Feb. 7, 2024
I am writing to express my deep concerns 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 a concerned participant in the financial markets, I believe it is imperative to address several key issues pertaining to this proposed amendment. First and foremost, I am apprehensive about the potential impact of these changes on market stability. Margin requirements play a crucial role in ensuring the integrity and resilience of our financial system, particularly during times of heightened volatility. Any adjustment to these parameters must be carefully scrutinized to mitigate the risk of exacerbating market instability and systemic risk. Furthermore, I am troubled by the lack of transparency surrounding certain redacted materials related to this proposed rule change. Transparency is fundamental to maintaining trust and confidence in our financial markets. Without access to comprehensive information, market participants are unable to make informed decisions and properly assess the implications of regulatory changes. Therefore, I urge the [SEC/Relevant Regulatory Body] to prioritize transparency and disclose all relevant materials pertaining to this rulemaking process. Additionally, I am concerned about the appalling nature in which margin waivers are handed out. There have been instances where margin waivers seem to be granted arbitrarily, without clear justification or adherence to established risk management protocols. This lack of consistency and accountability in the issuance of margin waivers undermines the integrity of the margin requirement framework and raises serious questions about the OCC's commitment to effective risk management practices. Furthermore, I am concerned about the potential conflict of interest associated with the role of the Financial Risk Management (FRM) Officer in this matter. The OCC's FRM Officer holds a significant responsibility in safeguarding the financial stability of the organization. However, the dual role of overseeing risk management while also advocating for regulatory changes poses inherent conflicts of interest. It is imperative that regulatory decisions be made independently and free from any undue influence to ensure the best interests of the broader market are upheld. In light of these concerns, I respectfully urge the [SEC/Relevant Regulatory Body] to conduct a thorough reconsideration of the proposed rule change. It is essential that any amendments to margin requirements be grounded in sound risk management principles, promote market transparency, and prioritize the stability of our financial system. I implore the [SEC/Relevant Regulatory Body] to engage in a comprehensive review process, soliciting feedback from a diverse range of stakeholders, to ensure that the interests of all market participants are adequately represented. Thank you for considering my concerns regarding this proposed rule change. I trust that the [SEC/Relevant Regulatory Body] will give due diligence to the issues raised and take appropriate action to safeguard the integrity of our financial markets. A concerned household investor, Andrew C. Rohrbaugh