Aug. 09, 2022
August 9, 2022 This is related to SR-OCC-2022-803 and rather sneaky at that. SR-OCC-2022-803 The basic of request MRAs while SR-OCC-2022-802 changes the rules around Said MRAs. Similar to SR-OCC-2022-803 the occ wants to raise capital from non members sources. There is no reason to raise capital from outside sources except someone or some party within the OCC making very bad decisions and ignoring advice on risk avoidance. The occ should increase the insurance pool sourced from the occ own members and hold its members accountable. If there are no consequences to making bad choices then how do members learn from their mistakes? As a self regulatory organization the OCC should be held to a higher standard in order to earn that trust. This proposal lowers the bar and has no place in the actions of a self regulatory organization. Theres also a section near the bottom that basically says: if a member defaults, of which is going to cause the OCC and other members to lose too much money, the OCC can just not declare it a default. Again this is not something a self regulatory agency should should even consider. See my first paragraph on learning from our mistakes through consequences. This proposal along with SR-OCC-2022-803 should be struck down and the OCC held responsible for keeping its member risks to a minimum. It seems pretty clear if the OCC is afraid of a systemic risk, then its privilege of self regulation should be reassessed. Thank you.