May 11, 2024
Sir/Ma’am, I am writing to leave brief comments in objection to adoption of SR-OCC-2024-001. As per the SEC’s own published grounds for disapproval, the changes are inconsistent with Section 17A of the Exchange Act, notably Section 17A(b)(3)(F), Rule 17Ad-22(e)(2), and Rule 17Ad-22(e)(6). In short, these inconsistencies result in a marked lack of accountability both within & amongst participants, a failure to properly predict & account for all manner of risk, and a failure to provide & conduct effective, efficient, and transparent market operations. If allowed to metastasize unchecked, these vulnerabilities are certain to promote an environment that condones or even incentivizes irresponsibly risky practices that at best materially harm outside entities such as retail investors, and at worst constitute serious systemic risk on a national and likely global level. I thus object to approval of SR-OCC-2024-001 on the grounds that it violates the letter of the Exchange Act, but more importantly that it inevitably sabotages the people & the markets that the Exchange Act, and the SEC itself, were created & entrusted to protect. Thank you for your time & consideration, both are very much appreciated. Very respectfully, Mike McCarthy