Aug. 22, 2022
August 22, 2022 To whom it may concern, This comment refers to: Release No. 34-95327 File No. SR-OCC-2022-803. OCC is obligated to make certain payments in the unlikely event of a Clearing Member default. It suggests accessing additional committed sources of liquidity, especially in market stress scenarios. OCC believes that it should seek to expand its liquidity facility to increase its access to cash by diversifying its base of liquidity providers to include banks and non-bank, non-Clearing Member institutional investors, such as pension funds or insurance companies. This measure would provide OCC with more potential vehicles that would OCC to expand the size of its liquidity facilities. This proposal is immoral and absurd. OCC must go back to the drawing board and rework its proposal. Rather than proposing to include non-Clearing Member institutional investors, such as e.g. pension funds or insurance companies, OCC should require its very own members to provide additional collateral to modify its current liquidity plan. In addition to an increase in required collateral from its member organizations, OCC is obligated to responsibly supervise and co-manage the increase in the stressed liquidity demands from its members. In order to give OCC greater capacity to source liquidity from external liquidity providers, OCC should actively consider expanding its liquidity sources to include high net worth individuals, such as General Partners of OCC member organizations. Sincerely, E. Barnett-Fecklesworth