Subject: SR-OCC-2022-803: WebForm Comments from Josh S. Timpleton
From: Josh S. Timpleton
Affiliation:

Aug. 10, 2022



August 10, 2022

 Good day,


Please note that I oppose and recommend the SEC reject this SR-OCC-2022-803, 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.


Under no circumstances should the OCC have access to pension fund and insurance company money because a Clearing Member is about to default.

\"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.


Thank you.