Subject: SR-OCC-2024-001 34-100009 comment
From: Andrew Affrunti
Affiliation:

May 17, 2024

Hello, 


I want to share my comments/concerns about SR-OCC-2024-001 Release No 34-100009 entitled “Proposed Rule Change by The Options Clearing Corporation Concerning Its Process for Adjusting Certain Parameters in Its Proprietary System for Calculating Margin Requirements During Periods When the Products It Clears and the Markets It Serves Experience High Volatility” 
I support the SEC's grounds for disapproval. To be clear, I do not support approving the new rule as it would allow the OCC to reduce margin call requirements by adjusting margin thresholds using [REDACTED] parameters during periods of high market volatility. There is a lack of transparency in the document for the proposed rule that I find concerning. 


As a retail investor, I see the lack of details in the proposed rule as a sign that the OCC will try to game the system. In other words, if the proposed rule wasn't nefarious they would not have to hide key details on how the OCC plans to use this new ruling to their advantage, and at the expense of retail investors. 


Thanks