Feb. 5, 2024
To whom it may concern, I appreciate the opportunity to comment on this proposed rule. I do not support this proposal or the idea that margin requirements for certain market participants should be waived or reduced during volitile market conditions. Margin requirements are meant to expose and contain risk. If a participant cannot meet margin requirements the solution is to deleverage. If a Clearing Member or other participant believes they will fail margin requirements under certain market conditions they can slowly deleverage before those conditions occur. If margin requirements are felt to be too restrictive then propose to reduce requirements across the board in a transparent fashion that does not favor certain participants or cater to potentially over-leveraged positions. Waiving or arbitrarily reducing margin requirements encourages the maintenance and growth of unstable positions. Please hold Clearing Members accountable with transparent and orderly rules rather than entertaining a slippery slope towards infinite leverage. Sincerely, Lee Cunningham