Feb. 25, 2024
Thank you for the opportunity to comment regarding SR-OCC-2024-001 34-99393 entitled “proposed Rule Change by the Options Clearing Corporation Concerning its Process for Adjusting Certain Parameters in its Proprietary System for Calculating Margin Requirements During Periods When the Products It Clears and the Markets It Serves Experience High Volatility” I would argue that releasing margin requirements contribute to the very volatility this rule seeks to eliminate. There is no certainty of punishment for poor decisions made by options investors, and as such, the risk for those foolish and/or corrupt trades fall squarely on someone other than the persons responsible for making those decisions. There is no incentive whatsoever for ethical performance within that market environment if the risk of failure is removed. Enforcing margin requirements instills discipline in a market that clearly is not capable of self regulation. I have several concerns about the OCC rule proposal, and HIGHLY OPPOSE ANY PROPOSAL THAT GRANTS RELIEF TO COMPANIES AND INDIVIDUALS WHO HAVE MANIPULATED STOCK VALUES AND DO NOT SUPPORT IT’S APPROVAL! I’m concerned about the lack of transparency in our financial system as evidenced by this rule proposal, amongst others. The details of this proposal along with supporting information are significantly footnoted which prevents common language public interpretation, making it impossible for the public to meaningfully review and comment on this proposal, and this proposal should be rejected on that basis alone. Who is behind this proposal? Who benefits if the rule is changed? Who benefits when the SEC drags its heels on enforcing regulations already on the books? That’s where the focus should lie-enforce the rules we have on the books right now. Stop the naked shorting like other governments around the world have already done! Force these rogue corporations to allow markets to function properly and to allow pricing to be established not because shady deals are allowed to be made in dark pools, but based upon a publicly traded company’s performance. I am a retail AND institutional investor who is losing confidence in our financial markets, specifically because rules are not being enforced and certain companies are allowed to set security pricing by their corrupt short-selling practices. For these reasons, this proposed rule should be dispatched rapidly and all investors should be required to operate under the same rules. Those margin rules should be enforced and our banking and investment system should not be permitted to be hijacked by rouge players who wink at each other and turn a blind eye toward enforcing basic accounting practices. Smaller players in the market are not permitted to do what the largest players have been permitted to do, and what those largest players are doing put more stress on our financial system than anyone can imagine. Draw the line in the sand now before there is no salvaging our financial system, our economy, and dare say our society. Matthew D. Carlson Glen Ellyn, IL