Feb. 8, 2024
Thank you for the chance to share my thoughts on SR-OCC-2024-001 34-99393 titled "Proposed Rule Change by The Options Clearing Corporation Regarding Its Procedure for Modifying Specific Parameters in Its Internal System for Calculating Margin Requirements During Periods of High Volatility in Cleared Products and Markets.” I express strong opposition to the OCC's proposed rule, firmly disapproving of its approval. My primary concern lies in the lack of transparency within our financial system, exemplified by this rule proposal among others. The extensive redaction of details and supporting information in this proposal hinders public review, preventing meaningful commentary. Based on this alone, the proposal should be declined. These regulations establish an inequitable marketplace, particularly burdening retail investors who endure long-tail risks while the OCC consistently reduces margin requirements for Clearing Members, granting repeated waivers for margin calls. Consequently, I advocate for the rejection of this rule proposal, urging the imposition of well-defined margin requirements for Clearing Members akin to those applicable to other investors. Best regards, Todd Roderick A Retail Investor with Concerns