001). The idea of locking in margin threshold calculations seems a bit sketchy, you know? Like, it might unintentionally protect those risky financial moves when things get wild. If we make these adjustments based on market conditions, it could mess with the usual risk management vibe, letting folks with dicey risks off the hook. And considering the OCC's track record of frequent control setting changes, it feels like we're playing with fire in terms of long-term market stability. Now, let's talk about the Financial Risk Management (FRM) Officer's role. That's a bit of a red flag, creating a potential conflict of interest. We want to make sure the OCC's interests don't overshadow the broader market's well-being. Plus, those redacted materials don't help with transparency, making it tough to see what's what. I've got a suggestion: let's prioritize Clearing Fund deposits from non-defaulting firms over the OCC's pre-funded resources. That way, the contributions from Clearing Members can jump in right away to cover losses, keeping things fair and transparent. And let's throw in an independent review to check the impact of control settings and beef up transparency requirements. To wrap it up, I'm all about creating a financial scene that's fair, transparent, and good for everyone involved. I trust the SEC will take these concerns to heart and come up with a rule that manages risk without sacrificing the core principles of a solid market. Cheers, Mvh/Kind Regards/ Mit freundlichen Grüßen Mattias Wihlborg Madsen www.madsensfjedre.dk Madsens Fjedre & Metalvarefabrik Midtager 26A 2605 Brøndby Tlf. : +45 4342 9008 Mobil. : +45 4021 9019