Aug. 09, 2022
August 9, 2022 Good Evening, The purpose of maintaining Clearing Member collateral is to ensure that its' obligations are going to be meet regardless of what happens in the market especially when under volatile market conditions. When you remove the collateral and allow for the OCC to diversify its base of liquidity among providers among banks and non-bank, non-Clearing Member institutional investors, such as pension funds or insurance companies you expose everyone else in the whole market to the risks of these individuals. This is what lead to the collapse in 2008. SR-OCC-2022-802 should not be approved because it exposes wall streets risk to the main street individuals. If a clearing member is not acting in good faith and fails it should be allowed to fail and face the consequences rather than liquidate pension funds. Instead of pension funds being at risk the collateral that is associated with the risky bets should be liquidated. The clearing members should not be making money be allowed to pay for their los ses with either taxpayer money or pension funds or other people's money. This proposal states that it would reduce systemic risk. It does not reduce systemic risk, he only protects that member and puts everyone else in the market at risk and responsible for their default.