Feb. 7, 2024
? Dear Mr. Gary Gensler, We hope this letter finds you well. We want to express my gratitude 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 in Adjusting Certain Parameters and its Proprietary System for Calculating Margin Requirements During Periods When the Products it Clears and the Markets it Serves Experience High Volatility." After careful consideration, WE feel compelled to share several concerns regarding the OCC rule proposal. Simply put, WE ARE in strong opposition to this proposal and cannot support its approval. Our main concern stems from the lack of transparency evident within our financial system, particularly highlighted by this rule proposal. The excessive redaction of details within the proposal, combined with the absence of supporting information, severely hampers public review and renders meaningful commentary virtually impossible. Consequently, I firmly believe that this proposal should be rejected based on this fundamental lack of transparency alone. Furthermore, these rules introduce unfairness into the marketplace, especially for retail investors, who bear disproportionate long-tail risks. Meanwhile, the OCC repeatedly grants clearing members exemptions from margin calls by consistently reducing their margin requirements. Given these significant issues, I implore you to reject this rule proposal. Additionally, I advocate for the imposition of stringent margin requirements on clearing members, aligning them with the standards imposed on other investors. Thank you for considering my perspective on this matter. Sincerely, John Haye and everyone here at Haye Financial! Any questions Call 267-767-0105