Mar. 4, 2024
I trust this letter finds you well. I am writing to express my 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 household investor, I am deeply invested in the stability and integrity of the financial markets, and I believe that the proposed rule change poses potential risks to both. Firstly, I am apprehensive about the potential impact on market stability that may result from the proposed adjustments to margin requirements during periods of heightened volatility. While I acknowledge the importance of adapting risk management strategies to changing market conditions, I am concerned that the proposed changes may inadvertently exacerbate market instability by introducing uncertainty and potentially triggering abrupt responses from market participants. Secondly, the lack of transparency in certain redacted materials associated with the proposed rule change is disconcerting. Transparency is a cornerstone of a well-functioning financial system, and it is crucial for market participants to have access to complete information to make informed decisions. The redacted materials raise questions about the full scope of the proposed changes and limit stakeholders' ability to thoroughly assess the potential implications. Furthermore, I wish to draw attention to the inherent conflict of interest associated with the role of the Financial Risk Management (FRM) Officer in this matter. The FRM Officer, being an integral part of the OCC, may face conflicting pressures to prioritize organizational objectives over the broader market's well-being. This potential conflict of interest raises concerns about the objectivity and independence of the decision-making process surrounding the proposed rule change. In advocating for a thorough reconsideration of the proposed rule change, I strongly emphasize the importance of transparency, robust risk mitigation, and the overall well-being of the broader market. I urge SEC to carefully evaluate the potential consequences of the proposed adjustments, ensuring that any changes made prioritize the long-term stability and integrity of the financial markets. I appreciate the efforts of SEC in safeguarding the interests of market participants, and I trust that your thorough examination of these concerns will contribute to the development of sound regulatory policies. Thank you for your attention to this matter, and I am available for further discussion should you require additional information or clarification. Respectfully, Mike Miller