Dear SEC, I am writing to express my strong opposition to the proposed rule change outlined in SR-OCC-2024-001, filed by The Options Clearing Corporation (OCC) concerning its process for adjusting certain parameters in its proprietary system for calculating margin requirements during periods of high volatility. While I understand the intention behind the proposal is to mitigate procyclical margin requirements and ensure stability across the markets OCC serves, I am concerned that the implementation of such measures could inadvertently encourage riskier behavior among market participants. By potentially lowering margin requirements during volatile periods through the application of "high volatility control settings," the proposal may create a false sense of security among clearing members and their clients, leading them to undertake greater risks under the assumption of reduced financial safeguards. Margin requirements serve as a critical risk management tool, ensuring that market participants have sufficient skin in the game to cover potential losses. By adjusting these requirements in response to market volatility, we risk undermining the very foundation of market stability and investor protection. The ability to swiftly increase margin requirements in response to market conditions is essential for maintaining the integrity and liquidity of the clearing system, especially during periods of stress. Furthermore, the proposal's reliance on OCC's internal assessments and proprietary systems for determining when to adjust margin settings introduces a level of opacity and potential for bias that could disadvantage certain market participants over others. The lack of clear, objective criteria for these adjustments may lead to uncertainty and uneven application of the rules, potentially harming investor confidence and market fairness. In conclusion, while I appreciate OCC's efforts to enhance its margin system and address procyclicality, I believe that the proposed rule change in SR-OCC-2024-001 may lead to unintended consequences that could exacerbate rather than mitigate market risks. I urge the Commission to consider these concerns carefully and reject the proposal in favor of maintaining robust, transparent, and consistent margin requirements that protect all market participants and uphold the stability of the financial system. Thank you for considering my comments on this matter. Regards, Kashyap