May 17, 2024
Dear Sir/ Ma’am- BLUF- I'm opposed to the proposed rule change SR-OCC-2024-001 by The Options Clearing Corporation due to concerns over transparency, systemic risk, conflicts of interest, moral hazard, and inadequate risk management. Discussion: - Opaque Practices: The proposal's significant redactions limit public scrutiny and feedback. - Financial Instability: Lowering margin requirements for Clearing Members could destabilize the financial system. - Dual Allegiances: The Financial Risk Management Officer's role presents a conflict of interest. - Risk Shifting: The proposal moves the cost of defaults to a non-bank liquidity facility, creating an unfair market. - Risk Management Deficiencies: The OCC's preference for reduced margin requirements does not sufficiently mitigate liquidity risks. Request: The SEC's should reject this rule change to protect investors and the integrity of our financial markets, citing: - Failure to ensure efficient securities transaction clearance and fund security. - Unclear governance responsibility lines. - Inadequate credit exposure management and insufficient margin for potential future exposures. Thank you for considering my stance on this critical issue. Sincerely, A Concerned Citizen