Feb. 26, 2024
Dear Members of the Securities and Exchange Commission, I am writing to express grave concerns regarding Rule SR-OCC-2024-001, which proposes adjustments to margin thresholds, particularly during periods of increased volatility. The proposal's use of "idiosyncratic volatility control settings" lacks transparency and introduces significant risks. This opacity in both calculation and implementation could lead to arbitrary adjustments by the Options Clearing Corporation (OCC), potentially favoring certain market participants and undermining fairness. Moreover, the lack of disclosure regarding supporting evidence, especially concerning margin threshold calculations, is deeply troubling and undermines regulatory transparency and accountability. Stakeholders require detailed information to ensure fair treatment. Additionally, the proposal grants unchecked authority to the Financial Risk Management (FRM) Officer during high market stress, raising concerns about potential conflicts of interest. This requires careful review and amendment. I urge the Securities and Exchange Commission to thoroughly reconsider Rule SR-OCC-2024-001, emphasizing clear guidelines, transparent calculations, and checks on discretionary authority to uphold market integrity. Thank you for your attention to this critical matter. I trust the SEC will address these concerns appropriately. Kind regards, Vester van Heijningen