Thank you for the opportunity to express my thoughts about the proposed rule change described in SR-OCC-2024-001 34-99393. This proposal effectively requests that the OCC be able to use a lower risk setting (rather than the previously used high risk model) to calculate brokers' margin requirements (demanding they post lower than previously demanded cash) in periods of high volatility in options trades. The implicit rationale being that, imposing higher margin requirements on these brokers risks fire sales of their assets to satisfy margin requirements, that in turn destabilises markets. While the appeal to avoiding destabilising markets (which affects everyone and is therefore necessary to avoid at all costs!) has an irresistible logic, it avoids the necessary conclusion; that brokers who sell massive amounts of call contracts (to make money on them if these stay out of the money) which subsequently (and I would argue, realistically given all market factors that their buyers are aware of) run heavily in the money, should only be able to do so if they have put aside a commensurate amount of money to be able to buy the contracted shares when people exercise their call options. The argument therefore revolves around what is a prudent amount of margin requirement that is required as the level of risk to them increases. A frankly laughable amount of "backtesting" (carried out by "the industry") has been cited as the justification for adopting this proposal but I would suggest an actual recent episode be more instructive. As the GameStop report revealed, the margin requirement was unaffordable for several brokers, as evidenced by the fact that margin requirements had to be waived. This proves that risk management had not been prudent enough. The situation was only "resolved" not because they were adequately capitalised to meet their obligations but rather, by these brokers going Position Close Only; with share holders, of a stock that was rapidly rising, feeling compelled to sell, thus lowering the price for those who were short shares to be allowed to buy at lower prices. The effect being, the brokers avoided capital loss, shorts avoided infinite loss, other clearing members avoided having to bail out these risk-taking brokers, but the shareholders and call holders were not able to obtain full value for their positions. If these brokers were left to fail, the obligation would fall to other clearing members - this would serve to focus minds, to mitigate systemic risk, in a way that this proposal cannot achieve. I suggest this is as it should be, as a deterrent to brokers who ignorantly or greedily fail to exercise adequate risk management, hoping to capitalise from retail investors who they afford no such margin requirement grace. This proposal, I fear is just another move in the direction of even more asymmetry of opportunity from retail investors towards those who already enjoy great advantage, and use it recklessly. Rather than decrease systemic risk this proposal ultimately increases it. Many thanks, Claire Schofield