Dear SEC, Black box models that assess VAR and margin requirements are a detriment to the industry in USA. To be a leader of the global industry and to usher in a 21st century marketplace, you need to be forward thinking. A more reasonable solution to this issue would be mandatory buy-ins to reduce margin risk. If firms cannot manage their risk, they shouldn't be operating in the USA financial markets. Thank you, S MSc Economics Colorado School of Mines & Series 3