Feb. 7, 2024
Thank you for the opportunity to provide feedback on SR-OCC-2024-001 34-99393, titled "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 have several concerns regarding the OCC's rule proposal, and I strongly oppose it while advocating for improvements before its approval. My foremost concern pertains to the transparency of our financial system, which is essential for maintaining trust and integrity. However, the extensive redaction of details and supporting information in the proposal inhibits public scrutiny, hindering meaningful review and commentary. To address this, I recommend increasing transparency by providing more accessible and comprehensive information for public review. Furthermore, the proposed rules appear to create an unequal playing field for market participants, particularly disadvantaging retail investors. The repeated waivers of margin calls for Clearing Members through reductions in their margin requirements could lead to unfair advantages and increased risks for retail investors. Thus, I advocate for measures to ensure fairness and stability in the marketplace, such as implementing stricter oversight and accountability measures for Clearing Members. In conclusion, while recognizing the importance of adapting margin requirements during periods of high volatility, I believe that enhancements are necessary to address concerns regarding transparency and fairness. By working towards these improvements, we can strengthen trust in our financial system and promote a more equitable environment for all investors. Sincerely, A. Smith