My Esteemed Colleagues at the Securities and Exchange Commission, Please allow me to extend my gratitude for affording the privilege to proffer my observations on the matter of great import encapsulated in SR-OCC-2024-001 34-99393, under the title "Proposed Rule Change by The Options Clearing Corporation Concerning Its Process for Adjusting Certain Parameters in Its Proprietary System for Calculating Margin Requirements During Periods When the Products It Clears and the Markets It Serves Experience High Volatility." As a humble retail investor, I find myself beset with numerous apprehensions regarding the aforesaid proposition. My disapproval of its sanction is rooted in the paucity of transparency prevalent in our financial realm, as conspicuously exemplified by this specific rule proposal, among others. The ostensible opacity, particularly in the redactions adorning Exhibit 5 and the supporting details concealed in Exhibit 3, serves as an impediment to public scrutiny. It renders the proposal impervious to meaningful review and public commentary, thereby warranting its categorical REJECTION on these grounds alone. The imperative of public review assumes heightened significance when considering the accusatory stance adopted by the Options Clearing Corporation (OCC) against U.S. regulators. The OCC, in its Proposed Rule, lays blame at the feet of U.S. regulators for their reluctance to mandate the adoption of prescriptive procyclicality controls, as embraced by their counterparts in other jurisdictions. Given the potential manifestations of procyclicality in augmenting margin during periods of market stress, the repercussions could imperil the financial stability of Clearing Members and, by extension, the OCC itself. The OCC's designation as a Systemically Important Financial Market Utility (SIFMU) necessitates an unwavering commitment to transparency, given the reverberations its failure could unleash on the U.S. financial system. This rule proposal, seemingly crafted to shield Clearing Members from the perils of onerous trades by endorsing reductions in margin requirements, introduces a precarious dynamic. The OCC's acknowledgment of systemic risk owing to the insufficient capitalization and over-leverage of Clearing Members underscores the fragility of the current financial framework. A single Clearing Member's default, stemming from inadequate risk management amid heightened volatility, could potentially cascade into a systemic financial crisis. In layman's terms, the precarious wagers of a single Clearing Member could precipitate a calamitous financial maelstrom, given the collective risk exposure of Clearing Members. The OCC's proposed solution to this conundrum rests on the implementation of "idiosyncratic" and "global" control settings, ostensibly aimed at mitigating the risks associated with specific factors. However, the frequency of employing these measures—over 200 instances in less than four years—raises questions about their purported idiosyncrasy. Granting reprieves to Clearing Members by repeatedly reducing their margin requirements creates an asymmetrical playing field, disadvantaging other market participants, including retail investors, who are left to grapple with the ramifications of long-tail risks. The fundamental premise of these rules engenders an unfair marketplace, wherein Clearing Members are shielded from the consequences of their risky endeavors, while other investors face the full brunt of market dynamics. It is incumbent upon us to REJECT this rule proposal, insisting on a regime of strictly defined margin requirements that treat all investors equitably. Moreover, the proposal introduces an inherent conflict of interest within the role of the Financial Risk Management (FRM) Officer. Tasked ostensibly with safeguarding the OCC's interests, the FRM Officer, under the proposed framework, paradoxically becomes a rubber stamp for reducing margin requirements to forestall Clearing Member failures. This undermines the protective function of margin collateral collected by the OCC and, by extension, jeopardizes the stability of the financial system. In light of these concerns, I urge you to consider the following modifications: 1. Increase and rigorously enforce margin requirements in line with the risks inherent in Clearing Member positions, fostering responsible risk management. 2. Institute external auditing and supervision as a fourth line of defense, akin to the four lines of defense model for financial institutions, coupled with enhanced public reporting for transparency. 3. Amend the Loss Allocation waterfall to prioritize Clearing fund deposits of non-defaulting firms before OCC's own pre-funded financial resources, fostering peer accountability and minimizing the risk of bailouts. I am grateful for the opportunity to articulate my concerns, for in the pursuit of a fair, transparent, and resilient market, the collective interest of all investors converges. Yours Sincerely, James