May 8, 2024
Dear Commission, I am commenting on this rule to support the SEC's decision to disapprove the Proposed Rule Change by the OCC concerning its process for adjusting certain parameters in its proprietary system for calculating margin requirements during periods when the products it clears and the markets it serves experience high volatility. I support the SEC's disapproval un this matter due to multiple issues with the OCC rule proposal. I do not support the approval of the OCC rule proposal, due to the path it creates for a less transparent and more inequitable market. The lack of transparency promoted by the proposed rule is concerning. This rule appears to be written to protect Clearing Members from absorbing the consequences of high risk trades. Changes in margin requirements must be treated skeptically. Margin requirements prevent these entities from taking on trades which should not be made due to the inherent risk. Reducing these requirements or changing the structure will permit ongoing risky trades and bets. The SEC has identified reasonable grounds for disapproval of the proposed rule change. _____________________________ Baskin L. Jones