Subject: Concerning rule SR-OCC-2024-001 34-99393
From: Garret Combs
Affiliation:

Feb. 8, 2024

Concerning rule Sr-OCC-2024-001 34-99393.
I do not agree this rule will benefit the retail investor or anyone with a marginal investment in the markets.
It does not help with any risk control but adds to it in the long term with more risk
in the future.
And it encourages bad behavior from participants with no accountability for making bad bets.
Instead we should be updating margin requirements with a 99% expected shortfall  currently that number should be no more than 10% with an updated margin requirement.
Thank you for your time .
Sincerely Garret Combs

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