May 16, 2024
Dear Ms. Countryman, I am writing to express my strong support for the SEC’s decision to reject rule proposal SR-OCC-2024-001. This proposal, which would have allowed the Options Clearing Corporation (OCC) to adjust margin requirements during periods of high volatility, posed significant risks to market fairness and investor protection. The proposed adjustments to margin thresholds during volatile market conditions would have disproportionately favored clearing members at the expense of retail investors and overall market stability. Such changes could have exacerbated financial instability by allowing significant margin increases that could force liquidations, thereby affecting non-defaulting members and the broader financial system. The rejection of this rule is crucial in maintaining the integrity and stability of our financial markets. It ensures that all market participants, including retail investors, are protected from the adverse effects of sudden and unreasonable margin calls that could arise from high volatility control settings. I commend the SEC for its diligent review and ultimate rejection of this proposal, and I urge the Commission to continue upholding measures that protect the interests of all investors and promote fair and transparent market practices. Thank you for considering my comments. Sincerely, Blake Losee