Feb. 20, 2024
Dear Securities and Exchange Commission, I trust this message finds you well. In light of my involvement in the financial markets and my unwavering commitment to transparent, equitable, and resilient market practices, I am writing to express my resolute opposition to the proposed rule SR-OCC-2024-001. While I appreciate the intent behind the rule, aimed at formalizing OCC’s process for making adjustments during periods of heightened volatility, the conspicuous lack of transparency, particularly the redaction of specific details pertaining to the calculation of parameters and margin thresholds, gives rise to significant apprehensions. Transparency stands as a cornerstone for market participants to evaluate the equitability and efficacy of risk management measures. The consistent utilization of idiosyncratic control settings, the concentration of substantial decision-making authority within the purview of a singular FRM Officer, and the potential systemic risks associated with recurrent adjustments during periods of heightened volatility are distressing. The current iteration of the proposed rule poses a palpable threat through its potential to diminish margin call requirements by endowing the OCC with extensive authority to adjust margin thresholds based on undisclosed parameters during pivotal events. Moreover, the absence of actively soliciting comments for public input casts doubt on the transparency and impartiality of the rule-making process. Within the regulatory sphere, active engagement with stakeholders plays a pivotal role in ensuring comprehensive rules that address potential concerns from diverse parties. I implore you to consider the recommended enhancements, inclusive of fortifying and enforcing margin requirements, instituting external auditing and oversight, integrating public input, and augmenting transparency prerequisites. These measures are indispensable for nurturing trust among market participants and upholding the stability and integrity of our financial markets. In conclusion, I staunchly oppose the adoption of proposed rule SR-OCC-2024-001 in its current manifestation and advocate for a thorough reassessment of its implications. Thank you for your attention to this crucial matter. Sincerely, Nicholas J Mark Nick.j.mark@gmail.com