Subject: SR-OCC-2022-803: WebForm Comments from Alexander
From: Alexander
Affiliation:

Aug. 11, 2022



August 11, 2022

 Please note that I oppose and recommend the SEC reject this SR-OCC-2022-803, Notice of Filing of Advance Notice Related to an Expansion of The Options Clearing Corporation's Non-Bank Liquidity Facility Program as Part of Its Overall Liquidity Plan.

As the OCC is a Systematically Important Financial Market Utility (SIMFU), it should be able to adequately manage risk by restricting the margin and risks taken by its clearing members. It is the responsibility of the OCC to stay ahead of potential issues involving risk and limiting the liability exclusively to its own members. If a clearing member is about to default, this shows the risk was not managed properly to begin with and it should be the responsibility of the OCC and its clearing members to find the necessary liquidity or allow the member to default as a consequence of its risk seeking actions.

Under no circumstances should the OCC have access to pension fund and insurance company money because a Clearing Member is about to default.

Thank you for your time and consideration,

Alexander