Feb. 8, 2024
Thank you for the opportunity to comment on SEC Rule SR-OCC-2024-001 34-99393. I oppose this rule's approval due to the lack of stability that this rule will create in the market. My understanding of this rule is that it will grant the OCC the ability to allow Clearing Members to lower their margin requirements during periods of market volatility, such as instances of short squeezes. To me, this does not resolve the issue at hand with its Clearing Members current collateral and liquidity to meet margin requirements, and will create significant issues in our markets in the future if this rule is approved. The ability for Clearing Members to lower their margin requirements at any time of extreme volatility in the market will ultimately impact the retail investors and create further market instability. For this reason, I do not support this rule and strongly advise the SEC to not approve it. Instead, we should strictly define margin requirements for the Clearing Members and not grant them the ability to lower margin requirements that are solely in their best interests, and not for all of the market's participants. Thank you for your time! Best regards, Derek Fike