May 4, 2024
Dear SEC, I am writing as a retail investor to express my opposition to the proposed rule change, SR-OCC-2024-001, which aims to adjust margin requirements during high-volatility periods. I appreciate the opportunity to comment and wish to highlight significant concerns regarding this proposal: 1. Lack of Transparency: The proposal includes excessive redactions, making it impossible for the public to fully understand and meaningfully comment on the potential implications. 2. Inadequate Procyclicality Measures: The proposal fails to address the issue of procyclicality effectively. By potentially lowering margin requirements in times of market stress, the OCC risks destabilizing the financial system even further. This could lead to a domino effect of defaults among Clearing Members, which poses a grave threat to market stability. 3. Discretionary Control Settings: The frequent use of "idiosyncratic" and "global" control settings to reduce margin requirements could unfairly benefit Clearing Members at the expense of the overall market fairness and stability. Such practices could shield Clearing Members from the financial repercussions of high-risk trading strategies, placing undue strain on the broader financial system. In conclusion, the proposed rule change contradicts the SEC’s mission to maintain fair, orderly, and efficient markets. It jeopardizes investor protection by enabling practices that could lead to increased systemic risk and financial instability. Therefore, I strongly urge the SEC to reject this proposal and enforce strict and transparent margin requirements that ensure the stability and integrity of the financial market. Sincerely, A concerned retail investor