Subject: File No. SR-OCC-2024-004
From: Alan Mills

I am writing g to express my concern over a a SR OCC-2024-001 34-100009. This proposal appears to bring even more risk into the system by allowing clearing members to delay capital allocations because of a heated market in one or more stocks they choose to trade in by changing margin requirements during certain periods. This allows clearing members additional time to possibly increase losses and put every clearing member at more risk. The current system forces them to allocate capital at times of higher stress which protects all members and the system. Allowing members to “get out over their skis” even in times of higher stress would assume the member knows the end result and will have the ability to cover even more potential losses. I recommend not passing the new proposal.