Subject: Comments on SR-OCC-2024-001 34-99393
From: Lars Wohlfahrt
Affiliation:

Feb. 12, 2024

Dear Sir/Madam,

I'm writing to express my profound concerns regarding the proposed rule
change by the Options Clearing Corporation (OCC) pertaining to the
adjustment of parameters for calculating margin requirements during
periods of heightened market volatility. As a stakeholder deeply
invested in the stability and integrity of financial markets, I feel
compelled to address several critical issues that warrant thorough
reconsideration.

I am troubled by the redaction of specific details, which impedes market
participants from assessing the fairness and effectiveness of OCC
measures. This lack of transparency in risk management processes raises
significant doubts regarding the integrity and reliability of regulatory
decisions.

The proposal's general guidelines for idiosyncratic control settings'
duration introduce uncertainty and discretionary power, further eroding
confidence in the predictability and stability of OCC risk management
practices. Moreover, the reliance on idiosyncratic control settings,
particularly during periods of high volatility, poses systemic risks to
the financial ecosystem. Frequent waivers of margin calls may indicate a
lack of robustness in risk management practices, jeopardizing market
stability and investor confidence.

The proposal's categorization of Clearing Members as "Too Big To Fail"
exacerbates worries regarding the stability of the financial system. By
favoring the safeguarding of Clearing Members over the mitigation of
systemic risks, the proposal fosters moral hazard and weakens market
discipline. If approved, the rule change exposes the OCC to significant
financial risks by potentially depleting pre-funded resources in the
event of a large Clearing Member default. This not only undermines the
first line of protection outlined in OCC's default rules but also raises
questions about the sustainability of OCC's risk management approach and
its ability to withstand systemic shocks.

In light of these concerns, I urge you to undertake a thorough
reconsideration of the proposed rule change. It is imperative that
regulatory decisions are guided by principles of transparency,
accountability, and risk mitigation to uphold the stability and
resilience of financial markets.

Sincerely,

Lars Wohlfahrt