Subject: Comments on SR-OCC-2024-001 34-99393
From: marc bergeron
Affiliation:

Feb. 7, 2024

It is time you stop allowing the crimes of the stock market. The sec has gone too far into corruption. Short selling is already starting to be banned as well as the market makers in some countries. Enough of the corrupted ponzy scheme that line your pockets 



Thank you for the opportunity to comment on SR-OCC-2024-001 34-99393 entitled "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" (PDF, Federal Register) as a retail investor. I have several concerns about the OCC rule proposal, do not support its approval, and appreciate the opportunity to comment. 



I'm concerned about the lack of transparency in our financial system as evidenced by this rule proposal, amongst others. The details of this proposal in Exhibit 5 along with supporting information (see, e.g., Exhibit 3) are significantly redacted which prevents public review making it impossible for the public to meaningfully review and comment on this proposal. Without opportunity for a full public review, this proposal should be rejected on that basis alone. Public review is of the particular importance as the OCC's Proposed Rule blames U.S. regulators for failing to require the OCC adopt prescriptive procyclicality controls ("U.S. regulators chose not to adopt the types of prescriptive procyclicality controls codified by financial regulators in other jurisdictions." [1]). As "procyclicality may be evidenced by increasing margin in times of stressed market conditions" [2], an "increase in margin requirements could stress a Clearing Member's ability to obtain liquidity to meet its obligations to OCC" [ld.] which "could expose OCC to financial risks if a Clearing Member fails to fulfil its obligations" [3] that "could threaten the stability of its members during periods of heightened volatility" [2]. With the OCC designated as a SIFMU whose failure or disruption could threaten the stability of the US financial system, everyone dependent on the US financial system is entitled to transparency. As the OCC is classified as a self-regulatory organization, tr OCC blaming U.S. regulators for not requiring SRO adopt regulations to protect itself makes it apparent that the public can not fully rely upon them.