SIFMA submitted comments to the Securities and Exchange Commission (SEC) on the Proposed Capital Plan sought in a Notice of Filing of a Proposed Rule Change and a Notice of Filing of an Advance Notice (together, the Notices) filed by the Options Clearing Corporation (OCC).

SIFMA supports the need for the OCC and other systemically important financial market utilities to be appropriately capitalized. However, SIFMA believes 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 the market participants who use the OCC’s clearing services. As described in the Notices, the Proposed Capital Plan risks just that and should not be approved.

Instead, SIFMA believes 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.