Subject: SR-OCC-2024-001 34-99393
From: Edgardo Reyes
Affiliation:

Feb. 8, 2024

Good day, 


I have several concerns with this rule proposal as it interferes with transparency in the market, here are some comments: 


1. The process to adjust parameters for calculating margin requirements using a proprietary system (when the products that clear are experiencing high volatility is a big issue itself. 


2. Lack of details in this proposal without supporting information makes it difficult for the public to review, making this rule suggestion seem out of place or only benefiting the wealthy. 


3. The OCC is repeatedly waiving margin calls for clearing members/houses by repeatedly reducing margin requirements! The margin requirements should be strictly defined and followed. 


I oppose this rule proposal entirely. 






-Edgardo Reyes