February 28, 2022
This proposal doesnt consider the interests of clearing members customers. Continuing to accept proposals like the Options Clearing Corporation is putting forward here enables the Options Clearing Corporation to increase systematic risk for the sole benefit of their biggest shareholders.
The rationale for removing two meetings, increasing Options Clearing Corporation executives control with the reduction of Board control, and increasing roadblocks in several ways for potential new Board members is specious. Much of these proposals concentrate power and risk while reducing checks and balances.
If the Board suddenly feels, disadvantages, including mandating numerous matters be brought to the full Board for approval that otherwise would not occupy the time and attention of the Board, then instead increase the public Board membership as the public Board members may make important actions like rule changes more of a priority for their time and attention.