Aug. 10, 2022
August 10, 2022 As an educated member of the public, I am aware of proposed change: SR-OCC-2022-803. This filing from the OCC requests permission to expand their access to liquidity in pension funds due to Clearing Member default, which increases risks to pension funds. Pension funds are well known to be underfunded so exposing pension funds to losses at the OCC due to Clearing Member default would only increase the risks for more pension fund losses. This proposed rule change effectively bypasses the purpose collateral requirements by investors gambling in the options markets today. Should they default on those options exposures, then the collateral required was not sufficient to cover the risk of the investor. Allowing access to pension funds for the sake of liquidity is the equivalent of robbing an entire people just to satiate the gambling habits of a single individual. As 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. Taxpayers footing the bill for bad financial investments should not happen again like it did in 2008. This rule is completely absurd and only serves the purpose of shifting risk from an individual investor or investment firm onto taxpayers and people that have been putting their money into a vehicle that is supposed to be safe. Please reject this rule.