Feb. 8, 2024
To whom it may concern, I appreciate the opportunity to allow my voice to be heard in expressing concerns over these regulatory proposals. As a US citizen heavily invested in the stock market, I reject this proposal for the following reasons: This does not help in controlling risk. This would act as a temporary containment procedure, but will increase risk in the long term. This will result in a greater systemic risk in the future. This is the equivalent to treating cancer with a band-aid. If the criteria is met, institutions and individuals will play riskier bets knowing they "will still be saved." This will encourage more investors and institutions into riskier positions. This promotes extremely bad trading behaviors and practices. As a result, more future programs will be required to control the ticking time-bomb of risk caused by this rule proposal. To properly resolve the issues in the current market, instead of this rule, you need to update margin requirements to need more collateral to mitigate shortfalls. In your own document, you state you expect a 99% shortfall. To lower that risk, you need to increase margin requirements and force institutions to deposit more collateral. What this current proposal instead is trying to do is essentially letting these institutions "off the hook" because they have too much expected shortfall. Please take a sincere evaluation over these concerns, as well as the concerns of all the retail investors. Truly yours, - Michael.