Mar. 4, 2024
Thank you for the opportunity to comment on 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 have several concerns about the OCC rule proposal, HIGHLY OPPOSE THIS PROPOSAL, 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 redacted which prevents public review making it impossible for the public to meaningfully review and comment on this proposal, and this proposal should be rejected on that basis alone. These rules create an unfair marketplace for market participants, especially retail investors, who areWith the first and foremost line of protection for the OCC being “1. The margin deposits of the suspended firm”, this rule proposal is blatantly illogical and nonsensical. If this rule proposal is approved, mitigating the procyclical margin requirements directly reduces the first line of protection for the OCC, margin collateral from at risk Clearing Member(s), so this rule proposal should be rejected, made fully available for public review, and approved only with significant amendments to address the issues raised herein. In light of the issues outlined above, please consider the following modifications: Increase and enforce margin requirements commensurate with risks associated with Clearing Member positions instead of reducing margin requirements. Clearing Members should be encouraged to position their portfolios to account for stressed market conditions and long-tail risks. This rule proposal currently encourages Clearing Members to become Too Big To Fail in order to pressure the OCC with excessive risk and leverage into implementing idiosyncratic controls more often to privatize profits and socialize losses. Sincerely, Matthew lee