Aug. 10, 2022
August 10, 2022 I am a member of the public, and am aware of OCC filing SR-OCC-2022-803 The filing requests a rule change the OCC must follow regarding disclosures and funding of its liquidity facility. The requested changes are harmful to US markets they request changing the rules regarding advanced notice, which has no value to the public, and substantial public harm. All of their actions suggest the risk for a crash is large ($23.8B large) and growing. It is unfair that the OCC can gain an advantage by proposing that an alternative to selling Clearing Member collateral to manage a member default, through increasing the risk of the public through accessing cash from pension funds and insurance companies. If a member of the public goes into default, they have no say as to what market conditions their collateral is sold off to in order to meet it's obligation and as such the OCC should be held to the same standard. The SEC has a moral obligation to deny SR-OCC-2022-803 in its entirety. Failure to do so will create a larger bubble to pop when the next market correction, just like 2008 did for 2022