May 7, 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, I do not support its approval, and I 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 are significantly redacted which prevents public review making it impossible for the public to meaningfully review and comment. Without opportunity for a full public review, this proposal should be rejected on that basis alone. This particular OCC rule proposal appears designed to protect Clearing Members from realizing the risk of potentially costly trades by rubber stamping reductions in margin requirements as required by Clearing Members; which would increase risks to the OCC and the stability of our financial system. Fundamentally, rules such as these create an unfair marketplace for other market participants, including retail investors like myself, who are forced to face the consequences of long-tail risks while the OCC repeatedly waives margin calls for Clearing Members by repeatedly reducing their margin requirements. For this reason, this rule proposal should be rejected and Clearing Members should be subject to strictly defined margin requirements as other investors are. SEC approval of this proposed rule would perpetuate “rules for thee, but not for me” in our financial system against the SEC’s mission of maintaining fair markets. Thank you for the opportunity to comment for the protection of all investors as all investors benefit from a fair, transparent, and resilient market.