Feb. 5, 2024
To whom it may concern: I am writing to express my concerns regarding the proposed rule change by the Options Clearing Corporation (OCC) to adjust parameters for calculating margin requirements during periods of high market volatility. First and foremost, my apprehensions revolve around the potential impact on market stability. The proposed adjustments may inadvertently exacerbate volatility rather than mitigate it, potentially leading to increased market risks and uncertainties. I urge you to thoroughly evaluate the potential consequences on overall market stability before endorsing such changes. Furthermore, there is a notable lack of transparency in the redacted materials associated with the proposed rule. This lack of openness raises serious concerns about the fairness and completeness of the decision-making process. As a concerned market participant, I strongly advocate for increased transparency to ensure that all stakeholders have access to pertinent information that can inform their understanding of the proposed changes. Additionally, I wish to draw attention to the inherent conflict of interest associated with the role of the Financial Risk Management (FRM) Officer. Clear delineation of roles and responsibilities is crucial to maintaining the integrity of risk management processes. I respectfully request you to scrutinize this aspect carefully and consider measures to address potential conflicts to uphold the highest standards of governance. In advocating for a thorough reconsideration of the proposed rule change, I emphasize the paramount importance of transparency, effective risk mitigation, and the broader market's well-being. Striking the right balance between risk management and market efficiency is vital for the continued health of our financial markets. Thank you for your time and consideration of these concerns. I am confident that you will approach this matter with the diligence and dedication it deserves, safeguarding the interests of all market participants. Sincerely, Chad Theriot