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2 changes: 1 addition & 1 deletion SR-OCC-2025-801/README.md
Original file line number Diff line number Diff line change
Expand Up @@ -123,7 +123,7 @@ Investors simply shouldn't need to watch their brokers withdraw their profits fr

[^oi-token]: _See, e.g.,_ collapse of a cryptocurrency which employed off-exchange market-making deals to exclusively purchase outstanding digital assets, _available at_ https://youtube.com/clip/UgkxkjSFXLQtP9WnDp8Q7dd39_cGHwvosbaM. While this example showcases the inevitable collapse of an artificially-inflated price, perhaps staff might concur that the events leading up to the PCO event showcase the inevitable growth of a solvent corporation's shares after artificial deflation. Should the OCC's margining systems face risk of Wall Street insolvencies as contemplated _infra_ note 44 at 4?

[^rh-occ-cleaing]: Robinhood discloses their self-clearing business affiliate in their Form S-1 at F-15, first Form 10-K at 24, and even the OCC lists them as a clearing member mid-way through 2020; _available at_ https://www.sec.gov/Archives/edgar/data/1783879/000162828021013318/robinhoods-1.htm, https://www.sec.gov/Archives/edgar/data/1783879/000178387922000044/hood-20211231.htm, and https://web.archive.org/web/20200701202545/https://www.theocc.com/Company-Information/Member-Directory, respectively. As further described _infra_ note 82, the company claims these business practices made their service faster and more reliable. Indeed, presumably they had more discretion over Tim's position given their direct management of its risk exposure.
[^rh-occ-clearing]: Robinhood discloses their self-clearing business affiliate in their Form S-1 at F-15, first Form 10-K at 24, and even the OCC lists them as a clearing member mid-way through 2020; _available at_ https://www.sec.gov/Archives/edgar/data/1783879/000162828021013318/robinhoods-1.htm, https://www.sec.gov/Archives/edgar/data/1783879/000178387922000044/hood-20211231.htm, and https://web.archive.org/web/20200701202545/https://www.theocc.com/Company-Information/Member-Directory, respectively. As further described _infra_ note 82, the company claims these business practices made their service faster and more reliable. Indeed, presumably they had more discretion over Tim's position given their direct management of its risk exposure.

[^rh-cyber]: _See, e.g.,_ the Commission's $45 million fine for inadequate data security, electronic communications, and Reg SHO reporting, _available at_ https://www.sec.gov/newsroom/press-releases/2025-5. Ms. Countryman, your exceptional order, enabled by exceptional staff efforts, highlights one such case of gross cybersecurity vulnerabilities at ¶ 7. Later in ¶¶ 74–79, the order explains that millions of investors had their information stolen in an attack practically identical to one such breach over three months prior which resulted in a specific corrective action to block the type of software employed in the theft.

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