To Whom It May Concern, I am writing to express my strong opposition to the Proposed Rule Change outlined in SR-OCC-2024-001, titled "Proposed Rule Change by The Options Clearing Corporation 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." The implications of this proposal are deeply troubling and pose a threat to the fairness, transparency, and stability of our financial markets. Lack of Transparency: The significant redactions in Exhibit 5 and accompanying materials hinder meaningful public review and feedback, which are essential components of fair regulation and market integrity. Accountability: The OCC's attempt to deflect responsibility onto U.S. regulators for not implementing stricter controls reflects a concerning lack of accountability and transparency within the regulatory framework. Systemic Risk: The proposal's emphasis on reducing margin requirements for Clearing Members disregards the systemic risk associated with potential failures, prioritizing short-term gains over long-term market stability. Conflict of Interest: The proposal formalizes a conflict of interest for the Financial Risk Management Officer, undermining the core principles of risk management and regulatory oversight. Inadequate Protection: By neglecting to enforce margin requirements commensurate with risks, the proposal exposes the OCC and other market participants to increased financial risk and shifts the burden of Clearing Member defaults onto non-bank liquidity facilities, creating moral hazards. Governance Clarity: The governance arrangements outlined in the proposal lack transparency and clear delineation of responsibilities, further diminishing trust in the regulatory process. Exploitation of Position: The OCC's exploitation of its position as a single point of failure and attempts to coerce approval of the proposal establish a dangerous precedent of self-serving actions at the expense of market integrity. Stronger Safeguards Needed: Instead of reducing margin requirements, the proposal should prioritize implementing stronger safeguards, external auditing, and transparent governance to mitigate systemic risks and protect investors. Immediate Action Required: Swift suspension and liquidation of Clearing Members when projected losses surpass certain thresholds are essential to prevent escalating issues and preserve market stability. Reducing Systemic Risks: Encouraging redundancy and resilience in financial markets is vital to minimizing systemic failures and avoiding bailouts that undermine market integrity. In conclusion, I urge you to reject the Proposed Rule Change under SR-OCC-2024-001. Safeguarding fair markets, protecting investors, and ensuring the stability of our financial system demand urgent action and comprehensive measures to address these critical concerns. Thank you for considering my objections.