Subject: Request: Concerns about SR-OCC-2024-001
From: Anonymous
Affiliation:

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