Aug. 3, 2022
Hello, This comment is related to SR-OCC-2022-802 34-95236 titled "Notice of Filing of Advance Notice Related to a Master Repurchase Agreement as Part of The Options Clearing Corporation’s Overall Liquidity Plan". I believe this rule is unfair and needs a lot more clarification before serious further consideration. It seems the OCC is seeking additional liquidity in the event of a member default and it's undoubtedly true that more liquidity is 'more helpful' when managing a member default, the details in this MRA are horribly under or un-specified. The following terminology, quoted directly from the proposed change: "certain additional provisions tailored to help ensure certainty of funding and operational effectiveness." Serve as evidence that there is NO evidence such a rule is needed or at least none that matters to me, as an individual investor. If these large institutions are seeking out back-channel avenues to resolve their insolvency crises then I would ask that this proposed rule change NOT BE ACCEPTED, as no such exceptions would be afforded to smaller investors and the process of accounting for such such counterparty risks are a crucial part of what keep our free market healthy. To exempt larger players in this space from performing due diligence with their trades simply stacks the odds further in their favor and as a result, makes the supposedly free market a place where success can only be found with special regulatory exemptions. Thanks for your consideration, Rolando