Subject: My SR-OCC-2024-001 rule comment
From: Mark Bezzina
Affiliation:

Feb. 20, 2024

? Good day, I am writing to add my voice to the thousands of retail investors that have already commented and give my opinion in regards to the OCC considering making adjustments to the parameters for calculating margin requirements during periods of high volatility.
My strong opinion is that no such relief should be granted to market participants who make informed, yet highly risky trades or, let’s call a spade a spade, bets.
I am no longer surprised when every governmental agency that is supported with tax payer dollars continues to make or adjust rules that favor the ultra rich and unscrupulous hedge funds instead of promoting market fairness and transparency. At this point, I have lost all faith in the US capitol markets. I only see a wealth extraction tool to be used by the connected few to siphon wealth out of the middle class and into the pockets of the ultra rich. For those of us who have invested in Gamestop, myself included, we have seen over the course of the past three years every dirty trick and manipulative tactic in the book thrown at this stock to suppress it’s price, deter new investors and prevent fair price discovery.
When there are actors on the short side of the equation who are “too big to fail”, this illustrates a clear flaw in the way in which our markets function and they should be left to fail. The average American is quite resilient and used to subsisting at or below the poverty line. If such actors are that entrenched in our economic system, then our elected representatives and the SEC have NOT been doing their job in protecting us from the consequences of such failure. Like a cancer, they must be excised. It will be painful, but the nation as a whole will be better for it.
Retail investors have by necessity played by every rule that exists. We have done nothing illegal or unfair and only hope that the system works as equally for us as it does for Ken Griffin and Steve Cohen. Doubly so since the average retail investor simply buys and holds a stock they believe in and has none of the advantages hedge funds do, such as high frequency trading, quants, or a market maker side of the business that they definitely, 100%, most surely don’t share information with.
However much they claim the contrary, it has become abundantly clear that no one in our elected government or regulatory agencies cares about the other 99% of people who fund said government. Everyone is the hero of their own story. I’m sure that most people at the SEC think that they are good people. Many good rank and file people in our governmental agencies are being manipulated into keeping their jobs for fear of termination or future career prospects if they call out the bad actors. Given the revolving door from employment at the SEC directly over to the firms they oversee, the incentive is disgustingly apparent.
We can not and should not continue to amend rules that serve the wealthy few. Rules are rules, not suggestions. If Melvin Capital or Citadel has overextended themselves gambling on shorting a retail video game company, they deserve every consequence of losing that bet. They knew the risks and they made the play, even if we assume there were no nefarious intentions such as “cellar boxing” the company via aggressive naked shorting. They should not be allowed to draw cards from the deck until they turn the ace of spades they need to complete a royal flush and have it be accepted by our regulatory agencies as a legitimate draw to win their hand in this grand casino called the US stock market.
If you amend these rules to adjust margin requirements, I can guarantee you that many will lose faith in the US stock market and withdraw. Many already have. What will the government do when the world decides that investing in our markets is not trustworthy and that the privileged few have their thumb on the scale?
As a retail investor who simply wants the system to function equally for all parties including my future generations, I am asking you to take a principled stand and reject these new rules. You owe it to those who legitimately pay their fair share of taxes for a government that is supposed to serve them. Cut out the rot in our system.
Do Better. We’re screaming at you.
Mark Bezzina