Mar. 2, 2024
To the SEC, I am writing to express my profound concerns regarding the proposed rule change by the Options Clearing Corporation (OCC) to adjust parameters for calculating margin requirements during periods of high market volatility. As a stakeholder deeply invested in maintaining market stability and transparency, I believe it is imperative to address the potential ramifications of such adjustments on the broader financial ecosystem. First and foremost, I am apprehensive about the impact that the proposed rule change may have on market stability. Margin requirements serve as a crucial safeguard against excessive risk-taking and market instability. By adjusting these parameters during periods of heightened volatility, we risk exacerbating market fluctuations and amplifying systemic risks. This could potentially undermine investor confidence and disrupt the orderly functioning of financial markets. Furthermore, the lack of transparency surrounding the redacted materials in the proposal raises significant concerns about the integrity and fairness of the decision-making process. Transparency is essential for fostering trust and accountability within the financial industry. Without access to complete information, stakeholders are unable to fully evaluate the potential risks and benefits associated with the proposed rule change. I urge [SEC/Relevant Regulatory Body] to prioritize transparency and ensure that all relevant materials are made available for public scrutiny. Additionally, I am troubled by the inherent conflict of interest associated with the role of the Financial Risk Management (FRM) Officer in this matter. As stewards of market integrity and investor protection, it is imperative that regulatory decisions be made impartially and free from conflicts of interest. The involvement of individuals with vested interests in the outcome of the rule change undermines the credibility of the decision-making process and raises questions about the integrity of the regulatory framework. In light of these concerns, I respectfully urge [SEC/Relevant Regulatory Body] to conduct a thorough reconsideration of the proposed rule change. It is essential to prioritize transparency, risk mitigation, and the broader market's well-being in any regulatory decision-making process. I strongly believe that a comprehensive review of the proposed rule, taking into account the concerns raised by stakeholders, is necessary to safeguard the integrity and stability of our financial markets. Thank you for considering my concerns. I am hopeful that [SEC/Relevant Regulatory Body] will take appropriate action to address these issues and uphold the highest standards of regulatory oversight. Sincerely, Samuel Doyle (UK investor in US markets)