Aug. 09, 2022
August 9, 2022 I oppose the proposed OCC rule change of SR-OCC-2022-803. The OCCs risk mitigation/liquidity management functions is appropriately delegated among its members. This proposal, while drafted to suggest that there is non-bank demand to participate in the exchanges of member collateral for cash, fails to adequately take into account the risk to the non-bank entities, specifically, pension funds. Simply put, in a volatile market where OCC members may be called upon to liquidate non-cash assets to meet liquidity demands, the best use of cash for pension funds may be to acquire those assets, not to subsidize the bad bets made by OCC members. The OCC members have had themselves to regulate and monitor their collective market risks. The beneficiaries of pension funds have no such watchdogs to assess the risks that this proposal would let those funds sign up for.