To Whom It May Concern, I am writing to express my serious reservations regarding the proposed rule issued by the Office of the Comptroller of the Currency (OCC). I vehemently oppose this proposal and do not support its approval. Lack of Transparency: The OCC’s rule proposal suffers from a severe lack of transparency. The redaction of critical details and supporting information prevents meaningful public review and hinders the ability of stakeholders to provide informed comments. As such, I contend that this proposal should be rejected solely on the grounds of inadequate transparency. Unfair Marketplace: The proposed rules create an inequitable marketplace for market participants, particularly retail investors. While the OCC consistently waives margin calls for Clearing Members by reducing their margin requirements, other investors are held to stricter standards. This disparity places retail investors at a disadvantage, exposing them to the consequences of long-tail risks without commensurate protection. Risk Management and Too Big To Fail: The OCC justifies the proposal and its special margin reduction procedures by citing the potential risk of a single Clearing Member default triggering a cascade of defaults. However, this rationale does not absolve Clearing Members from their responsibility to prudently manage portfolio risk. Allowing them to operate without strictly defined margin requirements effectively designates them as “Too Big To Fail,” which is an untenable situation. In light of the above concerns, I urge the OCC to reconsider this proposal and take necessary steps to enhance transparency, promote fairness, and ensure robust risk management practices. Sincerely, Michael Stone