I oppose the amendment. The proposed amendment by the Options Clearing Corporation (OCC) is a direct threat to maintaining fair and orderly markets and should be strongly opposed. Permitting the OCC to decrease margin requirements for clearing members nearing default is essentially promoting fraudulent and reckless behavior on a widespread basis. The absence of openness, with crucial data withheld from the public, provides sufficient grounds to dismiss this proposal immediately. Without transparency, effective oversight and accountability are impossible, undermining public trust in the financial system. The details that have been disclosed raise even greater concerns. The OCC criticizes regulators for their restrictions on loosening risk controls, seeking approval to increase vulnerability and potential failures across the system. This undermines the foundational role of a self-regulatory organization designed to preserve market integrity. The proposed provision to excuse margin calls for financially weak clearing members is a clear attempt to privatize gains while distributing losses to others. Overlooking risk models recommending higher requirements constitutes financial irresponsibility. Clearing members engaging in risky behavior should be held accountable, not have their risks dismissed repeatedly, as the OCC has done over 200 times in less than four years. This rule embodies a hypocritical "rules for thee, but not for me" approach, contradicting the SEC’s core mission. Protecting clearing members from margin calls unfairly transfers significant risks to other investors. The potential for a single clearing member's failure to jeopardize the entire OCC suggests severe overleveraging and insufficient capital reserves. Rather than mitigating these risks, the OCC seeks more freedom to adjust risk parameters for its troubled members, reinforcing the problematic "too big to fail" ideology. Lowering margins to avert a default overlooks that risk management is the responsibility of the clearing members. This proposal weakens financial stability and forces pensions and insurers to provide emergency liquidity. It is a blatant attempt to privatize gains while spreading losses, endangering the savings of countless individuals. There is no justifiable reason for the SEC to endorse such a perilous proposal. It overlooks regulatory duties, jeopardizes investor protection, neglects public interest, fails in transparent governance, and ignores the necessity of bearing losses. This proposal exemplifies the worst tendencies in modern finance towards moral hazard and collective risk-taking. Regulators should enforce higher margin requirements, subject the OCC to independent audits, reallocate loss-bearing responsibilities, promptly close down insolvent clearing members, and spread systemic risks through a more decentralized market structure. Risky investments should be adequately capitalized, not shielded by exceptions that detriment the public. This proposal represents a failure in regulatory obligations and must be categorically denied. The SEC should maintain its foundational principles and aim for a truly accountable market environment. Best regards, Brian