The following Letter Type I, or variations thereof, was submitted by individuals or entities.

Letter Type I:

Subject: SR-OCC-2024-001

Dear SEC,

I am writing to express my deep concerns regarding the proposed rule change related to adjusting parameters for calculating margin requirements during periods of high market volatility. As a dedicated participant in the market, I believe it is crucial to provide constructive feedback on matters that could significantly impact market stability and the broader interests of all market participants, not just a select few.

1. Impact on Market Stability:The proposed rule change, specifically regarding margin adjustments during periods of heightened volatility, raises concerns about its potential impact on open, fair and transparent markets. While the intention may be to enhance risk management, there is a risk that abrupt changes in margin requirements during volatile periods could exacerbate market fluctuations, possibly leading to unintended consequences and systemic risks.

2. Strengthen Oversight Mechanisms: Actively involve regulatory bodies during heightened market volatility periods but realize margins are in place to protect market integrity. They’re not put in place to protect market participants. They should be utilized for the protection and stability of the market in it’s totality.

3. Inherent Conflict of Interest with FRM Officer's Role: Another critical aspect of the proposal that warrants attention is the potential conflict of interest associated with the role of the Financial Risk Management (FRM) Officer. It is essential to assess whether the proposed adjustments could inadvertently align with the personal or institutional interests of the FRM Officer, potentially compromising the objectivity of risk management decisions.

4. Regulators implying regulatory shortcomings: The proposal’s blame on US regulators implies regulatory shortcomings, yet the actual problem extends to market participants exploiting positions, such as engaging in excessive naked shorting, surpassing regulatory concerns.

In light of these concerns, I respectfully urge the SEC to reconsider the proposed rule change. Furthermore, I advocate for a more transparent and inclusive process that involves thorough consultations with market participants, ensuring a comprehensive understanding of the potential consequences and benefits of the proposed adjustments.

Given the gravity of these concerns, I am expressing my opposition to the proposed rule change. I believe it is crucial for the regulatory body to conduct a thorough and impartial review, emphasizing the need for transparency, effective risk mitigation, and the overarching well-being of the broader market, not just a select few participants.

I appreciate your attention to these concerns and trust that the SEC will carefully evaluate the potential implications of the proposed rule change on market participants and market stability.



Sincerely,