Mar. 5, 2024
Dear Members of the Securities and Exchange Commission, I am writing to express my concerns regarding the proposed rule change by the Options Clearing Corporation (OCC) pertaining to the adjustment of parameters for calculating margin requirements during periods of high market volatility. As a participant in the financial markets, I believe it is crucial to address potential implications that this rule change may have on market stability and transparency. Firstly, I am apprehensive about the potential impact of these adjustments on market stability. While I acknowledge the necessity of adapting margin requirements to accommodate market fluctuations, altering these parameters during periods of high volatility could inadvertently exacerbate market instability. The proposed rule change may introduce uncertainty and volatility into the market, potentially leading to unintended consequences for market participants and overall market functioning. Furthermore, I am concerned about the lack of transparency surrounding certain redacted materials related to the proposed rule change. Transparency is essential for maintaining trust and confidence in the regulatory process. Redacting crucial information may hinder stakeholders' ability to fully evaluate the proposed rule change and its potential implications. Therefore, I urge the OCC to provide greater transparency and disclose relevant information to ensure a comprehensive understanding of the proposed rule's impact. Additionally, I would like to address the inherent conflict of interest associated with the role of the Financial Risk Management (FRM) Officer in this matter. The FRM Officer plays a critical role in assessing and managing financial risks within the OCC. However, the potential conflict of interest arises from the fact that the FRM Officer may have vested interests in implementing rule changes that prioritize risk management objectives over broader market considerations. Therefore, it is imperative to ensure that regulatory decisions are made impartially and in the best interest of the broader market. In light of these concerns, I respectfully urge the SEC to thoroughly reconsider the proposed rule change by the OCC. It is essential to prioritize transparency, risk mitigation, and the broader market's well-being in regulatory decision-making processes. I believe that a comprehensive evaluation of the proposed rule's potential impact and broader market implications is necessary to safeguard the integrity and stability of the financial markets. Thank you for considering my concerns. I am hopeful that SEC will carefully review the issues raised and take appropriate action to address them. Sincerely, Japhy Blackwell Household Investor