Subject: SR-OCC-2022-802: WebForm Comments from Jesse
From: Jesse
Affiliation: Professor of Mathematics

Aug. 09, 2022



August 9, 2022

 This proposal does not make sense unless the OCC is afraid of a cascading default of its members. In particular, buyer's being obligated to enter contracts even if the OCC suffers a \"material adverse change\" is written purely to protect the OCC from irresponsible investments. This proposal should not be implemented. If the OCC fears that their members may default, then they should tighten their margin requirements for members, not force liquidity contracts to cover defaults.