May 4, 2024
Dear Securities and Exchange Commission, I'm writing as a retail investor to express my views on the SR-OCC-2024-001 proposal by The Options Clearing Corporation (OCC). While I appreciate the opportunity to provide feedback, I must express my concerns regarding the proposed rule change. Firstly, the lack of transparency in the OCC's rule proposal is troubling. Significant redactions hinder public review and prevent meaningful commentary. Transparency is crucial for ensuring fair and efficient markets. Furthermore, the proposal shifts responsibility away from Clearing Members onto the OCC, potentially increasing financial risks for all market participants. By reducing margin requirements for at-risk Clearing Members, the OCC risks destabilizing the financial system. Additionally, the proposal raises conflicts of interest, particularly regarding the role of the Financial Risk Management Officer. Prioritizing the safety of Clearing Members over the clearing agency itself undermines market integrity. Moreover, the OCC's attempt to justify the proposal by citing systemic risk concerns is flawed. Instead of addressing root issues, the proposal perpetuates a "too big to fail" mentality and places undue burden on non-bank liquidity facilities. In summary, the proposed rule change fails to uphold key principles of governance, transparency, and risk management. It poses significant risks to market stability and investor protection. I urge the SEC to reject the proposal in its current form and prioritize the interests of all market participants. Thank you for considering my concerns. Sincerely, A Concerned Retail Investor