May 14, 2024
Dear SEC, I'm writing to express my approval of the dismissal of SR-OCC-2024-001 34-100009. This proposal would give the Options Clearing Corp. (OCC) the authority to adjust the parameters used to calculate margin requirements during periods of high volatility. This proposal's dismissal must be enforced, as the proposal would decrease the integrity of the market. The passing of this proposal would theoretically give the OCC the ability to decide when they should margin call their members whenever they like. If a greedy firm gets caught on the wrong side of a bet and can't afford the collateral to sustain their bet, they should get margin called and default. Giving the clearing house the ability to tweak the criteria and decide not to margin call the member would increase risky behaviors in the industry, putting the entire market at risk. Giving a financial risk management (FRM) at the clearing house the ability to reduce the margin requirements for an at-risk clearing member gives a single person too much power and creates a conflict of interest. In short, SR-OCC-2024-001 34-100009 should be thrown out as it would decrease the integrity of the financial markets. Thank you, Logan Huacuja