Feb. 5, 2024
Hello Secretary Countryman and others concerned, I would like to voice my opposition to this proposed rule SR-OCC-2024-001; release no. 34-99393: Notice of Filing of Proposed Rule Change by the Options Clearing Corporation Concerning Its Process for Adjusting Certain Parameters in Its Proprietary System for Calculating Margin Requirements During Periods When the Products It Clears and and the Markets It Serves Experience High Volatility. I believe this proposal creates an unfair system where true supply and demand are separated from the market. I believe these proposed margin requirements to not be appropriately robust, especially for entities engaged in short selling activities. Strict margin requirements are a necessary deterrent against excessive risk taking. Lastly, I’ll state again but can’t be emphatic enough about, if certain market entities are playing by different rules, it removes the effect of supply and demand from the market. This destroys faith in the market and future public investment. For the market to function properly, strict margin requirements must be enforced. Thank you for your consideration. Matthew Waterman,