Feb. 7, 2024
All, I am highly opposed to the "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 believe that no entity should be able to change the rules in their favor when they believe they are about to lose money. This proposed rule change sends a clear signal to all market participants that the game is rigged in favor of large Clearing Members. Shouldn't Clearing Members face the same market risks as other market participants? I hope that members at the SEC reject this proposal because it gives Clearing Members an unfair advantage in the marketplace and it eliminates any need for Clearing Members to properly manage their portfolio risk. The OCC needs to properly enforce margin requirements and not let Clearing Members off the hook by giving them unlimited access to credit. This will help protect the OCC and discourage Clearing Members from becoming Too Big To Fail. This will also help to rehabilitate the SEC's image which is in dire need too. Thank You, Joe