May 8, 2024
To whom it may concern, I am writing today in support of the SEC's grounds for disapproval of the proposed OCC rule update (SR-OCC-2024-001 34-100009). The OCC's rule proposal would reduce market transparency and basic fairness by allowing the OCC to subjectively and dynamically adjust margin requirements for their clearing members merely to save themselves. The OCC rule proposal appears to be a request by the OCC to remove concrete, actionable rules in order to give themselves further unfair market advantages. Margin requirements (and margin calls) are an important market mechanism which, among other things, are supposed to act as a deterrent to reckless investing/trading/market making activities and if the OCC is permitted to all but suspend margin requirements and margin calls on a whim, then OCC clearing members will be further incentivized to make risky and potentially dangerous investments. The OCC's rule proposal can only serve to increase systemic risk within the US (and arguably global) financial markets and should not be approved by the SEC. Sincerely, Graham Ladner An informed retail investor.