Aug. 06, 2022
Retail has been blamed for destroying pension funds by Wall Street moguls recently. In regards to this proposed rule, it seems that blame was a scapegoat setup. This rule would expose pension funds to the same level of risk as options by institutions who willingly took that risk and lost. My real fear with this proposal is the following excerpt from pages 12-13: "The proposed change to the Non-Bank Liquidity Facility program to allow OCC to seek an aggregate commitment amount for up to the amount determined by the Board of the Directors from time to time would help OCC ensure the continued availability of its liquidity resources by providing OCC with the capacity to seek additional funding amounts on substantially the same terms, conditions, operations, and mechanics. In addition, the proposed change to the program would ensure that the approved amount would not be less than the currently approved amount of up to $1 billion. Because the proposed change preserves substantially the same terms and conditions as the MRA and the existing conformations, OCC believes that the proposed change would not otherwise affect or alter the management of risk at OCC." Not only is the OCC asking for unlimited access to pension funds (in order to escape the consequences of their own actions), they go on to make the ridiculous claim that this would not affect risk management as they are not taking any less money than before. As a working class citizen and retail investor, I believe the OCC already has more access to pension funds than it should. It should not be the responsibility of the working class to bail out Wall Street and the bad investments of millionaires and billionaires. As you are the Securities and Exchange Commission, your own stated mission is to " ...protect investors; maintain fair, orderly, and efficient markets; and facilitate capital formation. The SEC strives to promote a market environment that is worthy of the public's trust." I do not trust a market which is able to use retail's pension funds as an emergency piggy bank. I hope you agree with this sentiment and express this by refusing this proposal.