The proposed rule change presented by the Options Clearing Corporation (OCC) represents a severe challenge to the integrity of fair and orderly markets, and it must be vehemently opposed. Allowing the OCC to unilaterally reduce margin requirements for clearing members facing default risks is akin to institutionalizing fraud and moral hazard on a systemic level. The lack of transparency, evident in extensive redactions of critical information, is reason enough to dismiss this proposal outright. Without full public disclosure, meaningful review and accountability become impossible. This secretive behavior behind closed doors only exacerbates public distrust in the financial system's fairness. Moreover, the revealed details of the proposal are deeply troubling. The OCC is effectively blaming regulators for not permitting it to weaken its own risk controls sufficiently, absurdly seeking authorization to expose itself and the entire system to increased failures. This contradicts the very purpose of a self-regulatory organization tasked with safeguarding market integrity. The proposed ability to waive margin calls for undercapitalized clearing members is a bold attempt to privatize profits while socializing losses. Disregarding risk models that dictate higher requirements constitutes financial malpractice. Clearing members engaging in reckless behavior that jeopardizes their solvency should face the consequences rather than having risks conveniently mitigated, as proposed by the OCC. Fundamentally, this rule formalizes an unjust "rules for thee, but not for me" approach, directly opposing the SEC's mission. Shielding clearing members from margin calls unfairly shifts long-tail risks onto other investors who cannot simply wish them away with procedural maneuvers. Even more alarming is the acknowledgment that a single clearing member default could trigger a systemic cascade, endangering the entire OCC. This highlights the dangerously overleveraged and undercapitalized nature of these firms. Instead of addressing this vulnerability, the OCC proposes granting itself more flexibility to adjust risk parameters for its dysfunctional members, perpetuating the "too big to fail" mentality that eroded public trust after the 2008 financial crisis. The argument that reducing margins could prevent defaults overlooks the fact that managing exposure is solely a clearing member's responsibility. Codifying moral hazard to such an extent contradicts the OCC's mandate as a Systemically Important Financial Market Utility tasked with maintaining stability. This proposal undermines financial resilience intentionally. Equally disingenuous is the new "skin in the game" capital contribution imposed on the OCC after the GameStop frenzy exposed inadequacies in its models. Now, an entity knowingly courting insolvency risk demands even looser safeguards, aiming to compel liquidity backstops from pensions and insurers. This manipulative rule-making verges on criminality, jeopardizing the savings of millions in a bid to privatize profits while socializing losses. There are no valid grounds for the SEC to approve such a blatant amplification of systemic risk. It disregards the prudent responsibilities expected of a SIFMU, fails to safeguard investors, ignores public interests, neglects transparent governance, and undermines loss-bearing requirements. This proposal epitomizes the flaws in modern finance's reliance on moral hazard and socialized risk-taking. Rather than enabling this reckless behavior, regulators must: 1. Enforce higher margin requirements proportionate to the risks faced by clearing members. 2. Subject the OCC to external audits and oversight as a genuine fourth line of defense. 3. Assign loss-bearing responsibilities below clearing members' skin-in-the-game. 4. Establish a credible process for promptly resolving insolvent clearing members to prevent the spread of toxicity. 5. Distribute systemic vulnerability across a decentralized market structure without centralized points of failure. In an ethical system, risky investments should be backed by appropriate capital, not shielded by secretive waivers that harm the public. This proposal represents a flagrant abandonment of regulatory duty and warrants outright rejection. The SEC must uphold its principles by unequivocally dismissing it and steering markets toward genuine accountability.