Subject: SR-OCC-2022-802: WebForm Comments from Stephen Hildrew
From: Stephen Hildrew
Affiliation:

Aug. 3, 2022


 August 3, 2022

 Hello, I am an individual retail investor and I do not support this rule.

This rule is stating that the OCC wishes to create new products and sell them to buyers in order to access \"liquidity\" (cash) in order to cover member defaults. However, the terms written into this rule are extremely one-sided and places the OCC at a distinct advantage over its buyers.

 The buyer would be obligated to enter into transactions even if OCC had experience a material adverse change, such as the failure of a Clearing Member.
Translation: The buyer MUST give OCC more money even if a member defaults. The buyer has no choice in the matter.

 OCC would have the ability to substitute any Eligible Securities for purchased securities in its discretion by a specified time
Translation: OCC is allowed to exchange any asset for any other asset to give to the buyer. The \"conditions\" for this exchange are ONLY managed by OCC itself, so the buyer may end up with a completely different asset that they did not intend to purchase.

 OCC would require that it would not be an event of default if OCC suffers a \"material adverse change\".
Translation: OCC can never default, even if it cannot return cash or assets to the buyer, essentially changing the definition of a default.

The approval of this rule would allow the OCC to contaminate the American financial system with the fallout of bad bets made by the OCC and its members, which should have been prevented with better risk management and their own collateral. The OCC should cover its own obligations and not attempt to use this rule to write one-sided agreements to pass the impacts of their member defaults onto the rest of the market.