Feb. 4, 2024
Dear SEC-Team, I hope this letter finds you well. I am writing to express my deep concern as a German investor regarding the proposed rule change by the Options Clearing Corporation (OCC) to adjust parameters for calculating margin requirements during periods of high market volatility, as outlined in File No. [SR-OCC-2024-001]. I believe that the potential implications of these proposed changes merit careful consideration to safeguard the stability and integrity of the financial markets. Firstly, I would like to emphasize the critical importance of market stability. As a participant in global financial markets, I understand the significance of maintaining an equilibrium that fosters investor confidence and supports the overall health of the financial ecosystem. The proposed rule change, if implemented, has the potential to introduce heightened volatility and may disrupt the delicate balance that underpins market stability. Furthermore, my apprehension stems from the perceived lack of transparency surrounding redacted materials in the proposal. Transparency is paramount in ensuring the fairness and integrity of financial markets. The redactions within the proposal may hinder investors, such as myself, from fully comprehending the underlying methodologies and assumptions that inform the proposed rule changes. I respectfully urge the [SEC/Relevant Regulatory Body] to request a more comprehensive disclosure of information to facilitate an informed and thorough evaluation. Additionally, I would like to draw attention to the inherent conflict of interest associated with the role of the Financial Risk Management (FRM) Officer. Effective risk management is crucial for maintaining market stability, and any potential conflict of interest in this position may compromise the objectivity and fairness of risk assessment processes. It is imperative that the [SEC/Relevant Regulatory Body] thoroughly scrutinize this aspect of the proposal to ensure that risk management decisions are made in the best interest of the broader market. In advocating for a reconsideration of the proposed rule change, I urge the [SEC/Relevant Regulatory Body] to prioritize transparency, risk mitigation, and the overall well-being of the market. It is essential that any regulatory changes strike a delicate balance between accommodating market participants and safeguarding the interests of investors worldwide. I appreciate your attention to this matter and trust that the [SEC/Relevant Regulatory Body] will conduct a thorough review, taking into account the concerns raised by investors like myself. I believe that a robust regulatory framework is instrumental in preserving the stability and integrity of financial markets, and I trust that your esteemed organization will continue to act in the best interest of all stakeholders. Thank you for your time and consideration. Sincerely, Senad Serdarevic