May 17, 2024
Dear Members of the Securities and Exchange Commission, I am writing to express my concerns about Rule SR-OCC-2024-001, which proposes changing margin thresholds during high volatility. This proposal is troubling because it allows clearing members to hold less collateral when volatility is high, increasing the risk of defaults and destabilizing the financial system. Margin calls are meant to ensure members have enough collateral to cover potential losses. Adjusting these thresholds could encourage risky behavior and undermine market stability. The process lacks transparency and gives too much unchecked authority to the Financial Risk Management Officer, raising concerns about fairness and potential conflicts of interest. In conclusion, Rule SR-OCC-2024-001 poses significant risks to the financial system. I urge the SEC to reject this proposal to protect investors and maintain market stability. Thank you for your attention to this matter. Sincerely, Matthew Riddell-Ide