Feb. 19, 2024
I trust this letter finds you well. I am writing to express my concerns regarding the proposed rule change by the Options Clearing Corporation (OCC) to adjust parameters for calculating margin requirements during periods of high market volatility. As a concerned stakeholder in the financial markets, I believe it is imperative to address certain apprehensions that may have far-reaching implications for market stability, transparency, and potential conflicts of interest. Firstly, the potential impact on market stability is of utmost concern. Adjusting margin requirements during periods of high volatility could introduce additional risks and volatility rather than mitigate them. Such changes have the potential to exacerbate market swings, impacting the broader financial ecosystem and potentially leading to unintended consequences. Secondly, there appears to be a lack of transparency in redacted materials associated with the proposed rule change. Transparency is fundamental to maintaining trust in the financial markets. Without access to complete information, stakeholders are hindered in their ability to assess the full impact and implications of the proposed changes. I urge the OCC to provide a comprehensive and unredacted disclosure of all relevant materials to ensure transparency and allow for informed decision-making. Furthermore, my concerns extend to the inherent conflict of interest associated with the role of the Financial Risk Management (FRM) Officer. Given their pivotal role in risk management, it is crucial to address any potential conflicts that may compromise the objectivity and effectiveness of risk management practices. A thorough examination of the FRM Officer's role and responsibilities is warranted to ensure the proposed rule change aligns with the best interests of the market. Considering these concerns, I respectfully request that the Securities and Exchange Commission (SEC) thoroughly reconsider the proposed rule change. Emphasizing the importance of transparency, risk mitigation, and the broader market's well-being, I advocate for a comprehensive review that includes input from various stakeholders to ensure a balanced and informed decision-making process. I appreciate your attention to these matters and trust that the SEC will prioritize the long-term stability and integrity of the financial markets in their evaluation of the proposed rule change. Thank you for your time and consideration. Sincerely, A concerned retail investor.