Feb. 7, 2024
SEC, Thank you for the chance to share my thoughts on the proposed change by The Options Clearing Corporation (OCC) regarding its process for adjusting margin requirements during times of high market volatility (proposed rule: SR-OCC-2024-001 34-99393). As a market participant. I strongly disagree with this proposal and do not support its approval for a few reasons. Firstly, there's a lack of transparency in the financial system, including this proposal which has a lot of redacted information, making it hard for the public to understand and comment on it. These rules seem unfair to market participants, especially small investors, who face more risks while the OCC often reduces margin requirements for larger players. I believe everyone should face the same rules. The OCC says this proposal is to prevent a domino effect of defaults if one big player fails, but it seems like it's letting these players take too many risks, knowing they won't face the consequences. I think they should deal with the risks they take, like everyone else. This proposal also creates a conflict of interest for the Financial Risk Management Officer, who is supposed to protect the OCC's interests but might end up protecting the risky players instead. If this proposal goes through, it reduces the protection the OCC has against market risks, which is not a good idea. We need stronger rules to protect against potential financial disasters. To address these issues, I suggest increasing and enforcing margin requirements based on the risks involved, rather than reducing them. This way, everyone would be encouraged to manage their risks better, and we wouldn't have to worry about big players taking too many risks and expecting bailouts. Thank you for your time and consideration. Sincerely, Bill Allen