May 13, 2024
I appreciate the opportunity today to voice my consideration of SR-OCC-2024-001 Release No. 34-100009 in regards to Proposed Rule 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 Calculation 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 of this Proposed Rule. As I commented previously upon consideration of this rule change, there are many missing and redacted pages in the original proposal which prevents any kind of honest public discussion and should, with that fact alone, be grounds for disapproval until more transparency of these margin calculations is presented for public discussion. In addition, these rules appear to be a way to allow certain market participants and not others to mitigate risks imposed by poor investment decisions. A free-and-fair market operates when every participant has an equal playing field, and this proposal seems to be a way to tilt risk exposure by and for a small group of market participants. Why should most investors be subject to harsh margin requirements all hours of the day, every day, as is the reality, while a small group of investors get to operate outside the boundaries and change their calculations on a whim? That is not a fair market structure and will eventually become unstable and collapse. This can be avoided by disapproving and discarding Proposed Rule SR-OCC-2024-001 34-99393. If a firm cannot manage its portfolio's risk, it should face the consequences of the liquidation rules we already have in place. If that liquidation triggers bankruptcy, then the firm should not be operating in the first place. If persons involved in the risk management office of these firms deliberately engage in bad faith actions and non-compliance of the risk, then they should be removed and jailed. Again, I thank you for the time to present my views and consideration of proposed rule SR-OCC-2024-001 34-99393 and my SUPPORT for the SEC's grounds for disapproval via SR-OCC-2024-001 34-100009. Sincerely, Juan B. Business Owner