Feb. 7, 2024
Thank you for the opportunity to comment on SR-OCC-2024-001 34-99393, "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 the Markets It Serves Experience High Volatility". I ADAMANTLY OPPOSE this proposal. As a retail trader, I have spent 27 years of my adult life trading, attempting to build an investment that will serve me in retirement. I also manage my son's custodial account, with which he will be able to pursue higher education or a career. With some securities I have purchased, I have unrealized losses in the tens of thousands of dollars due to short selling by unscrupulous actors, gambling with leveraged funds. I am okay with this because I made my investments based on my evaluation of the company valuations, their boards, their business plans, and their current leadership. I believe some of these securities will see some extreme upside pricing action during market volatility because of the over-leveraged positions of the short sellers. No information in proposed rules or supporting information should be redacted. It's not an open and transparent process when critical details are hidden from the public. Reject this rule. Clearing Members are perfectly okay pushing the limits of leverage, swaps and other derivative trading to maximize profits. They undertook these investments knowing what their margin requirements and liabilities were. They are the ones that pushed the envelope. No allowances for reduced margin should be allowed during volatility. Markets are volatile. Markets with highly leveraged investments are even more volatile. They got themselves into these trades, they can get themselves out. I am retail. I am stuck with my unrealized losses by simply buying a security and holding it. I am doing nothing wrong. If my securities have to be repurchased on the open market during volatile market conditions, then they have to be repurchased. They have commitments. If I buy on margin, I have to cover my bets. If I buy options, I have to cover my bets. No Clearing Members are too big to fail. If the OCC has systemic risks, then maybe the "betting" behavior needs to be reigned in. Do not screw the retail trader, again. Reject this proposed rule. Respectfully, Rebecca Schwanke