May 12, 2024
Dear Securities and Exchange Commission, I am writing to you today to provide my comment on: File number: SR-OCC-2024-001 Release number: 34-100009 I agree with the Commission's rejection of SR-OCC-2024-001, and I support your reasons for the dismissal, specifically in relation to: Section 17A(b)(3)(F) of the Exchange Act; Rule 17Ad-22(e)(2) of the Exchange Act; and Rule 17Ad-22(e)(6) of the Exchange Act As a retail investor from Australia, and a long term investor in American financial markets (equities, options and futures), I believe that the proposed changes in SR-OCC-2024-001 would greatly undermine the stability of the Amercian financial system. Reducing or waiving margin requirements for OCC participants during periods of high market volatility, exactly when they're needed most, could allow participant's mismanagement of risk and their "bad bets" to escalate to a level that endangers the stability of the wider financial system. Margin requirements are in place to keep OCC participants disciplined with regards to their level of risk. Reducing or waiving these margin requirements during periods of heightened volatility serves no purpose other than to transfer risk from OCC participants to the wider financial system. OCC participants that mismanage their risk and are unable to meet margin requirements must be promptly liquidated to safeguard the stability of the wider financial markets. Failure to do so will allow OCC participants to escalate their level of market risk to such an extent so as to become "to big to fail". The threat of liquidation is the only incentive that OCC participants have to keep their risk levels in check. Knowing that margin requirements can be reduced or waived when needed completely defeats their purpose, and will allow excessive risk to build up during the good times so as to virtually guarantee a financial system crisis in the bad times. Should SR-OCC-2024-001 be implemented, it would cause myself (and no doubt countless other retail investors given the number of comments that the Commission has received regarding this proposal) to reconsider my involvement in the American financial markets given the increased likelihood of a systemic event occurring during periods of heightened market volatility. It is for these reasons that I support the Commission's decision to dismiss SR-OCC-2024-001. Thank you for providing me with the opportunity to comment on this proposal, and for upholding the integrity of the financial markets. Sincerely, A Concerned Investor from Perth, Western Australia