May 17, 2024
Dear Members of the Securities and Exchange Commission, I want to express my personal vehement opposition to Rule SR-OCC-2024-001. This proposed rule change by the Options Clearing Corporation (OCC) is a direct insult to fair and orderly markets. Allowing the OCC to unilaterally reduce margin requirements for clearing members at risk of a default allows for bad actors to subvert the laws that protect our free market, and allows institutionalized fraud on a systemic scale. The lack of transparency alone, with vast swaths of critical information redacted, is already sufficient grounds for dismissing this proposal outright. Without full public disclosure, there can be no meaningful review or accountability, and this rule would only further public distrust in our financial system. In addition to rejecting Rule SR-OCC-2024-001, regulators must unequivocally: Mandate higher margin requirements truly commensurate to the risks clearing members incur. Subject the OCC to binding external audits and oversight as a true fourth line of defense. Instate a credible process for swiftly shuttering insolvent clearing members before toxicity spreads. Disperse systemic vulnerability across a decentralized market structure without single points of failure. In an ethical system, risky bets must be backed by commensurate capital - not coddled by backroom waivers that fleece the public. This proposal is a criminal abandonment of regulatory responsibility that deserves only unequivocal repudiation. The SEC must uphold its principles by rejecting it outright and charting a course toward truly accountable markets. I urge the Securities and Exchange Commission to carefully reconsider this proposal and reject proposed rule SR-OCC-2024-001. Sincerely, Jeff Cromer jcromerm2@gmail.com