May 16, 2024
Otters Cesium May 16, 2024 Securities and Exchange Commission Office of the Secretary 100 F Street, NE Washington, DC 20549 Subject: Comments on SR-OCC-2024-001 34-100009 Dear Commissioners, I am writing to express my strong support for the Securities and Exchange Commission's (SEC) decision to reject the proposed rule change under SR-OCC-2024-001 34-100009 by the Options Clearing Corporation (OCC). As an advocate for fairness and transparency in financial markets, I appreciate the SEC’s commitment to these principles, which are crucial for protecting all participants, including retail and institutional investors. The SEC’s scrutiny regarding the lack of transparency in the OCC's proposed changes is commendable. Transparent operations ensure that all market participants can make informed decisions, a fundamental aspect often overlooked in complex financial instruments. The proposed rule change fell short in providing clear, accessible information that would allow investors to understand the implications of modified margin requirements, particularly during periods of high market volatility. Furthermore, I support the SEC’s concerns over potential systemic risks posed by the OCC’s proposed adjustments to margin requirements. These adjustments could lead to significant liquidity demands on investors during market downturns, potentially exacerbating financial distress. As an athlete, I understand the importance of resilience and preparedness, qualities that our financial systems should embody to withstand market pressures and protect the interests of the community. Additionally, the conflict of interest inherent in the role of the Financial Risk Management (FRM) Officer, as outlined in the proposal, is troubling. The independence of oversight roles is critical to maintaining the integrity of governance structures within financial institutions. It is essential that such roles remain free from conflicts to enforce risk controls effectively and impartially. The SEC’s role in ensuring that financial market infrastructures operate in a safe, transparent, and fair manner is vital for maintaining investor confidence and market stability. Your decision to disapprove SR-OCC-2024-001 34-100009 reinforces the necessary rigidity and oversight required to manage systemic risks and protect investors from unforeseen financial burdens. Thank you for your diligent evaluation of these critical issues and for upholding the highest standards of regulatory oversight. Your decision contributes significantly to maintaining the integrity of our financial markets and protecting the rights and assets of investors. Respectfully, Otters Cesium