Aug. 09, 2022
August 9, 2022 To Whom it May Concern, Please note that I oppose, most vigorously, and recommend the SEC reject SR-OCC-2022-802, Notice of Filing of Advance Notice Related to a Master Repurchase Agreement as Part of The Options Clearing Corporations Overall Liquidity Plan. Philosophically, it seems categorically opposed to the idea that many smaller individuals shouldn't be forced to pay for the mistakes of the privileged few in taking risks well known to them, and resulting in predictably negative outcomes. It amounts to a bailout, for an immense firm necessitated by an inadequate risk assessment and mitigation regime. When committing resources like public money, and shifting massive amounts of liquid capital around, it behooves us to make sure we do not do it to benefit one perversely motivated entity at the expense of the larger system, and the public. The doctrine of \"Too Big to Fail\" is a failure at producing the conditions it is ostensibly designed to promote. Such doctrine only allows self interested entities to hold the entire economy hostage for benefits undue to any participant. To hand out money in inflative conditions, to entities that already helped create them and benefitted with the Federal Reserves laisses faire attitude to distributing liquidity in the name of the health of the credit markets, seems entirely self defeating. Some of these very same entities that have benefitted from some the conditions and precedent set since the 2008 financial crisis make some of their most risk prone investments through the instruments offered by the OCC, and now the public is asked to finance these very same derivative bets? This should be out of the question. Under no circumstances should the OCC have access to pension fund and insurance company money because a Clearing Member is about to default. I believe this comment speaks to what is needed, and not the proposal put forward in SR-OCC-2022-802. \"The OCC should be looking to enhance its margin requirements for existing participants as well as demanding collateral within 60 minutes of an expected volatile event in the stock market. To echo Chance Fergerson's response to this: The OCC has an obligation to manage the risk of its participants and the investments traded through the OCC. At no point, should a financial contagion scenario be allowed to ensnare others, rather it should be absorbed by those government agencies and participating members who knowingly engaged in a shared default agreement.\" Thank you for your time and consideration. Note these comments are made with no malice for any particular firm, but seem needed by grace of similar proposals continuing to be regularly proposed.