May 17, 2024
I would like to express my opposition to SR-OCC-2024-001, the “Proposed Rule Change by The Options Clearing Corporation Concerning Its Process for Adjusting Certain Parameters in Its Proprietary System for Calculating Margin Requirements During Periods When the Products It Clears and the Markets It Serves Experience High Volatility.” I am grateful for the opportunity to provide input on this matter, albeit within a shorter time-frame than might usually be expected; presumably due to the timing of its submission. Despite this, I have seen many open comments which eloquently state the technical issues with the proposal, and wish to add my weight behind these accordingly. My understanding is that all comments received regarding this matter are not publicly available at this time, and would hope for this to be rectified in the interests of transparency. The subject of transparency is also a glaring issue with the proposal, in that it has not only necessitated a truncated window of opportunity to invite comment; but the very details of the proposal are significantly redacted! Thankfully this is a moot point, in that the essence of the suggestion seems to boil down to weakening a rule at the very times when it is required. Can a safeguard which exists only when not needed be considered a safeguard at all? The specifics of the notion are irrelevant in that context. Furthermore, turning a safeguard into a semblance of same is an inherent risk in itself, and should urge greater oversight of those who would advocate such dubiety. Beyond the poor optics of this proposal, with the damage it risks causing to general confidence in the functioning and stability of the system as stands, I commend the SEC for their rejection of this proposed rule change, and join many others in approving and championing their decision regarding this matter. I support the reasons for the dismissal as outlined on pages 4-5 of the Federal Register. Thank you for your time. Yours sincerely, John Bolt Household Investor