Subject: SR-OCC-2022-803
From: Ian Miller
Affiliation:

Jul. 25, 2022

 



I became aware of OCC filing SR-OCC-2022-803 to change the rules the OCC must follow regarding disclosures and funding of its liquidity facility. 


You can read public commentary and thoughts about it here: https://old.reddit.com/r/Superstonk/comments/w7zy4c/occ_filing_of_advance_notice_expanding_nonbank/ 


This proposal is absolutely antithetical to the safe and stable operation of US markets. 


The most egregious request is at the end: requesting to change the rules regarding advanced notice has zero public value, and lots of value to the OCC if it's trying to cheat the public. There could be no clearer example of a self-serving request in advance of a market-wide implosion. The OCC wants us to think that this risk is low, but every suggestion based on their actions, including this current filing, suggests the opposite. 


The remainder of the request is equally problematic and contrary to public interests. They propose using pension funding first, before putting the funds of the OCC members at risk. This is revolting! A public bailout must not come before the first parties have been liquidated. This is what happened during the GFC of 2008, and our failure to hold the individuals accountable (financially and criminally) who actually made the investments is why we are facing these same problems again. 


Please do the right thing for the American public and deny any and all aspects of SR-OCC-2022-803. 


Failure to do so will create a larger bubble to pop when the next substantive market correction comes, as well as set the scene for a recurrence in 10-20 years.