Subject: Opposition to Rule
From: Chris Smith
Affiliation:

Feb. 8, 2024

SR-OCC-2024-001 34-99393 

I vote no for this rule proposal because it does not help with any risk control it just temporarily contains it and adds to it in the long term. 

it creates a greater systemic risk in the future 

This encourages bad behavior and encourages people to be in the risk area because they know when the criteria is met they will be saved and play riskier bets.. 

Instead of this rule I highly suggest you update margin requirements to need more in case 

Within the rule proposal it is stated that there is a 99% expected shortfall. 
You should figure out a way to lessen the shortfall of rather than let them off the hook for the bad bets that they have made. If retail investors were in the same position we would be margin called instantly.