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2017 OCC Comment Letters

Securities and Exchange Commission, November 14, 2017
OCC Plans Minimum Cash Contributions to Clearing Fund
In a November 14, 2017 rule filing with the U.S. Securities and Exchange Commission (SEC), OCC proposed to establish a minimum cash contribution requirement for its Clearing Fund in order to increase the amount of highly liquid resources available to OCC to account for extreme scenarios that may result in liquidity demands exceeding OCC's current Cover 1 liquidity resources, as calculated under the current historically-based methodology, and provide for a more consistent level of cash resources in its available pre-funded financial resources.

Senate Finance Committee, November 13, 2017
OCC and U.S. Securities Markets Coalition Oppose Wyden Amendment in Letter to Senate Finance Committee Members
OCC and the U.S. Securities Markets Coalition (Cboe, Nasdaq, and ICE/NYSE) wrote a letter to the Senate Finance Committee sharing their opposition to an amendment filed by Senator Wyden to the Chairman's Mark of the Tax Cuts and Jobs Act that would add the language of the Senator's proposed Modernization of Derivatives Act of 2017 (MODA). OCC and the Coalition believe MODA would impose significant and unfair tax costs and complexities on taxpayers who use exchange-traded options, and such costs would greatly harm the exchange-traded options markets, reduce liquidity, and increase trading costs, with the repercussions felt in the underlying stock markets as investors and other market participants would be unable to allocate efficiently the risks associated with owning stocks.

The European Commission, April 27, 2017
OCC Comment Letter Encourages European Commission To Extend Transitional Periods for Own Funds Requirements for Exposures Related to CCPs
In connection with its application to be recognized as a Qualifying Central Counterparty, OCC encourages the European Commission in a letter to extend transitional periods for own funds requirements for exposures related to CCPs. As noted in a prior comment on the last implementing regulation that extended the transitional periods to June 15, 2017, OCC agrees with the concerns expressed in the draft regulation that European institutions could be harmed and markets could be disrupted if the transitional periods are not extended to December 15, 2017.