May 4, 2024
This proposed rule change (SR-OCC-2024-001) by the Options Clearing Corporation (OCC) is a threat to fair and orderly markets that must be rejected. Allowing the OCC to reduce margin requirements for clearing members at risk of default would introduce elevetated systemic risk be antithetical to the very purpose of the clearing system. The OCC is pushing for weaking it's own risk models and the ability to waive margin calls for undercapitalized clearing members. This is an obvious and serious risk to the financial markets. The lack of transparency this proposal aims to create is also alarming and would only benefit large institutional market participants while disadvantaged household investors further. I call for rejecting this proposal and mandating higher margin requirements in order to lessen the risks clearing members pose to the financial market. Instate a process for swiftly margin calling insolvent clearing members without exceptions before risk spreads. Financial risk must be backed by commensurate capital and not on the backs of the taxpayers amd investirs who ultimately end up bearing the cost of systemic risk that wasn't immediately acted upon without exceptions or waivers. Insolvent market participants are to be acted upon immediately without exception to prevent the risk of one market participant rapidly becoming a severe risk to the entire market structure. Sincerely, -Jyri Hukkataival