Aug. 09, 2022
August 9, 2022 What he said: Alex Mazakas (sorry for copy pasting dear Alex) Hello SEC, As a retail investor and United States citizen, I strongly condemn the proposed passage of SR-OCC-2022-802 titled \"Notice of Filing of Advance Notice Related to a Master Repurchase Agreement as Part of The Options Clearing Corporations Overall Liquidity Plan\". I urge you to do the same. The OCC now believes that it should seek to expand its liquidity facility to increase OCC's access to cash to manage a member default. The OCC already has access to a lot of sources for cash so they want to add to these sources a master repurchase agreement (\"MRA\"). The OCC will require the buyer (e.g., bank or pension fund) to enter transactions as long as neither are in default even if the OCC is exposed by a Clearing Member going broke. This rule would allow the OCC to do this within 60 minutes, even in the event of a default by a Clearing Member or a market disruption. This custom feature means that even if a buyer (e.g., bank or pension fund) fails to deliver purchased securities, OCC can \"mitigate risk with respect to a particular transaction, without declaring an event of default with respect to all transactions under the MRA.\" If a bank (e.g., Credit Suisse) is participating in an MRA with the OCC to buy securities and give cash to the OCC, then Fails To Deliver those securities back to the OCC because they're broke, the OCC will just agree this isn't an event of default. Most loans have had cross-default provisions that state if someone defaults with one lender, they automatically are in default with all lenders. Most loans have this to protect the lenders. Doing so would ultimately shift the financial fallout from those responsible for taking excessive risks to the American taxpayer. OCC members are responsible for taking financial risks and should be held accountable in times of Market Disruption. No member is too big or important to avoid default. No one is above the law. This proposed rule is ethically and fiscally wrong and you know it. On behalf of all American taxpayers and international retail investors who believe in the Integrity of the American market, do the right thing and reject SR-OCC-2022-803. Thank you for your time. Most Sincerely, Alex Mazakas