This rule seems to further distance the US markets from the concept of fairness, equity, and general economics. In lieu of enforcement of currently existing rules, penalties, and general features of a fair and free market, the OCC seems to be trying, instead, to protect large entities, shirk responsibility, and avoid any concept of fairness or supply and demand. Further, this rule will effectively increase the problem that it seeks to address. Attempting to adjust parameters for margin requirements during periods of high volatility effectually create such adjustments on a permanent, or calculable, basis. Institutional traders and entities could anticipate and calculate the leeway they would enjoy in their margin requirements in such a manner as these exceptions being 'priced-in' to the thoughtless and dangerous actions that have influenced the OCC to create this rule. In essence, why should they avoid highly volatile positions when they know the margin requirements will be eased when volatility truly becomes a problem. This is encouraging market participants to actually seek out high volatility positions in order to trigger the uniquely favorable exceptions to what should otherwise be a normal, standard, and unyielding rule. Where the justification for this rule is to avoid wide ranging market impact, idiosyncratic risks, and to promote market stability, it will most certainly have the opposite effect. As we've seen since the repeal of the Glass-Steagall act, institutional market participants will seek out catastrophic risks to the general public and the market at large (specifically with deposits and citizen's assets as far as GSA is concerned) in order to qualify for specific exceptions meant to avoid the repercussions that they will then be incentivized to cause. If failure is not an option for this sort of investing, then why should they hold back from taking on excessive amounts of risks? This does not discourage the type of behavior it seeks to address, it encourages it. By not allowing margin calls to occur, investment strategies will get more risk-prone, larger, and ultimately develop into more catastrophic scenarios that cannot be contemplated or controlled by the authority that this rule seeks to create. The FRM officer, specifically, seems to have an inherent conflict of interest in the desire to protect the OCC and the market at large. Further, the proposal cites "only one risk factor [that] had a 2-day expected shortfall short coverage under 99% while on idiosyncratic control settings that would have been above 99% on regular control settings...." The justification for this role is, by its own admission, insufficient to justify the risk it poses to the market at large. If the OCC feels that this rule is necessary, then redactions must be removed in order to appropriately make those considerations by those it affects and seeks comment from.