Subject: Comments on SR-OCC-2024-001 34-100009
From: Randy Borden
Affiliation:

May 3, 2024

As a retail investor, I appreciate the additional consideration and opportunity extended by SR-OCC-2024-001 Release No 34-100009 to comment on SR-OCC-2024-001 34-99393 entitled “Proposed Rule Change by The Options Clearing Corporation Concerning Its Process for Adjusting Certain Parameters in Its Proprietary System for Calculating Margin Requirements During Periods When the Products It Clears and the Markets It Serves Experience High Volatility" I SUPPORT the SEC's grounds for disapproval under consideration as I have several concerns about the OCC rule proposal, do not support its approval, and appreciate the opportunity to contribute to the rulemaking process to ensure all investors are protected in a fair, orderly, and efficient market.
I’m concerned about the lack of transparency in our financial system as evidenced by this rule proposal, amongst others. The details of this proposal in Exhibit 5 along with supporting information (see, e.g., Exhibit 3) are significantly redacted which prevents public review making it impossible for the public to meaningfully review and comment on this proposal. Without opportunity for a full public review, this proposal should be rejected on that basis alone.