Mar. 5, 2024
Dear SEC, I am writing to express my 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. My primary apprehension lies in the potential impact this rule change could have on market stability. Margin requirements serve as a critical safeguard against excessive risk-taking, particularly during turbulent market conditions. Any adjustment to these parameters must be carefully considered to avoid unintended consequences that may further destabilize the market. The lack of transparency surrounding certain redacted materials related to the proposed rule change are unnerving. Transparency is essential in fostering trust and confidence in regulatory processes. Redacted materials hinder stakeholders' ability to fully understand the rationale behind proposed changes and evaluate their potential implications effectively. Additionally, the inherent conflict of interest associated with the Financial Risk Management (FRM) Officer's role raises significant concerns. While the FRM Officer is tasked with managing risk, their dual role within the OCC creates a potential conflict of interest. It is imperative that regulatory decisions are made impartially and with the sole objective of safeguarding the broader market's well-being. In light of these concerns, I respectfully urge the SEC to conduct a thorough reconsideration of the proposed rule change. Emphasizing the importance of transparency, risk mitigation, and the broader market's well-being, I advocate for a comprehensive evaluation that prioritizes the interests of all market participants. Thank you for considering my concerns. I am committed to contributing to constructive dialogue and efforts aimed at ensuring the integrity and stability of our financial markets. Sincerely, -Nathan Novak