Subject: File No. SR-OCC-2024-001
From: Mark Marcelis
Affiliation:

Feb. 9, 2024

Sent from Mail for Windows
The occ has software to push buttons to make changes to global settings. If the rule is passed the occ loses the ability to say we’re going to do this or not do this. It means every single time criteria is met all meme stock or short squeezes because it will meet this criteria. We want the occ to have full power of when this goes into effect. The occ let hedge funds off the hook for 20 billion dollars during the meme frenzy. You admitted this yourself. I vote no to this rule proposal. It has no risk control. Just makes it worse in long term. It creates greater systemic risk down the line. It encourages hedge funds to keep making riskier bets as they will be protected by this rule. Instead of this rule, update margin requirements to need more capitol because in your own document there is a 99% expected shortfall. They are your words from your own website. 
Mark R. Marcelis