Subject: Comments on SR-OCC-2024-001 34-99393
From: Joel Wrapper
Affiliation:

Jan. 29, 2024

Thank you for the opportunity to comment on SR-OCC-2024-001 34-99393 entitled “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” as a retail investor. I have several concerns about the OCC rule proposal, do not support its approval, and appreciate the opportunity to comment. 

I’m concerned about the lack of transparency in our financial system as evidenced by this rule proposal, amongst others. The details of this proposal, along with supporting information are significantly redacted which prevents public review making it impossible for the public to meaningfully review and comment on this proposal. Without opportunity for a full public review, this proposal should be rejected on that basis alone. 

Why are we as public investors purposely kept out of the loop when changes like this are proposed? 

Clearing houses should not be taking on risk that they cannot afford to lose. 
If the OCC cannot regulate its own members, it should not be qualified as an SRO, the SEC needs to remove that designation, and actually regulate this organization; by not doing so, the SEC is effectively condoning these risks, which is contrary to the SEC's mission of a free and fair market, and clearly put the entire market at risk (otherwise, this proposal would not be necessary).
Thanks for listening,
A concerned investor.