Subject: File No. SR-OCC-2024-001
From: Jonas Klokke

To Whom It May Concern, I am writing to express my strong opposition to the proposed changes by the Options Clearing Corporation (OCC) concerning the revamping of idiosyncratic margin requirements and volatility controls (File No. SR-OCC-2024-001). As a retail investor, I believe these changes pose significant risks to the market and are disadvantageous to household investors like myself. Potential for Market Instability: The proposal seems to allow for the protection of positions that have made poor investment decisions. By not enforcing margin calls effectively, it could lead to the growth of these unstable positions, thus creating a larger systemic risk. Conflict of Interest: The proposed changes appear to grant excessive discretion to the Financial Risk Management (FRM) Officer, who may prioritize OCC's interests over broader market stability. This conflict could lead to decisions that may not adequately address the risks these bad bets represent. Lack of Transparency: A significant concern is the redaction of key materials related to this proposal. Without access to these materials, it is challenging for the public to assess the effectiveness and implications of these changes accurately. Amplifying Procyclical Behavior: The new rules may exacerbate procyclical tendencies in the market. During periods of high volatility, the adjusted margin requirements might not reflect the actual risk, potentially destabilizing the financial system rather than safeguarding it. These changes, in my view, are not in the best interest of the market and particularly disadvantageous to household investors. They could lead to increased market instability and obscure the true risks involved in trading, which goes against the principles of a fair and transparent market system. I urge the SEC to reconsider the approval of these changes, keeping in mind the potential adverse effects on market stability and the interests of household investors like myself. Sincerely, Jonas