Dear Sir or Madam, I am writing to oppose the implementation of SR-OCC-2024-001. It is my understanding that the implementation of this rule will allow the OCC to decide who is, in practice, exempt from margin requirements and who must abide by them. This amendment undermines the entire purpose of margin requirements, where the decision is a binary matter of being over leveraged or not. If the OCC can arbitrarily decide a body is exempt from margin requirements, it allows institutions to trade with impunity, in essence rewarding their lack of responsibility. It bears asking what the purpose of laws that are not implemented nor enforced? To maintain the illusion of a fair and free market? When in reality, institutions face zero risk nor repurcussion for unsuccessful positioning. Furthermore, this rule change begs the question of where the liability will be placed by the OCC in a scenario where liability must be apportioned, but not to their favoured actor? It is clear that this rule change can only serve to make the markets less equitable and more partisan, and ultimately hostile to all those not favoured by the OCC. Yours faithfully, Johnathan Persimon