SIFMA Submits Comments to SEC Relating to OCC’s Proposed Capital Plan

SIFMA submitted comments to the SEC on the proposed capital plan sought in a Notice of Filing of a Proposed Rule Change and in a Notice of Filing of an Advance Notice, both of which were filed by the Options Clearing Corporation (“OCC”).

SIFMA stated that it supports the appropriate capitalization of the OCC and other systemically important financial market utilities. However, SIFMA explained, it is “vital” that the enhancements to the OCC’s capital structure not “detract from or destroy the OCC’s successful history of operating as an industry utility for the benefit of market participants.” According to SIFMA, the proposed capital plan risks that very thing, and turns the OCC into a profit-making venture for selected securities exchanges.

SIFMA stated that the OCC should be encouraged to engage in a “public and transparent process” to ensure that it is able to obtain and maintain additional capital on terms and at prices that are “fair, reasonable, and efficient.”

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