Mar. 5, 2024
I do not support the approval of SR-OCC-2024-001 34-99393. The OCC's position appears to be that they should have the ability to reduce margin requirements for their clearing members during volatile markets. They also appear to have redacted the mechanism and parameters for which they are proposing they are granted the ability to modify via this rule change, which is disturbing to me given that this proposal has the potential to make an economic black swan event grow even larger. In other words, much like the 2007-2008 financial crisis, granting the OCC this extraordinary ability without so much as an opportunity to examine their redacted mechanics, could lead to the growth of a liability so large that it, once again, would be deemed "too big to fail" and seek bailout at my, the taxpayer's expense; thereby privatizing gains, and socializing losses. If I were to be trading options on margin with a brokerage and my trading went terribly south, I wouldn't have the privilege of requesting that they recalculate my margin requirements per my own redacted specifications in my favor and thus avoiding a margin call. So why should the OCC have that privilege for its clearing members? Please enforce margin requirements to curb irresponsible behavior by clearing members. Thank you.