Aug. 10, 2022
To Whom it May Concern, I oppose and recommend the SEC reject SR-OCC-2022-803 of the OCC's Overall Liquidity Plan. There are two points from 803 that caught my eye. These suggest that the OCC may extend its reach to additional sources of collateral to cover member defaults. This is a concern because the OCC is, instead of holding its members accountable, interested in finding an additional source to cover insolvency and/or defaults. " In the event of a Clearing Member default, OCC would be obligated to make payments, on time, related to that member’s clear transactions. To meet such payment obligations, OCC maintains access to cash from a variety of sources, including, a requirement for members to pledge cash collateral to OCC and various agreements with banks and other counterparties (“liquidity facilities”) to provide OCC with cash in exchange for collateral, such as U.S. Government securities. " " Based on such considerations, OCC now believes that it should seek to expand its liquidity facility to increase OCC’s access to cash to manage a member default. " Members who are not held accountable will continue to risk resources they neither own or are responsible for. This has cascading ramifications as OCC members who make risky bets will simply be bailed out and will continue causing harm. No, the OCC must hold its members accountable. Thank you very much for your time and consideration