Subject: SR-OCC-2024-001 Self-Regulatory Organizations; The Options Clearing Corporation; Notice of Filing of 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
From: Nick Ahlers
Affiliation:

Mar. 2, 2024

Dear Members of the Securities and Exchange Commission, I am writing to express serious concerns regarding SR-OCC-2024-001. The proposed rule change poses a significant threat to market stability and the integrity of the options market. By granting OCC unchecked discretion to modify margin requirements based on subjective assessments of market volatility, the proposed rule change creates a breeding ground for potential abuse and manipulation.
Allowing OCC to adjust margin parameters without clear guidelines or oversight opens the door to arbitrary and unfair practices that could harm market participants and investors. This lack of transparency and accountability undermines trust in the regulatory framework and erodes confidence in the financial markets.
Furthermore, the proposed rule change fails to adequately address the potential adverse impacts on market liquidity and efficiency. Arbitrary adjustments to margin requirements during periods of high volatility could exacerbate market turbulence, leading to increased trading costs and diminished market depth.
In light of these concerns, I strongly urge the Securities and Exchange Commission to reject SR-OCC-2024-001 and uphold stringent standards for risk management and market integrity. Failure to do so would expose investors and market participants to undue risks and jeopardize the stability of the financial system.
Thank you for your time.
Sincerely,
Nick Ahlers