Subject: SR-OCC-2022-803: WebForm Comments from
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Aug. 09, 2022



August 9, 2022

 This proposal seeks to expand liquidity for the OCC, but does so in a way that would create or increase systemic risk. The Non-Bank Liquidity Facility should not be expanded. While the OCC may need to look for additional liquidity it should do so within its syndicated credit facility. Expanding the Non-Bank Liquidity Facility would serve to create further risk among more parties, especially in the noted case of a member default. Specifically the OCC is looking to leverage pension funds which could negatively affect millions of Americans by putting their retirements at risk.