Aug. 10, 2022
August 10, 2022 To Whom it may concern, As a member of the public, I'm aware of OCC filing SR-OCC-2022-803. This filing from the OCC requests permission to expand their access to liquidity in the form of Pension Funds and Insurance Companies, due to a Clearing Member default. This is unprecedented and would shift an OCC Clearing Members financial responsibilities to the American public and Insurance Companies. Pension Funds are well known to be targeted for collateral, as people who own these funds are forced to hold these funds for most of their lives and have no say in what these funds do. In this case, a Clearing Member default, it is the OCCs obligation to provide liquidity. If the OCC does not have the capital to meet their margin requirements, the OCC does not have the right to use Pension Funds and Insurance Companies as collateral. Pension funds are frequently used and guaranteed by government entities at the federal, state and local levels. This unfairly enables shifting risks from a Clearing Member default to taxpayers. Therefore, the SEC should deny this proposal. Risks to the OCC should be managed by the OCC and its Clearing Members neither the public nor taxpayers should pay for bank losses again. Thank you for your time and consideration.