May 7, 2024
To whom it may concern, How exactly, from a regulatory standpoint, does this rule proposal pose to improve the form & function of America's financial markets? All I see are "too big to fail" institutions & clearing corporations begging for reduced margin requirements in order to mitigate their personal risk. What do these "Self Regulatory" Institutions have to hide? If this rule is instated, then the entities proposing the rule are mitigating their risk, without ever being liable. If institutions are allowed to change the rules, simply move the goal posts, to avoid default, then we have created an environment in our markets that is extremely susceptible to fraud & moral hazard. Financial institutions of this magnitude will cover their liabilities, and rig markets with impunity. This is done in a variety ways from naked short selling, failing to deliver, spoofing, pumping & dumping, banging the close, dark market swaps, cellar boxing, all designed to control price discovery throughout markets. The SEC's job is to regulate the most important financial markets on earth. Rule Proposals such as this is proof by itself that fraud is running rampant throughout our financial system. We need accountability in a free & fair financial market, not monopolized clearing corporations with "self regulatory" bodies. Thank you for your service as a regulatory institution of the United States of America. May justice ring true throughout the nation, and the free world. God bless America. -- Calvin Satterfield V