It's evident that transparency and consistency are lacking in the OCC's risk management processes. The redaction of specific details and the frequent adjustments of idiosyncratic control settings raise concerns about fairness, effectiveness, and systemic risks, particularly during high volatility. Moreover, the reliance on GARCH parameters and the discretionary power of the FRM Officer may lead to inadequate risk coverage and potential conflicts of interest. Concentrating significant decision-making authority in a single individual increases the risk of abuse of power and introduces uncertainty. Additionally, the proposal undermines the first line of protection outlined in OCC's default rules and procedures, potentially exposing it to financial risks. Overall, the rule would weaken risk management strategies and raise questions about the sustainability of OCC's approach. This proposal is unjust.