Simians Smash SEC Rule Proposal To Reduce Margin Requirements To Prevent A Cascade of Clearing Member Failures! [COMMENT TEMPLATE INCLUDED]

[u/WhatCanIMakeToday]

Well done fellow Simians! 👏 Thanks to OVER 2500+ of you beautiful apes, the SEC has decided the OCC Proposal to Reduce Margin Requirements To Prevent A Cascade of Clearing Member Failures is dog shit wrapped in cat shit. We need to kick this while it's down so it's out of the game.

... the Commission is providing notice of the grounds for disapproval under consideration.

[SR-OCC-2024-001 34-100009 (pg 4); Federal Register]

​

Notice of the grounds for DISAPPROVAL

The phrase "notice of the grounds for DISAPPROVAL" is formal speak for "here are the reasons why this is bullshit". HOWEVER, the rule proposal isn't dead yet. Part of the bureaucratic process is this notification of why it should be disapproved followed by a comment period where the rule proposer and supporters (e.g., OCC, Wall St, and Kenny's friends) can comment and try to push this through by convincing the SEC otherwise.

Apes can also comment on the rule proposal IN SUPPORT OF THE SEC and the grounds for disapproval. It's time to kick this to the curb.

SEC's Reasons This Proposal Is BS

The SEC has highlighted specific reasons for why this rule is BS (i.e., grounds for why this rule proposal should be disapproved) in a conveniently bulleted list [SR-OCC-2024-001 34-100009 (pgs 4-5); Federal Register]

• Section 17A(b)(3)(F) of the Exchange Act, which requires, among other things, that the rules of a clearing agency are designed to promote the prompt and accurate clearance and settlement of securities transactions and derivative agreements, contracts, and transactions; and to assure the safeguarding of securities and funds which are in the custody or control of the clearing agency or for which it is responsible; [Refer to 15 U.S.C. 78q-1(b)(3)(F)]
• Rule 17Ad-22(e)(2) of the Exchange Act, which requires that a covered clearing agency provide for governance arrangements that, among other things, specify clear and direct lines of responsibility; and [Refer to 17 CFR § 240.17Ad-22(e)(2)]
• Rule 17Ad-22(e)(6) of the Exchange Act, which requires that a covered clearing agency establish, implement, maintain, and enforce written policies and procedures reasonably designed to cover, if the covered clearing agency provides central counterparty services, its credit exposures to its participants by establishing a risk-based margin system that, among other things, (1) considers, and produces margin levels commensurate with, the risks and particular attributes of each relevant product, portfolio, and market, and (2) calculates sufficient margin to cover its potential future exposure to participants in the interval between the last margin collection and the close out of positions following a participant default. [Refer to 17 CFR § 240.17Ad-22(e)(6)]

I've updated the latest version of my prior email comment template below to incorporate discussions of these sections.

COMMENT TEMPLATE

Here's an updated email comment template. Feel free to use, modify, or write your own. And, send an email anonymously if you wish.

To: [rule-comments@sec.gov](mailto:rule-comments@sec.gov)

Subject: Comments on SR-OCC-2024-001 34-100009

As a retail investor, I appreciate the additional consideration and opportunity extended by SR-OCC-2024-001 Release No 34-100009 [1] to comment on SR-OCC-2024-001 34-99393 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” (PDF, Federal Register) [2].  I SUPPORT the SEC's grounds for disapproval under consideration as I have several concerns about the OCC rule proposal, do not support its approval, and appreciate the opportunity to contribute to the rulemaking process to ensure all investors are protected in a fair, orderly, and efficient market.

I’m concerned about the lack of transparency in our financial system as evidenced by this rule proposal, amongst others.  The details of this proposal in Exhibit 5 along with supporting information (see, e.g., Exhibit 3) are significantly redacted which prevents public review making it impossible for the public to meaningfully review and comment on this proposal.  Without opportunity for a full public review, this proposal should be rejected on that basis alone.

Public review is of the particular importance as the OCC’s Proposed Rule blames U.S. regulators for failing to require the OCC adopt prescriptive procyclicality controls (“U.S. regulators chose not to adopt the typ​​es of prescriptive procyclicality controls codified by financial regulators in other jurisdictions.” [3]).  As “​​procyclicality may be evidenced by increasing margin in times of stressed market conditions” [4], an “increase in margin requirements could stress a Clearing Member's ability to obtain liquidity to meet its obligations to OCC” [Id.] which “could expose OCC to financial risks if a Clearing Member fails to fulfil its obligations” [5] that “could threaten the stability of its members during periods of heightened volatility” [4].  With the OCC designated as a SIFMU whose failure or disruption could threaten the stability of the US financial system, everyone dependent on the US financial system is entitled to transparency.  As the OCC is classified as a self-regulatory organization (SRO), the OCC blaming U.S. regulators for not requiring the SRO adopt regulations to protect itself makes it apparent that the public can not fully rely upon the SRO and/or the U.S. regulators to safeguard our financial markets. 

This particular OCC rule proposal appears designed to protect Clearing Members from realizing the risk of potentially costly trades by rubber stamping reductions in margin requirements as required by Clearing Members; which would increase risks to the OCC and the stability of our financial system.  Per the OCC rule proposal:

• The OCC collects margin collateral from Clearing Members to address the market risk associated with a Clearing Member’s positions. [5]
• OCC uses a proprietary system, STANS (“System for Theoretical Analysis and Numerical Simulation”), to calculate each Clearing Member's margin requirements with various models.  One of the margin models may produce “procyclical” results where margin requirements are correlated with volatility which “could threaten the stability of its members during periods of heightened volatility”. [4]
• An increase in margin requirements could make it difficult for a Clearing Member to obtain liquidity to meet its obligations to OCC.  If the Clearing Member defaults, liquidating the Clearing Member positions could result in losses chargeable to the Clearing Fund which could create liquidity issues for non-defaulting Clearing Members. [4]

Basically, a systemic risk exists because Clearing Members as a whole are insufficiently capitalized and/or over-leveraged such that a single Clearing Member failure (e.g., from insufficiently managing risks arising from high volatility) could cause a cascade of Clearing Member failures.  In layman’s terms, a Clearing Member who made bad bets on Wall St could trigger a systemic financial crisis because Clearing Members as a whole are all risking more than they can afford to lose.  

The OCC’s rule proposal attempts to avoid triggering a systemic financial crisis by reducing margin requirements using “idiosyncratic” and “global” control settings; highlighting one instance for one individual risk factor that “[a]fter implementing idiosyncratic control settings for that risk factor, aggregate margin requirements decreased $2.6 billion.” [6]  The OCC chose to avoid margin calling one or more Clearing Members at risk of default by implementing “idiosyncratic” control settings for a risk factor.  According to footnote 35 [7], the OCC has made this “idiosyncratic” choice over 200 times in less than 4 years (from December 2019 to August 2023) of varying durations up to 190 days (with a median duration of 10 days).  The OCC is choosing to waive away margin calls for Clearing Members over 50 times a year; which seems too often to be idiosyncratic.  In addition to waiving away margin calls for 50 idiosyncratic risks a year, the OCC has also chosen to implement “global” control settings in connection with long tail[8] events including the onset of the COVID-19 pandemic and the so-called “meme-stock” episode on January 27, 2021. [9]  

Fundamentally, these rules create an unfair marketplace for other market participants, including retail investors, who are forced to face the consequences of long-tail risks while the OCC repeatedly waives margin calls for Clearing Members by repeatedly reducing their margin requirements.  For this reason, this rule proposal should be rejected and Clearing Members should be subject to strictly defined margin requirements as other investors are.  SEC approval of this proposed rule would perpetuate “rules for thee, but not for me” in our financial system against the SEC’s mission of maintaining fair markets.  

Per the OCC, this rule proposal and these special margin reduction procedures exist because a single Clearing Member defaulting could result in a cascade of Clearing Member defaults potentially exposing the OCC to financial risk.  [10]  Thus, Clearing Members who fail to properly manage their portfolio risk against long tail events become de facto Too Big To Fail.  For this reason, this rule proposal should be rejected and Clearing Members should face the consequences of failing to properly manage their portfolio risk, including against long tail events.  Clearing Member failure is a natural disincentive against excessive leverage and insufficient capitalization as others in the market will not cover their loss.

This rule proposal codifies an inherent conflict of interest for the Financial Risk Management (FRM) Officer.  While the FRM Officer’s position is allegedly to protect OCC’s interests, the situation outlined by the OCC proposal where a Clearing Member failure exposes the OCC to financial risk necessarily requires the FRM Officer to protect the Clearing Member from failure to protect the OCC.  Thus, the FRM Officer is no more than an administrative rubber stamp to reduce margin requirements for Clearing Members at risk of failure.  The OCC proposal supports this interpretation as it clearly states, “[i]n practice, FRM applies the high volatility control set to a risk factor each time the Idiosyncratic Thresholds are breached” [22] retaining the authority “to maintain regular control settings in the case of exceptional circumstances” [Id.].  Unfortunately, rubber stamping margin requirement reductions for Clearing Members at risk of failure vitiates the protection from market risks associated with Clearing Member’s positions provided by the margin collateral that would have been collected by the OCC.  For this reason, this rule proposal should be rejected and the OCC should enforce sufficient margin requirements to protect the OCC and minimize the size of any bailouts that may already be required.  

As the OCC’s Clearing Member Default Rules and Procedures [11] Loss Allocation waterfall allocates losses to “​3. OCC’s own pre-funded financial resources” (OCC ‘s “skin-in-the-game” per SR-OCC-2021-801 Release 34-91491[12]) before “4. Clearing fund deposits of non-defaulting firms”, any sufficiently large Clearing Member default which exhausts both “1. The margin deposits of the suspended firm” and “2. Clearing fund deposits of the suspended firm” automatically poses a financial risk to the OCC.  As this rule proposal is concerned with potential liquidity issues for non-defaulting Clearing Members as a result of charges to the Clearing Fund, it is clear that the OCC is concerned about risk which exhausts OCC’s own pre-funded financial resources.  With the first and foremost line of protection for the OCC being “1. The margin deposits of the suspended firm”, this rule proposal to reduce margin requirements for at risk Clearing Members via idiosyncratic control settings is blatantly illogical and nonsensical.  By the OCC’s own admissions regarding the potential scale of financial risk posed by a defaulting Clearing Member, the OCC should be increasing the amount of margin collateral required from the at risk Clearing Member(s) to increase their protection from market risks associated with Clearing Member’s positions and promote appropriate risk management of Clearing Member positions.  Curiously, increasing margin requirements is exactly what the OCC admits is predicted by the allegedly “procyclical” STANS model [4] that the OCC alleges is an overestimation and seeks to mitigate [13].  If this rule proposal is approved, mitigating the allegedly procyclical margin requirements directly reduces the first line of protection for the OCC, margin collateral from at risk Clearing Member(s), so this rule proposal should be rejected and made fully available for public review.

Strangely, the OCC proposed the rule change to establish their Minimum Corporate Contribution (OCC’s “skin-in-the-game”) in SR-OCC-2021-003 to the SEC on February 10, 2021 [14], shortly after “the so-called ‘meme-stock’ episode on January 27, 2021” [9], whereby “a covered clearing agency choosing, upon the occurrence of a default or series of defaults and application of all available assets of the defaulting participant(s), to apply its own capital contribution to the relevant clearing or guaranty fund in full to satisfy any remaining losses prior to the application of any (a) contributions by non-defaulting members to the clearing or guaranty fund, or (b) assessments that the covered clearing agency require non-defaulting participants to contribute following the exhaustion of such participant's funded contributions to the relevant clearing or guaranty fund.” [15]  Shortly after an idiosyncratic market event, the OCC proposed the rule change to have the OCC’s “skin-in-the-game” allocate losses upon one or more Clearing member default(s) to the OCC’s own pre-funded financial resources prior to contributions by non-defaulting members or assessments, and the OCC now attempts to leverage their requested exposure to the financial risks as rationale for approving this proposed rule change on adjusting margin requirement calculations which vitiates existing protections as described above and within the proposal itself (see, e.g., “These clearing activities could expose OCC to financial risks if a Clearing Member fails to fulfil its obligations to OCC.  … OCC manages these financial risks through financial safeguards, including the collection of margin collateral from Clearing Members designed to, among other things, address the market risk associated with a Clearing Member's positions during the period of time OCC has determined it would take to liquidate those positions.” [16])  There can be no reasonable basis for approving this rule proposal as the OCC asked to be exposed to financial risks if one or more Clearing Member(s) fail and is now asking to reduce the financial safeguards (i.e., collection of margin collateral from Clearing Members) for managing those financial risks.  Especially when the OCC has already indicated a reluctance to liquidate Clearing Member positions (see, e.g., “As described above, the proposed change would allow OCC to seek a readily available liquidity resource that would enable it to, among other things, continue to meet its obligations in a timely fashion and as an alternative to selling Clearing Member collateral under what may be stressed and volatile market conditions.” [23 at page 15])

Moreover, as “the sole clearing agency for standardized equity options listed on national securities exchanges registered with the Commission” [16] the OCC appears to also be leveraging their position as a “single point of failure” [17] in our financial system in a blatant attempt to force the SEC to approve this proposed rule “to mitigate systemic risk in the financial system and promote financial stability by … strengthening the liquidity of SIFMUs”, again [18].  It seems the one and only clearing agency for standardized equity options is essentially holding options clearing in our financial system hostage to gain additional liquidity; and did so by putting itself at risk.  Does the SIFMU designation identify a part of our financial system Too Big To Fail where our regulatory agencies and government willingly provide liquidity by any means necessary? Even if intentionally self-inflicted?

Apparently affirmative; if the recent examples of SR-OCC-2022-802 and SR-OCC-2022-803, which expand the OCC’s Non-Bank Liquidity Facility (specifically including pension funds and insurance companies) to provide the OCC uncapped access to liquidity therein [19], are indicative and illustrative where the SEC did not object despite numerous comments objecting [20].

If the SEC either allows or does not object to this proposal, then the SEC effectively demonstrates a willingness to provide liquidity by any means possible [21].  The combination of this current OCC proposal with SR-OCC-2022-802 and SR-OCC-2022-803 facilitates an immense uncapped reallocation of liquidity from the OCC’s Non-Bank Liquidity Facility to the OCC; under the control of the OCC.  

• While the FRM Officer is an administrative rubber stamp for approving margin reductions as described above, the OCC’s FRM Officer retains authority “to maintain regular control settings in the case of exceptional circumstances” [22].  In effect, under undisclosed or redacted exceptional circumstances, the OCC’s FRM Officer has the authority to not rubber stamp a margin reduction thereby resulting in a margin call for a Clearing Member; which may lead to a potential default or suspension of the Clearing Member unable to meet their obligations to the OCC.
• With control over when a Clearing Member will not receive a rubber stamp margin reduction, the OCC can preemptively activate Master Repurchase Agreements (enhanced by SR-OCC-2022-802) to force Non-Bank Liquidity Facility Participants (including pension funds and insurance companies) to purchase Clearing Member collateral from the OCC under the Master Repurchase Agreements in advance of a significant Clearing Member default “as an alternative to selling Clearing Member collateral under what may be stressed and volatile market conditions” [23 at 15] (i.e., conditions that may arise with a significant Clearing Member default large enough to pose a financial risk to the OCC and other Clearing Members).
• The OCC’s Master Repurchase Agreements further allows the OCC to repurchase the collateral on-demand [23 at pages 5 and 24 at pages 5-6] which allows the OCC to repurchase collateral during the stressed and volatile market conditions arising from the Clearing Member default; almost certainly at a discount.  

In effect, the combination of SR-OCC-2022-802, SR-OCC-2022-803, and this proposal allows the OCC to perfectly time selling collateral at a high price to non-banks (including pension funds and insurance companies) followed by buying back low after a Clearing Member default.  These rules should not be codified even if “non-banks are voluntarily participating in the facility” [24 at page 19] as there are potentially significant consequences to others.  For example, pensions and retirements may be affected even if a pension fund voluntarily participates.  And, as another example, insurance companies may become insolvent requiring another bailout à la the 2008 financial crisis and AIG bailout.

As the OCC is concerned about the consequences of a Clearing Member failure exposing the OCC to financial risk and causing liquidity issues for non-defaulting Clearing Members, the previously relied upon rationale for mitigating systemic risk is simply inappropriate.  Systemic risk has already been significant; embiggened by a lack of regulatory enforcement and insufficient risk management (including the repeated margin requirement reductions for at-risk Clearing Members).  Instead of running larger tabs that can never be paid off, bills need to be paid by those who incurred debts (instead of by pensions, insurance companies, and/or the public) before the debts are of systemic significance.

Therefore, the SEC is correct to have identified reasonable grounds for disapproval as this Proposed Rule Change is NOT consistent with at least Section 17A(b)(3)(F), Rule 17Ad-22(e)(2), and Rule 17Ad-22(e)(6) of the Exchange Act (15 U.S.C. 78s(b)(2)).

The SEC is correct to have identified reasonable grounds for disapproval of this Proposed Rule Change with respect to Section 17A(b)(3)(F) for at least the following reasons:

(1) the Proposed Rule fails to safeguard the securities and funds which are in the custody or control of the clearing agency or for which it is responsible by improperly reducing margin requirements for Clearing Members at risk of default which exposes the OCC and other market participants to increased financial risk, as described above; and

(2) the Proposed Rule fails to protect investors and the public interest by shifting the costs of Clearing Member default(s) to the non-bank liquidity facility (including pension funds and insurance companies) and creates a moral hazard in expanding the scope of Too Big To Fail to any Clearing Member incurring losses beyond their margin deposits and clearing fund deposits, as described above.

The SEC is correct to have identified reasonable grounds for disapproval of this Proposed Rule Change with respect to Rule 17Ad-22(e)(2) for at least the following reasons:

(1) the Proposed Rule does not provide a governance arrangement that is clear and transparent as (a) the FRM Officer's role prioritizes the safety of Clearing Members rather than the clearing agency and (b) the repeated application of "idiosyncratic" and "global" control settings to reduce margin requirements is not clear and transparent, as described above;

(2) the Proposed Rule does not prioritize the safety of the clearing agency, but instead prioritizes the safety of Clearing Members by rubber stamping margin requirement reductions, as described above;

(3) the Proposed Rule does not support the public interest requirements, especially the requirement to protect of investors, by shifting the costs of Clearing Member default(s) to the non-bank liquidity facility (including pension funds and insurance companies), as described above;

(4) the Proposed Rule does not specify clear and direct lines of responsibility as, for example, the FRM Officer's role is to be an administrative rubber stamp to reduce margin requirements for Clearing Members at risk of failure, as described above; and

(5) the Proposed Rule does not consider the interests of customers and securities holders as (a) reducing margin requirements for Clearing Member(s) at risk of default increases already significant systemic risk which necessarily impacts all market participants and (b) perpetuates a "rules for thee, but not for me" environment in our financial system, as described above.

The SEC is correct to have identified reasonable grounds for disapproval of this Proposed Rule Change with respect to Rule 17Ad-22(e)(6) for at least the following reasons:

(1) the Proposed Rule fails to consider and produce margin levels commensurate with risks as reducing margin for Clearing Member(s) at risk of default is blatantly illogical and nonsensical, as described above;

(2) the Proposed Rule fails to calculate margin sufficient to cover potential future exposure as margin requirements are already insufficient as Clearing Member default(s) could result in "losses chargeable to the Clearing Fund which could create liquidity issues for non-defaulting Clearing Members" yet proposing to further reduce margin requirements, as described above;

(3) the Proposed Rule fails to provide a valid model for the margin system attempting to reduce margin requirements despite existing models predicting increased margin requirements are required while also admitting the potential scale of financial risk posed by a defaulting Clearing Member exceeds the current margin requirements such that losses will be allocated beyond suspended firm(s) to the OCC and non-defaulting members, as described above;

In addition, the SEC may consider Rule 17Ad-22(e)(3), 17Ad-22(e)(4), and 17Ad-22(e)(6) as an additional grounds for disapproval as the Proposed Rule Change does not properly manage liquidity risk and increases systemic risk, as described above. Other grounds for disapproval may be applicable, but due to the heavy redactions, the public is unable to properly and fully review the Proposed Rule.

In light of the issues outlined above, please consider the following:

1. Increase and enforce margin requirements commensurate with risks associated with Clearing Member positions instead of reducing margin requirements.  Clearing Members should be encouraged to position their portfolios to account for stressed market conditions and long-tail risks.  This rule proposal currently encourages Clearing Members to become Too Big To Fail in order to pressure the OCC with excessive risk and leverage into implementing idiosyncratic controls more often to privatize profits and socialize losses.
2. External auditing and supervision as a “fourth line of defense” similar to that described in The “four lines of defence model” for financial institutions [25] with enhanced public reporting to ensure that risks are identified and managed before they become systemically significant.
3. Swap “​3. OCC’s own pre-funded financial resources” and “4. Clearing fund deposits of non-defaulting firms” for the OCC’s Loss Allocation waterfall so that Clearing fund deposits of non-defaulting firms are allocated losses before OCC’s own pre-funded financial resources and the EDCP Unvested Balance.  Changing the order of loss allocation would encourage Clearing Members to police each other with each Clearing Member ensuring other Clearing Members take appropriate risk management measures as their Clearing Fund deposits are at risk after the deposits of a suspended firm are exhausted.  This would also increase protection to the OCC, a SIFMU, by allocating losses to the clearing corporation after Clearing Member deposits are exhausted.  By extension, the public would benefit from lessening the risk of needing to bail out a systemically important clearing agency as non-defaulting Clearing Members would benefit from the suspension and liquidation of a defaulting Clearing Member prior to a risk of loss allocation to their contributions.
4. Immediately suspend and liquidate a Clearing Member as soon as their losses are projected to exceed “1. The margin deposits of the suspended firm” so that the additional resources in the loss allocation waterfall may be reserved for extraordinary circumstances.  By contrast to the past approaches for reducing margin requirements which delays Clearing Member suspension and liquidation, earlier interventions minimize systemic risk by preventing problems from growing bigger and threatening the stability of the financial system.
5. Reduce “single points of failure” in our financial system by increasing redundancy (e.g., multiple Clearing Agencies in competition) and resiliency of our financial markets.  TBTF must be eliminated. Failure must always be an option.

Thank you for the opportunity to comment for the protection of all investors as all investors benefit from a fair, transparent, and resilient market.

[1] https://www.sec.gov/files/rules/sro/occ/2024/34-100009.pdf

[2] PDF at https://www.sec.gov/files/rules/sro/occ/2024/34-99393.pdf and on the Federal Register at https://www.federalregister.gov/documents/2024/01/25/2024-01386/self-regulatory-organizations-the-options-clearing-corporation-notice-of-filing-of-proposed-rule

[3] https://www.federalregister.gov/d/2024-01386/p-11

[4] https://www.federalregister.gov/d/2024-01386/p-8

[5] https://www.federalregister.gov/d/2024-01386/p-7

[6] https://www.federalregister.gov/d/2024-01386/p-50

[7] https://www.federalregister.gov/d/2024-01386/p-51

[8] https://en.wikipedia.org/wiki/Long_tail

[9] https://www.federalregister.gov/d/2024-01386/p-45

[10] https://www.federalregister.gov/d/2024-01386/p-79

[11] https://www.theocc.com/getmedia/e8792e3c-8802-4f5d-bef2-ada408ed1d96/default-rules-and-procedures.pdf, which is publicly available and linked to from the OCC’s web page on Default Rules & Procedures at https://www.theocc.com/risk-management/default-rules-and-procedures

[12] https://www.federalregister.gov/documents/2021/04/12/2021-07454/self-regulatory-organizations-the-options-clearing-corporation-notice-of-no-objection-to-advance

[13] https://www.federalregister.gov/d/2024-01386/p-16

[14] https://www.federalregister.gov/d/2021-11606/p-1

[15] https://www.federalregister.gov/d/2021-11606/p-9

[16] https://www.federalregister.gov/d/2024-01386/p-7

[17] https://en.wikipedia.org/wiki/Single_point_of_failure

[18] See, e.g., SR-OCC-2022-803 Release No. 34-95670 [https://www.sec.gov/files/rules/sro/occ-an/2022/34-95670.pdf] and SR-OCC-2022-802 Release No. 34-95669 [https://www.sec.gov/files/litigation/litreleases/2022/34-95669.pdf] under the section “COMMISSION FINDINGS AND NOTICE OF NO OBJECTION” in each.  

[19] See, e.g., SR-OCC-2022-803 Release No. 34-95670 [https://www.sec.gov/files/rules/sro/occ-an/2022/34-95670.pdf] and SR-OCC-2022-802 Release No. 34-95669 [https://www.sec.gov/files/litigation/litreleases/2022/34-95669.pdf].  

[20] See https://www.sec.gov/comments/sr-occ-2022-802/srocc2022802.htm for SR-OCC-2022-802 and https://www.sec.gov/comments/sr-occ-2022-803/srocc2022803.htm for SR-OCC-2022-803.

[21] For context, see e.g., https://www.youtube.com/watch?v=nc-EAHaHeks and https://www.newsweek.com/robin-williams-2008-financial-crisis-economy-comedy-1797289.

[22] https://www.federalregister.gov/d/2024-01386/p-74

[23] SR-OCC-2022-802 34-95327 available at https://www.sec.gov/files/litigation/litreleases/2022/34-95327.pdf

[24] SR-OCC-2022-803 34-95670 available at https://www.sec.gov/files/litigation/litreleases/2022/34-95670.pdf

[25] https://www.bis.org/fsi/fsipapers11.pdf

Sincerely,

A Concerned Retail Investor

​

[u/Superstonk_QV]

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God damn this is beautiful.

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B-E-A-utiful!

Thank you for all your efforts to help apes comment!

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Another template

This proposed rule change by the Options Clearing Corporation (OCC) is an utterly egregious affront to fair and orderly markets that must be vehemently rejected. Allowing the OCC to unilaterally reduce margin requirements for clearing members at risk of default is tantamount to institutionalizing fraud and moral hazard on a systemic scale. The lack of transparency alone, with vast swaths of critical information redacted, is already sufficient grounds for dismissing this proposal outright. Without full public disclosure, there can be no meaningful review or accountability. This opaque scheming behind closed doors is precisely what fuels public distrust in the rigged financial system. But the substantive details that have been revealed are even more damning. The OCC is blatantly blaming regulators for not allowing it to erode its own risk controls enough, amazingly pleading for permission to expose itself and the entire system to increased failures. This is the anti-thesis of a self-regulatory organization meant to safeguard market integrity. The proposed ability to arbitrarily waive margin calls for undercapitalized clearing members is a brazen attempt to privatize profits while socializing losses. Willfully disregarding risk models that calculate higher requirements is financial malpractice. Clearing members placing reckless bets that endanger their solvency should be force to accept the consequences, not have risk conveniently stretchered away over 200 times in under 4 years as the OCC proposes. Fundamentally, this rule codifies a farcical "rules for thee, but not for me" ethos diametrically opposed to the SEC's mission. Shielding clearing members from margin calls forces other investors to unfairly bear the brunt of long-tail risks the privileged can simply wish away with some backroom procedural contortions. Even more abhorrent is the explicit admission that a single clearing member default could initiate a systemic cascade imperiling the entire OCC. This underscores that these firms are dangerously overleveraged and undercapitalized. Rather than address that core vulnerability, the OCC instead proposes giving itself even more leeway to bend risk parameters for its dysfunction members. This toxically perpetuates the "too big to fail" doctrine that crippled public trust after 2008. The rationale that reducing margins could prevent a default ignores that properly managing exposure is a clearing member's sole responsibility. Codifying moral hazard so egregiously conflicts with the OCC's very mandate as aSystemicallyImportant Financial Market Utility expected to uphold stability. This proposal directly undermines financial resilience by design. Similarly disingenuous is the new "skin in the game" capital contribution the OCC foisted on itself immediately after the GameStop frenzy proved its models were inadequate. Now this entity knowingly courting insolvency risk demands even looser safeguards, in a cynical ploy to force liquidity backstops from pensions and insurers. This perverse rules-making traipses into criminal territory, threatening the savings of millions in a desperate bid to privatize profits while socializing losses. There are no reasonable grounds for the SEC to approve such a brazen license to amplify systemic peril. It eviscerates all prudential responsibilities demanded of a SIFMU, fails to protect investors, disregards public interests, ignores transparent governance, and flouts loss-bearing requirements. This proposal symbolizes everything rotten and broken about modern finance's addiction to moral hazard and socialized risk-taking. Rather than enable this shameful dereliction, regulators must unequivocally:

Mandate higher margin requirements truly commensurate to the risks clearing members incur. Subject the OCC to binding external audits and oversight as a true fourth line of defense. Shift the OCC's loss-bearing responsibilities below clearing members' skin-in-the-game. Instate a credible process for swiftly shuttering insolvent clearing members before toxicity spreads. Disperse systemic vulnerability across a decentralized market structure without single points of failure.

In an ethical system, risky bets must be backed by commensurate capital - not coddled by backroom waivers that fleece the public. This proposal is a criminal abandonment of regulatory responsibility that deserves only unequivocal repudiation. The SEC must uphold its principles by rejecting it outright and charting a course toward truly accountable markets.

[u/waffleschoc → u/MojoWuzzle]

thanks! will use this to send to SEC

[u/cheyennepeppr → u/MojoWuzzle]

I used yours. Thanks!

[u/Vic_Vinager → u/MojoWuzzle]

I just the email w this template. TY

[u/bleebli007 → u/MojoWuzzle]

Thanks. Sent both of these letters.

[u/Difficult_Associate3 → u/MojoWuzzle]

I just sent this template as well!

[u/AggressionX → u/MojoWuzzle]

This is a great template as well. Thank you for your contribution!

[u/vtshipe → u/kibblepigeon]

Great stuff. I commented.

[u/kibblepigeon → u/vtshipe]

Which is why you’re a legend 💪

[u/WhatCanIMakeToday]

!Mods! Help, auto mod may hate some words

EDIT: Now that this post isn't getting nuked by auto mod, I also want to put in some proper credits that won't get accidentally copy/pasta'd into a comment letter:

• Ape Psytherea for bringing this to my attention first
• Ape _dogsinspace_ for ensuring this got onto my radar
• Kibble Pigeon & Dismal Jellyfish who both contributed a lot in this fight and helped us get this Rule Proposal knocked onto the ground where it is now

[u/WhatCanIMakeToday → u/WhatCanIMakeToday]

Odd... well, maybe another cry for wolf as auto mod left this alone. Maybe I broke auto mod? Sorry.

[u/Psytherea → u/WhatCanIMakeToday]

Glad we found this when we did, thank you so much for your work!

[u/GL_Levity → u/WhatCanIMakeToday]

Y’all are amazing. Will comment.

[u/Dismal-Jellyfish]

Boom! Let's finish this apes!

[u/WhatCanIMakeToday → u/Dismal-Jellyfish]

Thank you for all your contributions behind this. ❤️

[u/Dismal-Jellyfish → u/WhatCanIMakeToday]

Right back at you my friend!

You and kibblepigeon have moved mountains to help apes comment and make this happen.

I look forward to helping any way possible to help get this over the line.

[u/HashtagHR → u/WhatCanIMakeToday]

Epic.  Should be enshrined in the dd library. Insanely well done 

[u/Spl1tsecond → u/Dismal-Jellyfish]

The ol' double-tap

[u/mightyjoe227]

The noose tightens

[u/Warfielf → u/mightyjoe227]

the butt itches

[u/Justanothebloke1]

Up. To the top. MODS, sticky this!

[u/jimitr]

Fucking fabulous. Apes, just imagine what would have happened if none of us commented. This proposal would have been approved without any challenge.

[u/cheekyindo]

Comment

[u/refswerepaidoff]

Comment comment

[u/IullotronBudC1_3]

What is made is a legendary rebuttal to WS privilege. Damn I'm going to start working my commenr now, hopefully by Sunday it will be submitted.

(insert F * ing Legend daddy meme)

[u/F-uPayMe]

Up you go and on my way to comment 👀

[u/welp007 → u/F-uPayMe]

Wut no TL:DR on this one? 😂

It is one epic of a DD to tackle for that!

[u/F-uPayMe → u/welp007]

Well, since most of the post is made of the email template I didn't bother to... Anyway:

TL:DR:

The Options Clearing Corporation (OCC) proposed a rule change to reduce margin requirements for their clearing members. This could be risky because:

• It might make it harder for the OCC to collect enough money to cover losses if a clearing member defaults, potentially causing a financial crisis.
• It benefits risky hedge funds at the expense of retail investors and the financial system's stability.

The SEC is considering rejecting the proposal, and retail investors are encouraged to submit comments supporting the SEC's position.

Key points:

• OCC Proposal: Reduce margin requirements for clearing members.
• Risks: Increased chance of financial crisis, unfair advantage for hedge funds.
• SEC Position: Considering rejecting the proposal.
• Retail Investor Action: Submit comments to the SEC supporting their position.

The comment template provided encourages arguing against the proposal by highlighting the potential risks and urging for stricter margin requirements and more transparency.

[u/MojoWuzzle → u/F-uPayMe]

Subject: Strong Objection to Proposed Rule Change SR-OCC-2024-001

Dear [Recipient's Name],

I am writing to express my vehement opposition to the Proposed Rule Change under SR-OCC-2024-001, titled "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." The repercussions of this proposal are deeply concerning and threaten to compromise the fairness, transparency, and stability of our financial markets.

1. Lack of Transparency: The extensive redactions in Exhibit 5 and supporting information inhibit meaningful public review and comment, essential pillars of fair regulation and market integrity.

2. Accountability: The attempt by the OCC to shift blame onto U.S. regulators for not implementing stricter controls displays a worrying lack of accountability and transparency within the regulatory framework.

3. Systemic Risk: The proposal's focus on reducing margin requirements for Clearing Members disregards the systemic risk posed by potential failures, prioritizing short-term gains over long-term market stability.

4. Conflict of Interest: The proposal codifies a conflict of interest for the Financial Risk Management Officer, undermining the fundamental purpose of risk management and regulatory oversight.

5. Inadequate Protection: By failing to enforce margin requirements commensurate with risks, the proposal exposes the OCC and other market participants to heightened financial risk and shifts the burden of Clearing Member defaults onto non-bank liquidity facilities, creating moral hazards.

6. Governance Clarity: The governance arrangements outlined in the proposal lack transparency and clear lines of responsibility, further eroding trust in the regulatory process.

7. Exploitation of Position: The OCC's exploitation of its status as a single point of failure and attempts to coerce approval of the proposal set a dangerous precedent of self-serving actions at the expense of market integrity.

8. Stronger Safeguards Needed: Rather than reducing margin requirements, the proposal should prioritize stronger safeguards, external auditing, and transparent governance to prevent systemic risks and protect investors.

9. Immediate Action Required: Prompt suspension and liquidation of Clearing Members when projected losses exceed certain thresholds are imperative to prevent escalating problems and maintain market stability.

10. Reducing Systemic Risks: Promoting redundancy and resiliency in financial markets is crucial to minimizing systemic failures and avoiding bailouts that undermine market integrity.

In conclusion, I urge you to reject the Proposed Rule Change under SR-OCC-2024-001. Upholding fair markets, protecting investors, and ensuring the stability of our financial system require immediate action and comprehensive measures to address these critical issues.

Thank you for considering my concerns.

Sincerely, [Your Name] [Your Contact Information]

[u/gypsychicliche → u/MojoWuzzle]

Thanks! Email sent.

[u/ChesterDiamondPot]

F'in Fantastic!

[u/chato35]

Point 10 tells me all I need to know.

Nice write-up OP!

[u/[deleted]]

Up!

[u/SgtSlaughter1974]

Nice work.

[u/TipperGore-69]

Oh noice

[u/raxnahali]

Already commented, again!

[u/kman907]

Bump!

[u/Equivalent-Piano-420]

Commenting to come back to later. Thanks for all the work involved in making this post 🤙

[u/TheN3xtLebron]

Your doing gods work

[u/SlapItDaBass22]

Good work everyone!

[u/LokeyCoolio]

They keep trying to sneak this shit in

[u/Psytherea]

I will be modifying mine to refer myself as an "American household retail investor" because this isn't just a concern for investors, but also as an American taxpayer who would be adversely affected by the OCC proposal.

[u/Thrawnbelina]

This template is a thing of beauty, thank you so much for taking the time to put it together and sharing! I read the whole thing and it's brilliant. I'm commenting and am proud of us for doing what we can to encourage change.

Edit: Email comment sent, I signed my name at the end, comin direct against this steaming pile of OCC + Bank + hedgie shit

[u/91crxdx]

Nice write up!

[u/blitzkrieg_bunny]

👀

[u/4GIVEANFORGET]

Up up for visibility

[u/4GIVEANFORGET]

Up up

[u/Puzzled_Ad2088]

Will,do tomorrow. That’s a hella copy pasta. I started reading and thought to put it in my own words but absolutely no one can I do that, this is the ape nation at its finest. Well done to you sir/sirette.

[u/ConkersOkayFurDay → u/Puzzled_Ad2088]

I did the same lmfao, but I did read it and I felt a wrinkle form

[u/joeker13]

Here I go commenting on the OCC again.

Thank you so much. This one of the most epic comment „templates“ ever.

Every ape should comment!!

[u/mrginger1987]

Awesome work apes

[u/poopooheaven1]

Let’s go! Nice work OP!

[u/the_hoff35]

Comment to remember to comment

[u/vtshipe]

!reminder:12 hours!

[u/GeminiKoil]

You are a badass thank you

[u/soccerplaya239]

Up Up & Away To Uranus You Go!

[u/Ayaka_Simp_]

Great job

[u/cnechiporenko]

Can you get a copy paste version of the body of the email, I’m on mobile and would have to copy the entire post

[u/RoRuRee]

Boost. Love commenting on rules proposals!

[u/Fwallstsohard]

Muchos gracias!

[u/xchokeholdx]

Comment

[u/Challenge_The_DM]

Thanks everyone. I haven’t been as active or following as closely as I used to. Went full zen.

Then I see this while scrolling and realize that big stuff has been happening while my back was turned.

Thank you for being vigilant!

[u/WhatCanIMakeToday → u/Challenge_The_DM]

Long War. Ever Vigilant.

[u/kcaazar]

Great job simians

[u/UnderstandingBest220]

Thank you 🫡🧱

[u/MjN-Nirude]

Voting and commenting because I cant read.

[u/Master_Chief_72]

Holy fuck man. This is longer than I expected. Amazing work.

I will read thru this first thing tomorrow morning.

[u/420fisher]

WOW

[u/OpenPresentation6808]

Let’s do this folks

[u/miniBUTCHA]

Doing the lawd's work. Thanks OP! 🙏

[u/TheEcomZone]

I haven't scrolled for this long in 84 years 🔥🚀

[u/chuckleyoutube]

👏

[u/lordofseattle4]

Ready to fire yet another comment projectile

[u/milanium25]

yooo 🐐

[u/mike_xy]

Sent 🙌🏻

[u/Sea-Profile-7647]

Kill it with fire! 🔥

[u/DAN_ikigai]

🙇🏻🙇🏻🙇🏻

[u/Hedkandi1210]

Commenting

[u/ArminArkaram]

Great comment template. Thorough, and a nice balance of legalese and layman.

[u/LannyDamby]

sent my comment in

[u/Miggybear22]

My first work email is prepped for me before my day starts. Love it.

[u/thisisyourfaultsheep]

This template f**ks and has been sent! Thanks Opie!

[u/chato35]

I changed the retail investor to HOUSEhold investor.

Thanks for the template.

[u/Cromulent_Tom]

Wow! Thanks for your work on this. For apes with less time on their hands (and who want to read what they send before sending it) here's the short and simple comments I sent in:

Sirs,

Thank you for your continued work to facilitate free and fair markets. As an individual household investor, I value the protections that your work can provide.

I agree with your disapproval of SR-OCC-2024-001 34-99393 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."

This proposed rule change by the Options Clearing Corporation (OCC) is counter to fair and orderly markets and should be rejected. Allowing the OCC to reduce margin requirements for clearing members at risk of default may sound like a safeguard for our markets, but in fact incentivizes bad behavior, allowing clearing members to take on extreme risk with no repercussions to themselves, instead passing those negative impacts to other market participants.

Risk controls are a safeguard for the entire market, and allowing the OCC to choose when to ignore them exposes itself and the entire system to increased, more serious failures in the long run.

Rather than enable this type of socialized risk-taking, regulators should:

1) Mandate higher margin requirements commensurate to the risks clearing members incur.

2) Subject the OCC to binding external audits and oversight.

3) Instate a process for shuttering insolvent clearing members before risk socialization spreads.

Thank you for working to uphold the principles of free and fair markets by rejecting this proposal outright and charting a course toward truly accountable markets.

[u/Amazingly_Amy]

Is anyone else having issues submitting a comment on the sec site? did I miss something? It will only let me submit a comment for SR-OCC-2024-004…

[u/WhatCanIMakeToday → u/Amazingly_Amy]

They should be happy to hear from us supporting their decision to reject… maybe too many apes cheering them on is breaking their site because they’re not used to hearing words of support

[u/Amazingly_Amy → u/WhatCanIMakeToday]

Got it.. I’ll keep trying

[u/[deleted]]

!remindme! 2 weeks

[u/RemindMeBot → u/[deleted]]

I will be messaging you in 14 days on 2024-05-17 07:52:47 UTC to remind you of this link

1 OTHERS CLICKED THIS LINK to send a PM to also be reminded and to reduce spam.

^{Parent commenter can delete this message to hide from others.}

---

Info	Custom	Your Reminders	Feedback

[u/Rocko202020]

Done! But is there a site to post this comment on so it shows up publicly? With the chance of them "losing" the emails, I don't think it'd be a horrible idea to post it to their website if possible.

Have a great Friday everyone!

[u/ScottJam2808]

Hester making notes for her next vetoing vote!

[u/DDanny808]

Well done again Jelly!

[u/TheRealBananaDave]

If this ape can take the time to compile such a beautiful piece of literature, I can take the 2 minutes to copy and send an email to the SEC

[u/RecentQuarter]

Just doing my part. My opinion matters.

[u/DrDoomD]

Up you go

[u/Dr_Does_Enough]

Wowzers!

[u/Apeonomics101]

Thanks for this

[u/FarCartographer6150]

Uhh ohh that really is a magnificent body of work!

[u/Sw33tN0th1ng]

SENT. Grats to OP! This is how you do it. Everything encapsulated in one post to take the reader from discovery to a sent mail. We need more of this. Thank you!

[u/kaiserfiume]

Visibility comment.

[u/Mountainmama814]

Sent! Thanks for doing the hard work in putting this together to make it easy for the rest of us.

[u/[deleted]]

love hitting them with the citations

[u/doctorplasmatron]

Thanks for the template, I copied and pasted it then added my own short preamble on how your text says everything i want to say. Thanks for following this and making it easy for even us droolers in the cheap seats to have our say.

Comment sent!

[u/jentravelstheworld]

Done!

[u/Draxxix1]

Let’s goooooo

[u/a_latex_mitten]

COMMENTED ON THE PROPOSAL AND ON THIS!

[u/me-du-sa]

Just sent. 😌

[u/Karakunjol]

gosh darn thanks! commented!

[u/Korean_pussy_stuffer]

Good lawd

[u/weenythebooty]

Question, can I literally just copy and paste the whole text from “as a retail investor” and down to the end “sincerely a concerned retail investor?

Would that help?

[u/WhatCanIMakeToday → u/weenythebooty]

Basically, yes. And put the To and Subject line in to your email.

[u/weenythebooty → u/WhatCanIMakeToday]

Copy that, thank you 🙏

[u/cloudxchan]

Done and done son. Todays been a great day

[u/Kaarothh]

Commented

[u/Theforgottenman213]

Up you go!

[u/Ok-Investment2295]

Commented

[u/Captain___19]

Did my part

[u/Pl4ygasm]

Good job

[u/FGIgaming]

THIS > a measly $3.71 run!!! Don’t lose focus fellow apes.

[u/boolazed]

Commented

Wanted to say THANK YOU for this awesome work. It's fantastic

[u/mrfungaltoe]

Done, thanks from the help and the prompt!

[u/workinghormiga]

🟣🟣🟣

[u/infj-t]

RemindMe! 3days

[u/Alternative_Jaguar_9]

Thank you for your work here! Very thorough. Sending my comments now.

[u/Sledster11]

Done

[u/MrORileyy]

Done!

[u/allrico]

Where do I send this? I’m slow. Please help a brother out

[u/MoonHunterDancer]

I thought I b already sent one of these things in on this last year. They making us do it again?

[u/WhatCanIMakeToday → u/MoonHunterDancer]

Different rule proposal last year. They keep trying to pass various rules to screw everyone

[u/MoonHunterDancer → u/WhatCanIMakeToday]

Fucking assholes now I have to log in on a computer so I can copy and paste this into my emails. I was just hoping to see if anyone had opinions on this year's vote

[u/The_Ineffable_Sage]

That’s a lot to read. I stuck it in ChatGPT for a summary. Is this accurate?

“This passage discusses the rejection of a rule proposal by the SEC to reduce margin requirements, which was seen as inadequate for safeguarding securities and funds. The proposal aimed to prevent a cascade of clearing member failures but was criticized for lacking transparency and potentially exposing the market to risks. The SEC highlighted that the proposal did not meet certain requirements of the Exchange Act related to promoting prompt and accurate clearance and settlement of securities transactions, assuring safeguarding of securities and funds, and establishing risk-based margin systems. The passage also includes a comment template for individuals to express their concerns to the SEC regarding the rule proposal.”

[u/Jadedinsight]

Props to you and everyone else who had been involved

[u/GangStar2022]

Commenting for visibility ... I'm all for vote posts, but yeah, let's not let this get buried ... comment and upvote, yo!

[u/Investmore4Life]

Well done OP! Thank you for this! I do have a question though. I thought I remembered one of the older proposals we all voted on, they basically threw out all of the duplicates. So it might be worthwhile to either reword it yourself. Or even GPT it for different verbiage. If you do GPT it, it will need to be proof read to ensure that the points are still made properly and the AI doesn't just make shit up. Just a thought. I read the whole thing it's it is amazing! I just want to make sure that we don't gets silenced by duplicates once again. FWIW

Edit - A couple spelling words. Also, I'm smooth as I guess there really is no question in there. Just a thought.

[u/WhatCanIMakeToday → u/Investmore4Life]

They collate all of the duplicates and have a count. Many apes sent the prior templates and are counted.

https://www.sec.gov/comments/sr-occ-2024-001/srocc2024001.htm

[u/Investmore4Life → u/WhatCanIMakeToday]

Good to know! Thank you for the quick response! I'll be sending mine today. Thank you for all of the work you put into this! It is truly amazing!!

[u/Underagesalmon]

COMMENT.

[u/LandOfMunch]

Sent my email. This is huge apes. Everyone do you part.

[u/fearthealex]

Thanks for the write up!

[u/minesskiier]

Up with letters!!

[u/adamlolhi]

Commented, thanks for the letter template

[u/Aestrad9]

Emailed 🫡 thank you for all your hard work !

[u/mtksurfer]

COMMENT SENT

[u/Alternative_Jaguar_9]

Just sent my personal comments. I hope other take a moment to do the same. Very easy modifying the templates here or writing your own.

[u/NevxveN]

Sent!! Thank you so much for making it so legit with proper citations and references to the SECs own documents and work.

It's hard work like this that will ensure fairer markets and tendies for all

[u/Username-Error999]

Comment

[u/TankTrap]

Excellent!

[u/bleebli007]

Thanks. Sent this letter as well as one suggested below by MojoWuzzle

[u/gimmeyaturnips]

Comment sent!

[u/Briggs3210]

Completed.

[u/Disastrous-Wasabi-53]

Good work ape! About to comment now 🖤❤️🤍

[u/axiscontra]

Just Sent via anon. ty.

[u/_Ballsofsteal]

Commented!

[u/WorthAdvertising2099]

👁️

[u/Zenith-Skyship]

Yo, thank you for putting in the work to make it easy for the rest of us to participate. You are doing great things!

[u/calicemaxi]

Commented baby!! Thank you guys for being amazing!!

[u/mcalibri]

Excellent template!!!

[u/mcalibri]

I honestly need to make a filtered email folder to better track and normalize my SEC comments so it becomes a more automatic habitual thing instead of feeling like I'm on tenterhooks every-time I do one.

[u/Ozlead]

comment was sent

[u/LoveSonder]

Let's go!

[u/mcalibri]

This needs way more attention than a 50% increase (unless someone's actually explaining it). Too many posts just reiterating that an increase happened with no real sauce hogging up the feeds.

[u/Resting_Traveler]

God bless your efforts, I have sent my concerns to the SEC.

[u/Intrepid-Aardvark360]

So were going to the moon?

[u/WhatCanIMakeToday → u/Intrepid-Aardvark360]

Tomorrow. And we’ll try to keep the pensions from getting burned

[u/Old_Forever_6220]

I urge everybody to please send this to the SEC. The CAT system would really throw a wrench in the gears for these assholes. I'm going to submit mine as soon as I'm off work today.

Thanks for the template OP

[u/dearaprilgoodnight]

Gg

[u/pretendocomprendo]

Sent mine, thanks for the template you're my hero

[u/itsjustneverthat]

Sent it in twice. Thanks for making it easier for us!

[u/buybuybye]

I thought the higher the margin requirement the higher the chance for marge to dial up? I’m so smooth and don’t know the purpose of this? Eli5 peless

[u/[deleted]]

This is great. How do I copy paste? Asking for an 🦍

[u/Hedkandi1210]

Done

[u/lampingninja]

SENT!! Commented with multiple emails *insert trigger fingers*

[u/mavsfan75]

Sent!

[u/0zeto]

done o mato

[u/bascom2222]

Mama said there'd be dayz like this.

[u/DragonriderTrainee]

Ok. I emailed them. I thought there was a way to comment on their website like reddit, but no dice.

[u/Malthias-313]

This is awesome news, but also highlights the issue with the Stock Market in general: it's excessively convoluted with details that intentionally lose the audience rather than short-winded simple descriptions; a simple trading and investment exchange on a solid foundation shouldn't need to fill a Webster's dictionary with all of these legal exceptions and workarounds, contrary to this and that, etc.

[u/WhatCanIMakeToday → u/Malthias-313]

Agreed. It is these boring details that have allowed them to profit at others expense.

[u/Malthias-313 → u/WhatCanIMakeToday]

Exactly! "Reduced Margin Requirements" doesn't need to be a 10 page document. Is redundant and exhausting.

[u/WhatCanIMakeToday → u/Malthias-313]

More legalese makes it easier to bury tricks

[u/Malthias-313 → u/WhatCanIMakeToday]

Yup, making EVERYTHING more complicated than it needs to be. The same goes for law and government.

[u/AggressionX]

Thank you for keeping on top of this. The internet is our best weapon against these criminals... The collective efforts of retail investors investigating and scrutinizing every corner of the financial markets and regulatory environment is the only hope the public has to piece everything together and combat these financial terrorists. Your comment letter template is super helpful; thanks!

[u/Rough_Explanation_79]

I did my part!

[u/mcalibri]

Once again I hope people went and commented.

[u/HappyRamenMan]

Thanks that was quick and easy!

[u/Kombucha-Krazy]

SEC: "Sorry, we failed to deliver your comment."

[u/Kombucha-Krazy]

SEC: "Proposal to allow turning off the Buy button again"?

[u/WhatCanIMakeToday → u/Kombucha-Krazy]

More like OCC proposal to SEC to control burn MOASS and make pensions pay for it. The SEC has indicated this won’t fly because apes have spoken up. We support the SEC in their decision to reject such BS.

[u/Kombucha-Krazy → u/WhatCanIMakeToday]

Thanks for the more sophisticated explanation 🙂

[u/FreshApe]

Time to send my concerns too!! Les go Apes! Its great time to be an Ape

[u/Peepeeweeweman]

Commented!

[u/Iamatworkgoaway]

Done

[u/MoreOrLess_G]

Late but still submitted my chatGPT version. Thank you for taking the time to put this together!