Subject: SR-OCC-2024-001 34-99393
From: zazik swan
Affiliation:

Feb. 7, 2024

Dear [Recipient’s Name], I hope this message finds you well. 


I am writing to express my deep concerns regarding the recent announcement by the Securities and Exchange Commission (SEC) about the Options Clearing Corporation’s (OCC) proposed rule change, which aims to remove margin requirements for its banking cartel members during periods of high volatility. The rationale provided, that a sudden and extreme increase in margin requirements could unduly stress a member’s liquidity and potentially lead to defaults and unexpected costs for non-defaulting members, is understandable. However, this approach appears to overlook the fundamental principles of accountability and risk management that should govern financial markets. Banks and financial institutions, as pivotal players in the economic landscape, should be adequately prepared for periods of volatility and should not be exempt from the safeguards designed to maintain market stability and integrity. Removing margin requirements during critical times could set a dangerous precedent, potentially encouraging imprudent risk-taking and undermining the very mechanisms intended to protect the market and its participants from systemic risks. It is crucial to maintain a balanced approach that ensures liquidity and sustains operations without compromising on the accountability measures that keep the financial system robust and secure. Offering carte blanche to major banking entities during volatile periods might not be in the best interest of the broader market and could lead to significant long-term repercussions. Therefore, I urge the SEC and the OCC to reconsider this proposed rule change, taking into account the need for a resilient and accountable financial environment. It is essential to implement policies that safeguard against undue risk while ensuring that all market participants are held to standards that promote stability and fairness. Thank you for taking the time to consider my perspective on this matter. I look forward to your response and am keen to see how the SEC and the OCC will address these concerns moving forward. 


Sincerely, a concerned investor