Feb. 5, 2024
Dear Commissioners, As a professional with extensive experience on Wall Street, I am writing to express my personal and professional opposition to the proposed rule change by the Options Clearing Corporation (OCC) regarding the adjustment of parameters for calculating margin requirements during periods of high market volatility. I believe this rule to be fundamentally flawed and potentially abusive, as it could disproportionately impact smaller market participants and exacerbate market volatility rather than mitigate it. Furthermore, the lack of transparency and potential conflict of interest inherent in the role of the Financial Risk Management (FRM) Officer raises serious concerns about the integrity of the process and the potential for decisions to be made that favor the interests of a few at the expense of the broader market ecosystem. Given my background and understanding of market dynamics, I strongly urge the SEC to reconsider the proposed rule. It is crucial that we prioritize the stability, transparency, and fairness of our financial markets to protect all participants and maintain confidence in our financial system. I appreciate your attention to this matter and hope that my perspective, informed by years of experience on Wall Street, will contribute to a more thoughtful and equitable consideration of the proposed rule change. Sincerely, Luke Petersen