Subject: SR-OCC-2024-001 34-99393
From: justin garre
Affiliation:

Feb. 8, 2024

I appose rule SR-OCC-2024-001 34-99393. The rule temporarily contains risk but adds to it during the long term. If this rule were to pass it would create a greater systematic risk in the future. This rule encourages risker bets because they know if the criteria it met they will be safe and continue to place riskier bets. 

There's a 99% expected shortfall amount and to reduce the percentage margin requirements must be updated to need more. We need to lower the expected shortfall percentage not ignore it with this rule. 



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