Comments Requesting Postponement of Final and Temporary 871(m) Regulations

OCC, on behalf of the U.S. Securities Markets Coalition, submitted a letter to the U.S. Department of the Treasury and the Internal Revenue Service, requesting a one-year postponement of the effective date of the final and temporary regulations issued under section 871(m). Since the promulgation of the regulations ten months ago, OCC's clearing members have been working to make the changes to their systems necessary to implement the regulations. Given the sheer magnitude of the approximately 850,000 unique options series that are available for trading and that would need to be reviewed each trading day to determine whether they are in-scope, as well as the cooperation that the regulations require among a wide range of market participants, OCC does not expect its members' systems will be operational by the January 1, 2017 deadline. OCC and the Coalition join other organizations in requesting the temporary, one-year postponement of the effective date of the regulations.

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