Feb. 9, 2024
Dear sir, misses, As a retail investor I strongly oppose to the proposed rule change by the OCC concerning its process for adjusting margin requirements calculations during high volatility. (SR-OCC-2024-001 34-99393) This change does not help in any risk controle, it just temporarily contains it and adds to the risk in the long run. It will create a greater systemic risk in the future because it encourages bad behaviour among Clearing Members. The OCC already let Clearing Members off the hook in early 2021 for around 20 Billion and if these members now know that proposed new criteria will be met in the future, they will take even riskier bets! Instead of this rule, update margin requirments to a higher level. Bc in your own documents you state that there will be an expected 99 % shortfall. So to let that shortfall amount drop much lower ,the margin requirements should be MORE collateral instead of letting them off the hook with this proposal. If a Clearing Member is margin called they should not be facilitated so they get away with it bc they chose to not having a proper risk management. Their failure is a natural consequence of not managing their portfolio correctly and it will help to reduce excessive leverage in the future by other Clearing Members. This market should be a fair one for all participants and the SEC should make sure that rules are followed and not adjusted to serve some of the Clearing Members. Kind regards Kirscha Kievits