Subject: SR-OCC-2022-803: WebForm Comments from Nathan Rosenstock
From: Nathan Rosenstock
Affiliation: CEO, Crafty

Aug. 10, 2022



August 10, 2022

 Imagine you are a hard working American whose retirement depends on a pension guaranteed (or so you thought) by the government. Youve made sacrifices in your youth so that you and your family will be able to enjoy life a little bit more later on. Youve invested in your future.

Behind the scenes and unbeknownst to you, a Clearing Member defaults. The default is driven primarily by irresponsible risk taking, and now the OCC has access to your pension fund and can access the liquidity to cover that default.

Does that seem fair? Does that seem like a system you would want to invest your future in? Does that sound American? No.

With this filing, the OCC is requesting permission to expand their access to liquidity in pension funds to cover Clearing Member defaults. This increases risk to pension funds who we already know to be historically and materially underfunded. This proposal would exacerbate the risk for pension fund loses, and worst of all, this would seriously erode the publics trust and confidence in the markets and the governments role in maintaining free and just financial systems.