TL;DR: Sus wants OCC to act as its personal insurance/rainy day account in the event they get caught at the Casino betting more than the house. They are avoiding margin call just as much as Citadel. If 003 passes, they not only get margin called along with Citadel, they are subject to the exact same panty raid that will befall Kenny and all his belongings in his golden kingdom. Sus only has a kingdom on paper, and as long as the rules stand as currently written. If you change the rules, they are no longer players in the game. Their comment seeks to stop that.

In the hours and days following my post Susquehanna is Sus going up, we have learned, in short, that they are V sus.

Then I read the Susquehanna International Group comments on SR-OCC-2021-801 🧐 Which was passed today.

So let’s talk about OCC 801 first. What it DOESN’T do is margin call anybody. Let’s be clear about that. The margin call rule is the NSCC801. The 801 of today is not a standalone catalyst. What it does do is open for discussion the rule (003) that will build a firewall of protection around OCC’s other members; i.e. protection from the flames of a burning hedgie(s).

Members of the OCC pay into a community pot. If any player gets sent directly to jail, the OCC draws from this free parking loot bag and pays up the damages, as a hedge of protections and form of insurance for all the “innocent” members. OCC is the custodian of this account.

Now, members still have access to however much they’ve contributed to this pot, but what SR-OCC-2021-004 does, is starts talking about an auction process for liquidating Kenny boy’s assets to pay his debts instead of pulling from OCC funds first, which is a big statement. That, in my opinion, will be the catalyst.

Ok so I’m getting sidetracked. We came here to shit talk Susquehanna.

They commented on 801, but what they really decided to bitch about was SR-OCC-2021-003.

But... I thought we were talking about OCC-801? Why moar numbers??? 😭

Because think of it this way. OCC-801 is Pikachu. OCC-003 is Raichu. So 801 is the first evolution of the rule. (Which was approved today!) The middle of this evolution is the discovery period wherein the public can make comments. THIS IS WHERE SUS COMES IN. And eventually the evolution completes with the passing of rule 003/Raichu. This is extremely generalized but you get the idea. The fact that Sus commented on 801 means that 003 is now delayed until May 31 (DO NOT GIVE A SECOND THOUGHT TO THIS DATE OUTSIDE OF ITS INTENDED MEANING). This rule was set to automatically take effect in April.

So Susquehanna International Group filed a comment on 801. That means the train is fucking halted until the issues raised are addressed. What are the issues raised? I won’t bore you with their unnecessarily big words. Basically;

Sus wants OCC shareholders to get burned the worst and carry the most consequences (and pay the repercussions) in the event of a member default, instead of the member themselves being the one burned to the ground. Remember that free parking pot of money? Sus claims that violates one of OCC’s rule - 17A(b)(3)(F)- and pretty much is under-regulated and carries too much incentive for the OCC to keep in the current account, as is. (Essentially saying it becomes a net positive on their books, thus benefitting the shareholders by making the OCC appear more fiscally valuable on paper.) Sus claims the money should rightfully be moved to a more restricted, controlled account, which does not contribute to the OCC books, and only pays out in the event of a member default.

This comment is a desperate attempt to find issue where there should be none. They attempt to pin it on the fact that SLDs would raise the fees per transaction. What they’re really saying if you read between the lines is, please don’t pass this rule. If you pass this, we r fuk 2.

All this comment did was perhaps bring about a minor amendment to 003 before its passing. It also kicked that can down the road to May 31 before it will automatically pass, but I have no doubt it will enact much sooner. OCC is lining up their hedge of protection from the hedgie fire by approving the rules in this way. They are literally building a moat around their castle.

In my opinion, the OCC is frantically trying to get their moat built before the fire rages. That's why we're seeing stale price action and volume right now. They are delaying the inevitable while they get these ducks (rules) in a row. Signing off on the 003 rule is essentially saying "ok we've done all we can to prepare. We're ready." They have duct tape over the hole in the titanic. Or maybe it's flex seal. Either way, the titanic is still going down.

Remember the scene in the Big Short where Dr. Burry is trying to exit his positions but the bank won’t call him back for days because they are setting themselves up a lifeboat before allowing anyone else on. This is precisely what we are witnessing now.