To the Securities and Exchange Commission, I write to express my strong opposition to The Options Clearing Corporation (OCC)'s proposed rule change regarding the formalization of margin adjustment procedures during high volatility periods. While the intentions behind these changes may be to ensure market stability and clarity, the implications could significantly undermine financial stability and the integrity of market operations. **Concerns Over Financial Stability**: Introducing predefined adjustments for margin requirements during volatile periods risks embedding a moral hazard within our financial system. By signaling to market participants that margin requirements will become more accommodating in times of stress, we may inadvertently encourage riskier behaviors. This could lead to an accumulation of positions that, when unwound, might precipitate financial disturbances reminiscent of the pre-2008 era. The essence of market stability lies not in cushioning the fallout from risky bets but in ensuring such positions are responsibly managed from the outset. **Impairment of Price Discovery**: The proposed rule might delay critical market adjustments, as short sellers and others could exploit these more predictable margin adjustments to sustain untenable positions longer. **Opportunities for Regulatory Arbitrage**: Detailed, publicly known adjustments create a playbook for sophisticated entities to strategize around, potentially leading to market manipulation. This specificity not only invites gaming of the system but may also reduce the OCC's agility in responding to market anomalies, turning a tool meant for stability into a lever for instability. **Retail Investors at a Disadvantage**: The complexity of these proposed changes threatens to alienate retail investors further. The nuanced understanding required to navigate these adjustments is beyond what is reasonable for the average investor, potentially exacerbating the divide between institutional and retail market participants. Given these considerations, I urge the SEC to reconsider the approval of this rule. The path to genuine market stability involves measures that promote prudent risk management, transparency, and equal footing for all market participants, not rules that could potentially magnify the very risks they seek to mitigate. Kevin Carter