Subject: File No. SR-OCC-2024-001
From: Chance Furgerson

Dear SEC and OCC, I am writing with grave concern over SRO filing number: SR-OCC-2024-001. This self-regulating body is proposing codifying their right and ability to adjust margin requirements for volatility and perceived idiosyncratic risks. The stated benefit being, avoiding procylicality in stressed market conditions. However, I believe the SEC and OCC are overlooking the principles of fairness, competition, and even the basic tenets of capitalism. If a market player has their margin requirement rapidly increased due to idiosyncratic risk, then that risk must be absorbed by the participant and the OCC and that clear the contracts and trades to begin. In the name of avoiding procylicality, you are in fact encouraging and supporting risky, reckless behavior by large market players that know you will ease their margin requirements when they make a mistake. You need to ask yourself if the rules you write are making the market fairier and safer for all Americans, or are making the market safer and easier for the select few wealthiest insitutions in our nation. By the most basic rules of logic, idiosyncratic risk and market volality should INCREASE margin requirements, not DECREASE them. You get what you reward, and rewarding market participants to build a "Too Big to Fail" trade position only leads to privatizing the profits and socializing the losses among Clearing Members. To the SEC in particular, I would like to call your attention to a particular line from the OCC filing - "Written comments were not and are not intended to be solicited with respect to the proposed change....". I find this deeply alarming and disturbing that the OCC is not interested in receiving or publishing commentary from their Clearing Members. I disagree with the OCC's right to be a SRO without Federal management, but surely you can see the problem when this organization does not even make room for transparency and discussion in their filings? Sincerely, Chance Furgerson