Aug. 03, 2022
Hello, This comment is related to SR-OCC-2022-803 34-95327 titled "Self-Regulatory Organizations; The Options Clearing Corporation; Notice of Filing of Advance Notice Related to an Expansion of The Options Clearing Corporation’s Non- Bank Liquidity Facility Program as Part of Its Overall Liquidity Plan". This proposal is also seeking to expand liquidity facilities for the OCC. In principle, additional access to capital would reduce overall risk, but the question is: Where is the money coming from? The OCC already has access to LOTS of capital, now they want more? The proposal seems to be asking that the OCC can enter new agreements with orgs "such as Pension Funds and Insurance Companies." This, to be blunt, is quite suspicious and 'smells' wrong... Why is the OCC seeking additional money from Pension funds in event of "the failure of any bank, securities or commodities clearing organization, or investment counterparty to perform any obligation to OCC when due." This rule change seems to empower speculative OCC members to get further out on a limb with their finances and leave institutions with American Citizens' pensions the job of covering the bill, but only if things go poorly of course... This proposed rule change is literally a means of distributing risk between lower risk OCC members such as Pension/Insurance Funds and more speculative members. Without any complementary rule proposal for distributing rewards, I feel very strongly that this rule should NOT BE ACCEPTED. Thanks for your consideration, Rolando