Aug. 19, 2022
August 19, 2022 In its filing (Release No. 34-95326, File No. SR-OCC-2022-802), the Options Clearing Corporation (OCC) suggests a change to the OCC's liquidity in the unlikely event of a default of one of its Clearing Member organizations. Unfortunately, this proposal is unacceptable and it must be reworked by the OCC. Rather than to provide OCC with another vehicle for accessing cash to meet its payment obligations, OCC should execute oversight over its Clearing members in a way that would not let the unlikely event of a default of one of its members happen. It should perform transparent risk management analyses in a timely manner that would allow to classify the investment activities of its Member organizations 24/7 and make those risk classifications available to the general public. Rather than accessing pension funds in the unlikely event of an OCC Member default, formal chapter 7 or chapter 11 bankruptcy proceedings should be initiated.