Subject: File No. S7-09-19
From: Scott A La Botz

December 4, 2019

As a private retail trader, I request the Commission to please correct the margin discrepancy placed upon the SSF products by going to a risk based margining as utilized by clearinghouses on other SSF products worldwide. To have this product restricted by unfair margin treatment would be a loss to the trading community as well as to me personally.

Thank you for your consideration.