I am highly concerned about this "rule" passing. It gives the OCC the ability to do what children losing games do-- change the rules when things aren't going their way. I'm tired of cheaters getting bailed out. As a regular person, if I racked up credit card debt so high that I could not pay the minimum payment, I'm screwed, there is no bailout option in which the credit card company change the rules for me to keep me solvent. I dislike the lack of specificity regarding the "proprietary system for calculating margin requirements". Why are there 200 redacted pages in this document about how margin requirements are calculated? Why shouldn't the public have access to this knowledge? Seems like a convenient way to bail out cheaters or parties that have made bad decisions. I think that before this passes, it should have a public review given the OCCs importance as a SIMFU. Building on the earlier credit card analogy, it is important for clearing members to be accountable to margin obligations even during challenging market conditions. This sort of accountability discourages risky behaviors by clearing members which contributes to market stability. The OCCs measures should reinforce accountability, and ensure that clearing members meet their margin obligations since a clearing member default poses a significant credit risk to the OCC. Lastly, and in a similar vein to earlier mention of the lack of transparency in the proposed rule, there should be transparency in the use of "idiosyncratic" measures. There have been over 200 decisions related to idiosyncratic occurrences over the last four years. We (the public) need transparency and clarity regarding when idiosyncratic control settings are used. Without transparency, there is a high risk of selective application and lack of justification for the use of indiosyncratic control mechanisms. In short, I oppose this rule. Clearing members should be held accountable to margin requirements as this encourages effective risk management and promotes market stability. There is a significant lack of transparency in how marign requirements are calculated currently, and there is no reason that the public should not be able to review this sort of data.