Aug. 09, 2022
August 9, 2022
I am a member of the public wanting to share my opinion on OCC filing SR-OCC-2022-803. The filing requests to change the OCC rules regarding disclosures and funding of its liquidity facility. These changes are harmful to US markets and individuals. Changing the rules regarding advanced noticewhich has no value to the publicwill cause substantial public harm.
Only a dishonest OCC can benefit: if they plan to follow the rules, there is no need for this change at all. In addition, they request a bailout package for the individuals who took on high-risk bets, which encourages such behavior in the future. All of their actions suggest the risk for a crash is large ($23.8B large) and growing, and unless they are allowed to bear the full financial and criminal consequences for their behavior, it will only continue to happen.
The SEC has a moral obligation to deny SR-OCC-2022-803 in its entirety.