Feb. 28, 2024
Dear Members of the Securities and Exchange Commission, I am writing to express my concerns regarding Rule SR-OCC-2024-001, which proposes adjustments to margin thresholds, specifically during periods of high volatility. The OCC should not have the ability to arbitrarily decide when to apply margin thresholds and when not to as they distort the economic principles of supply and demand that the stock market is supposed to be based. The lack of clear guidelines on how margin requirements are determined and applied allows the Options Clearing Corporation (OCC) to potentially alter the margin criteria whenever a potential clearing member require assistance. We saw this in January of 2021 during the Game stop and AMC price surges. To date no one has been brought to justice in regards to the blatant fraud that occurred against retail investors. To further allow a non-governmental agency without direct federal oversight the ability to apply ad hoc margin requirements sets a dangerous precedence for continued fraud. The lack of transparency in our markets already undermines the integrity of financial markets. When the next market downturn inevitably occurs, the SEC can not claim to have no knowledge of the ramifications that passing rules such as SR-OCC-2024-001 will have. Financial markets must be dictated by the laws of supply and demand. The SEC serves as the safeguard to ensure a fair and equitable market. Passing this resolution will further prevent fair market functioning. As an investor and a representative of millions of individuals who have retirements dependent on the fair functioning of the market. I demand more clarity on what constitutes margin requirements and how those calculations are set. I refuse to allow private entities to determine these requirements solely under their discretion to participants of their choosing. I implore the SEC to step in and force transparency on these actors. I agree with other commenters that specifically, SR-OCC-2024-001 grants unchecked authority to the Financial Risk Management (FRM) Officer to make unilateral decisions during periods of high market stress. This authority, while ostensibly intended to protect the interests of the OCC, raises questions about potential conflicts of interest. The FRM Officer is entrusted with safeguarding both the OCC's interests and those of at-risk Clearing Members, creating a potential conflict that needs addressing and changing. I sincerely ask the SEC to demand clear guidelines on margin requirements, transparency in calculations, and checks and balances on requirement authority. Without these safeguards the system will collapse under market stress that in the past 20 years has been demonstrated to happen over and over again. Sincerely, Retail Investor