May 17, 2024
Dear Members of the Securities and Exchange Commission, I am writing to express concerns about Rule SR-OCC-2024-001, proposing margin threshold adjustments during high volatility. This adjustment risks allowing clearing members to maintain insufficient collateral, raising default and market destabilization risks. It raises questions about market integrity and the OCC's risk management role. The rejection of this rule aligns with Exchange Act sections 17A(b)(3)(F), 17Ad-22(e)(2), and 17Ad-22(e)(6), crucial for market integrity and risk management. The OCC's role in market integrity is paramount, and margin calls are vital safeguards against excessive risk-taking. Allowing margin threshold adjustments during high volatility undermines this. The proposal lacks transparency and introduces arbitrariness, potentially favoring certain members and eroding market trust. Redacted evidence and unchecked authority for the FRM Officer raise further concerns. Rejecting Rule SR-OCC-2024-001 is necessary to protect market stability and investor interests. I urge the SEC to prioritize market integrity by rejecting this proposal. Transparency, clear guidelines, and checks on discretionary authority are crucial for financial market stability. Thank you for your attention. Sincerely, Andrea Phillips