April 20, 2022
This rule change appears to be an attempt by members to bypass current obligations. It is most obviously an attempt to alleviate the strain caused by members taking great risk and trying to avoid the consequences of their actions. By no means should the rule change be allowed. This is clearly an attempt to try another route after their previously failed attempt with rule change 2021-010. It would be an egregious offense to fair market performance to implement this rule change. For the sake of the people who would be negatively affected by this change, it MUST NOT BE APPROVED.