Feb. 20, 2024
Dear SEC, I hope this letter finds you well. I am writing to express my concerns about the proposed rule change by the Options Clearing Corporation (OCC) regarding the adjustment of parameters for calculating margin requirements during periods of high market volatility. As a concerned stakeholder in the financial markets, I believe it is crucial to bring attention to several issues that, if left unaddressed, may have significant implications for market stability and transparency. Firstly, the proposed rule change raises apprehensions about its potential impact on market stability. While adapting margin requirements in response to market volatility is a prudent approach, the proposed adjustments may inadvertently exacerbate market stress. The lack of clarity on how the new parameters will be determined and implemented raises concerns about their effectiveness in mitigating risk and ensuring stability during turbulent market conditions. Furthermore, the redacted materials accompanying the proposal contribute to a lack of transparency, hindering stakeholders' ability to thoroughly evaluate the proposed changes. Transparency is fundamental to maintaining trust in financial markets, and the undisclosed details create uncertainty and limit our ability to assess the potential consequences of the proposed rule change. I strongly urge the [SEC/Relevant Regulatory Body] to consider the importance of transparency in regulatory matters and request the release of unredacted materials for comprehensive scrutiny. Additionally, my concerns extend to the perceived conflict of interest associated with the role of the Financial Risk Management (FRM) Officer. The efficacy of risk management relies on impartial decision-making, and any perception of conflicts of interest can undermine the integrity of the risk management process. It is imperative that the [SEC/Relevant Regulatory Body] thoroughly examines the potential conflicts and takes appropriate measures to ensure the independence and objectivity of the risk management function within the OCC. In light of these concerns, I respectfully request that the [SEC/Relevant Regulatory Body] thoroughly reconsider the proposed rule change by the OCC. Emphasizing the importance of transparency, risk mitigation, and the broader market's well-being, I advocate for a comprehensive review that includes stakeholder input and a thorough assessment of potential consequences. I appreciate your attention to this matter and trust that the [SEC/Relevant Regulatory Body] will prioritize the interests of market participants and the overall health of our financial markets. Thank you for your time and consideration. Sincerely, Chris Lane