Comments Regarding ZRIN: 1210-ZA25 (the "BIC Exemption Proposal") and RIN: 1210-AB32 (the "Fiduciary Proposal")

On behalf of the U.S. Securities Market Coalition, OCC submitted this letter addressing two related proposals issued by the U.S. Department of Labor: the "Fiduciary Proposal" and the "BIC Exemption Proposal." OCC and the Coalition said these proposals would take away the current ability of investors to use exchange-traded or listed options in IRA accounts. The letter noted that almost 25 percent of volume (and perhaps even more) on U.S. options exchanges is attributable to individual investors; that IRA account owners are increasingly using listed options in their accounts with the ultimate goal of increasing their retirement savings, and; approximately 15 percent of individual investor volume currently comes from IRA accounts. OCC and the Coalition offered recommendations to the DOL proposals.

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