Subject: Comments on SR-OCC-2024-001 34-99393
From: M Devine
Affiliation:

Jan. 29, 2024

Thanks for letting me share my thoughts on the proposed rule change by The Options Clearing Corporation. I've got some concerns about it and wanted to make sure my voice is heard. 


First off, I'm not a fan of how this proposal lacks transparency. It's hard to give meaningful feedback when so much of the details are redacted. Without being able to see the full picture, it's tough for the public to weigh in properly. 


What worries me even more is how this proposal seems to shift responsibility onto U.S. regulators. It feels like the OCC is blaming them for not putting enough controls in place to deal with market volatility. But shouldn't the OCC be taking more accountability here? 


The way I see it, this proposal is all about protecting Clearing Members from facing the full consequences of their risky trades. By reducing margin requirements, it's like giving them a safety net while the rest of us are left to deal with the fallout. 


And let's talk about the conflict of interest with the Financial Risk Management Officer. Their job is supposed to be about protecting the OCC's interests, but it seems like they're just rubber-stamping margin reductions for Clearing Members, putting everyone else at risk. 


Instead of making it easier for Clearing Members to skate by, we should be holding them accountable for managing their risks properly. That means enforcing stricter margin requirements and making sure they're not taking on more than they can handle. 

Overall, we need more transparency, accountability, and fairness in our financial system. 


Thanks for listening. 



A Seriously Concerned Household Investor 




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