Feb. 7, 2024
Thank you for the opportunity to comment on SR-OCC-2024-00134-99393 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. I have several concerns about the OCC rule proposal, HIGHLY OPPOSE THIS PROPOSAL, AND DO NOT SUPPORT ITS APPROVAL! 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 along with supporting information are significantly redacted which prevents public review making it impossible for the public to meaningfully review and comment on this proposal, and this proposal should be rejected on that basis alone. These rules create an unfair marketplace for market participants, especially retail investors, who are forced to face the consequences of long-tail risks while the OCC repeatedly waives margin calls for Clearing Members by repeatedly reducing their margin requirements. For this reason, this rule proposal should be rejected. The proposed changes could lead to an increase in market manipulation, as it would make it easier for large institutional investors to manipulate the market, potentially at the expense of retail investors. This would create an unfair playing field and put retail investors at a disadvantage. Additionally, the proposed changes could reduce transparency in the market, making it more difficult or retail investors to make informed decisions about their investments. This lack of transparency could also make it easier for large investors to take advantage of retail investors. The proposed changes could also result in increased costs for retail investors, as they may need to pay more for access to market data and other information that is currently available for free or at a lower cost. This would make it more difficult for retail investors to compete with larger institutional investors. Finally, the proposed changes could reduce competition in the market, as smaller market participants may be unable to compete with larger institutional investors. This could result in less choice and higher costs for retail investors. In conclusion, I believe that the proposed rule change could have a significant negative impact on retail traders and investors. We urge the SEC to carefully consider the potential consequences of the proposed changes and to take steps to ensure that the interests of all market participants are protected. Sincerely, Camellia Mastakoski