Feb. 8, 2024
Thank you for allowing me to share my thoughts on the proposed rule change by The Options Clearing Corporation (SR-OCC-2024-001 34-99393). As a retail investor, I have serious reservations about this proposal and cannot support its approval. My main concern lies with the proposal's lack of transparency. Significant portions of the proposal, specifically in Exhibit 5 and related documents like Exhibit 3, are heavily redacted, making it impossible for the public to fully understand and critique the proposed changes. Without complete access to these details, I believe the proposal should not proceed. Furthermore, the proposal's approach to adjusting margin requirements during volatile market periods raises questions about the overall stability and fairness of the financial system. It seems designed to protect Clearing Members at the expense of increasing risks for the OCC and, by extension, the broader market. This could lead to scenarios where systemic risks are amplified due to insufficient capitalization or over-leverage by Clearing Members. The proposal also frequently employs "idiosyncratic" and "global" control settings to manage margin requirements, a practice that seems overly frequent and potentially risky. This strategy, aimed at preventing systemic crises by reducing margin calls for Clearing Members, could unfairly disadvantage other market participants, including retail investors like myself. Given these concerns, I urge the rejection of this proposal. Instead, the OCC should enforce stricter margin requirements and adopt more transparent practices to ensure a fair, resilient market for all participants. Sincerely, A Concerned Retail Investor Sent with Proton Mail secure email.