Feb. 8, 2024
Good Afternoon I vote no to rule-comments@sec.gov 34-99393, because it does not help in any Risk Control. It just temporarily contains it and add to it in the long term. It creates a greater Systemic Risk in the future. It encourages bad behavior and encourages more people to live in the Risk area, because they know if the criteria are met, they will be saved and continue placing Riskier Bets. Instead of this rule update Margine Requirement to need more in case it is needed. Remember they have 99% Shortfall. To reduce that to 10% or 5% they should be required to deposit more Collateral to lower this expected shortfall amount, and not let them off the hook because they made Bad Decisions. 99% Shortfall is Criminal and that should be addressed.