May 4, 2024
Thank you for the opportunity to comment. The Proposed Rule fails to consider and produce margin requirements commensurate with risks as reducing margin for Clearing Member(s) at risk of default is blatantly illogical and nonsensical. Existing models predict increased margin requirements are required. The Proposed Rule is also heavily redacted, and the public does not have adequate opportunity to fully outline other objections. Please increase and enforce margin requirements commensurate with risk for Clearing Members instead of reducing. External auditing and supervision are paramount to protect the market. Thank you, Riley Giaquinto