Aug. 03, 2022
Good morning, I object to the proposals set forth in SR-OCC-2022-803. To me, a retail investor, the premise of these proposals is inherently flawed. The OCC should not need to look to non-members for liquidity. Else, what is the point in having member banks? If a member defaults, should the burden not remain internal to the OCC and other participating members? The concept of creating MRAs with unsuspecting pension funds is incomprehensible. It is nothing short of a bait and switch- legalizing robbery in broad daylight. As I interpret these proposals, they are asking permission to hand the bags of knowingly problematic positions to unsuspecting pension funds, insurance companies, and other non-members who have no way to know how problematic these positions may be. This is an OCC problem that should lead to an OCC solution. Perhaps the OCC should take a closer look to their member’s risk management procedures before passing the bill to unsuspecting and unrelated funds. I urge the SEC to reject these proposals, and reconsider why they may be necessary. Thank you for your time David Ellenberger