To: Securities and Exchange Commission Subject: Comment on SR-OCC-2024-1 Dear SEC, I am writing to express my strong opposition to the proposed rule change SR-OCC-2024-1 by the Options Clearing Corporation (OCC), which aims to adjust margin requirements during periods of high market volatility. Proper risk management should plan accordingly for volatility in the market, ensuring financial soundness and mitigating systemic risks without relying on relaxed regulations that could allow market participants to become further underwater. It is essential that clearing members maintain adequate capital to back their positions, especially during times of increased volatility. Allowing for lower margin requirements under such conditions undermines this principle and introduces unnecessary risks into the financial system. Firstly, lowering margin requirements during periods of high market volatility poses a substantial risk to market stability. Margin requirements are a critical tool in ensuring the financial soundness of market participants and mitigating systemic risks. By reducing these requirements during volatile times, the proposal could exacerbate market fluctuations and introduce additional uncertainty. Such a change could have far-reaching negative consequences, not only for individual investors but also for the broader financial system. Furthermore, the lack of transparency in the rule-making process is deeply concerning. The proposal includes redacted materials that prevent market participants from fully understanding the rationale and implications of the change. Transparency is a fundamental pillar of fair and efficient markets, and the absence of complete information undermines the integrity and accountability of the OCC's decision-making process. It is imperative that all relevant information be made available to the public to ensure informed decision-making and to uphold market integrity. Additionally, there is a significant conflict of interest associated with the Financial Risk Management (FRM) Officer's role under the proposed rule change. Granting the FRM Officer the authority to adjust margin calculation parameters creates a situation where the OCC's financial interests could unduly influence risk management decisions. This conflict undermines the credibility and effectiveness of the risk management framework and raises serious questions about the OCC's commitment to maintaining a fair and transparent market. In light of these concerns, I respectfully urge the SEC to reject the proposed rule change SR-OCC-2024-1. To ensure market stability, transparency, and robust risk management practices, I recommend the following actions: 1. Conduct a comprehensive review of the potential impact of the proposed rule change on market stability, involving feedback from market participants and independent analyses 2. Enhance transparency by providing full access to all relevant materials and redacted information. 3. Address the conflict of interest associated with the FRM Officer's role by establishing an independent oversight mechanism for margin calculation parameter adjustments. By taking these steps, the SEC can demonstrate its commitment to maintaining a fair, transparent, and stable market. It is crucial that regulatory bodies prioritize the well-being of the market and its participants to safeguard the broader financial system. Thank you for considering my concerns. I trust that the SEC will carefully evaluate the potential implications of the proposed rule change and act in the best interest of all market participants. Yours sincerely, Michael C