Mar. 5, 2024
Dear SEC Commissioners, I am writing to express my strong opposition to the proposed rule change (SR-OCC-2024-001) filed by the Options Clearing Corporation (OCC) that seeks to adjust the parameters for calculating margin requirements during periods of high market volatility. I believe this proposal, as currently formulated, raises significant concerns regarding market stability, transparency, and potential conflicts of interest. Market Stability Concerns: The proposed rule's potential to inadvertently shield risky positions from necessary margin calls during volatile periods is concerning. This could lead to unchecked growth in such positions, potentially amplifying losses and jeopardizing long-term market stability. Transparency Concerns: The significant redactions within the proposal, particularly in Exhibits 3 and 5, hinder a comprehensive public review and informed discussion. This lack of transparency is problematic and raises concerns about the potential for unintended consequences. Conflict of Interest Concerns: The proposal assigns a central role to the OCC's Financial Risk Management (FRM) Officer in determining margin adjustments. This raises concerns about a potential conflict of interest, as the FRM Officer's primary duty is to safeguard OCC's interests, which may not always align with the broader market's well-being. Therefore, I urge the SEC to thoroughly reconsider the proposed rule change Sincerely: Abdul Saboor Sent from my iPhone