I am writing to express my deep concerns regarding the proposed rule change by the Options Clearing Corporation (OCC) to adjust parameters for calculating margin requirements during periods of high market volatility. As a concerned market participant, I believe that this proposed change warrants thorough reconsideration due to its potential impact on market stability, lack of transparency, and inherent conflicts of interest. 1. **Market Stability**: The proposed adjustment to margin requirements could have far-reaching consequences for market stability. During volatile periods, accurate risk assessment is crucial to prevent systemic risks. Any miscalculation or inadequate margin coverage may exacerbate market turbulence, leading to unintended consequences for investors, financial institutions, and the broader economy. As responsible stewards of the financial system, we must prioritize stability over short-term gains. 2. **Transparency**: Transparency is the bedrock of investor confidence. Unfortunately, the redacted materials accompanying the proposed rule change lack the necessary clarity and detail. As stakeholders, we deserve full disclosure to understand the rationale behind these adjustments. Without transparency, market participants are left in the dark, unable to assess the potential impact on their portfolios. I urge the SEC to demand complete transparency from the OCC, ensuring that all relevant information is accessible to the public. 3. **Conflict of Interest**: The role of the Financial Risk Management (FRM) Officer is pivotal in maintaining the integrity of risk management processes. However, the proposed rule change raises concerns about inherent conflicts of interest. If the FRM Officer is influenced by commercial interests or pressured to favor certain market participants, it undermines the credibility of risk assessments. We must safeguard against such conflicts to maintain investor trust and uphold the principles of fair and unbiased risk management. 4. **Supporting Evidence**: I encourage the SEC to conduct an independent review of the proposed rule change. Consider seeking input from market experts, academics, and industry practitioners. Analyze historical data to assess the impact of similar adjustments in the past. Robust empirical evidence should guide decision-making, ensuring that any changes align with the best interests of all stakeholders. 5. **Advocacy for Reconsideration**: I respectfully request that the SEC thoroughly scrutinize the proposed rule change. Emphasize the importance of transparency, risk mitigation, and the broader market's well-being. Engage in a dialogue with market participants, solicit feedback, and consider alternative approaches that strike a balance between risk management and market efficiency. In conclusion, I believe that the proposed rule change requires a more comprehensive evaluation. As guardians of financial stability, we must prioritize transparency, fairness, and the long-term health of our markets. I trust that the SEC will act diligently to protect investors and uphold the integrity of our financial system. Thank you for your attention to this matter. I look forward to a thorough review and meaningful dialogue. Sincerely, Nitesh Alve