Feb. 5, 2024
I would like to express my concerns about the proposed rule SR-OCC-2024-001 / 34-99393 change by the Options Clearing Corporation (OCC) to adjust parameters for calculating margin requirements during periods of high market volatility as potential unintended consequences, such as shielding risky positions during volatile market conditions. transparency in redacted materials, and the inherent conflict of interest associated with the Financial Risk Management (FRM) Officer's in the role of the Financial Risk Management (FRM) Officer. in addition to the lack of transparency due to redacted materials accompanying the proposal. It is very essential to set up a balanced risk manageent that allows margin calls and therefore maintain the market stability ,the proposal has unfortunately the potential to undermie these mechanisms, leading to unchecked risk exposure ,so its is important to adjust parameters in a way that balances risk management with broader market interests. Thus i would like to recommend a reassessment of the loss allocation framework to prioritise Clearing Fund deposits over the OCC's pre-funded resources and propose the implementation of an independent review mechanism to ensure impartial evaluation of control settings. In additoion i would like to advocate for enhanced transparency measures, such as providing non-confidential summaries of redacted materials. and suggest strengthening oversight mechanisms and incorporating public input in decision-making processes beside emphasising the importance of industry-wide standards and best practices to promote market stability. Its is very vital for the market to collaborate with stakeholders to establish industry-wide standards and best practices and give more importance to public accessibility to stress testing results to demonstrate the effectiveness of risk management measures. I reiterate my commitment to fostering a financial environment that prioritises fairness and transparency and express confidence in the SEC's ability to thoroughly consider the concerns raised during the rulemaking process.