May 10, 2024
Hello This is for SR-OCC-2024-001 No. 34-100009 but the submit a comment link doesnt seem to me on the webpage. Must be a glitch... Thank you for the opportunity to comment on SR-OCC-2024-001 No. 34-100009 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 have several concerns about the OCC rule proposal, I HIGHLY OPPOSE SR-OCC-2024-001 No. 34-100009 AND DO NOT SUPPORT IT'S APPROVAL. I am very concerned about the lack of transparency in our financial system as evidenced by this rule proposal, amongst others. The details of this proposal along with supporting information are significantly redacted which prevents public review making it impossible for the public to meaningfully review and comment on this proposal, and this proposal should be rejected on that basis alone. These rules create an unfair marketplace for market participants, especially retail investors, 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. Thanks Mike