Jan. 21, 2024
To SEC, The development of a robust volatility model is a difficult task. Instead of adjusting the existing mathematical parameters of a proven volatility model, a more reasonable approach or solution to this situation would be to require more collateral from participating members. Even if margin requirements temporarily surge, the participating members have resources at their disposal to secure such financing and should use them. For example, a line of credit and api to margin account that sends funds upon a draw request. This can be automated or artificially delayed 5-10 minutes to allow for verification on both ends. All proposed changes need to be forward looking, so we may operate in a 21’st century marketplace. Thank you. Scott Pollan, Professional Trader