May 17, 2024
Dear Commissioners, I am writing to express my strong support for the SEC’s decision to reject the Options Clearing Corporation’s (OCC) proposed rule change. This decision highlights the SEC’s commitment to maintaining a fair, transparent, and resilient financial market. The lack of transparency in the OCC’s proposal is a significant concern. Transparent processes are essential for investor confidence and market integrity. The proposed adjustments to margin requirements during market volatility lacked the necessary clarity, which could have led to unpredictable and destabilizing market conditions. Moreover, the potential systemic risks associated with the OCC’s proposal are alarming. Adjusting margin requirements without clear parameters during market volatility could exacerbate market stress, leading to sudden liquidity demands and increasing the likelihood of a systemic crisis. Another critical issue is the conflict of interest in the role of the Financial Risk Management (FRM) Officer. The proposed structure could compromise the objectivity and independence of the FRM Officer, undermining effective risk management. The SEC’s decision to disapprove the OCC’s proposal reflects a prudent approach to safeguarding market stability and investor interests. Upholding the principles of transparency, risk mitigation, and eliminating conflicts of interest is crucial for maintaining a robust financial market. In conclusion, I commend the SEC for its decisive action. This decision protects investors and fortifies the integrity of the financial system. Thank you for your attention to this important matter. Sincerely, Marcelo