Subject: File No. SR-OCC-2024-001
From: Peter

The SEC has highlighted specific grounds for why this rule proposal should be disapproved. These reasons can be seen on the proposed rule change SR-OCC-2024-001 34-100009 on pages 4-5. 1) Section 17A(b)(3)(F) of the Exchange Act, which requires, among other things, that the rules of a clearing agency are designed to promote the prompt and accurate clearance and settlement of securities transactions and derivative agreements, contracts, and transactions; and to assure the safeguarding of securities and funds which are in the custody or control of the clearing agency or for which it is responsible; [Refer to 15 U.S.C. 78q-1(b)(3)(F)] 2) Rule 17Ad-22(e)(2) of the Exchange Act, which requires that a covered clearing agency provide for governance arrangements that, among other things, specify clear and direct lines of responsibility; and [Refer to 17 CFR § 240.17Ad-22(e)(2)] 3) Rule 17Ad-22(e)(6) of the Exchange Act, which requires that a covered clearing agency establish, implement, maintain, and enforce written policies and procedures reasonably designed to cover, if the covered clearing agency provides central counterparty services, its credit exposures to its participants by establishing a risk-based margin system that, among other things, (1) considers, and produces margin levels commensurate with, the risks and particular attributes of each relevant product, portfolio, and market, and (2) calculates sufficient margin to cover its potential future exposure to participants in the interval between the last margin collection and the close out of positions following a participant default. [Refer to 17 CFR § 240.17Ad-22(e)(6)] I am in full support of the reasons for disapproval provided by the SEC. I strongly oppose the proposed rule change SR-OCC-2024-001. Allowing these market makers to bail themselves out on taxpayer dollars to fix their own mistakes does not promote a fair and equal market for all. Thank you for reading.