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

On behalf of the U.S. Securities Markets Coalition and TD Ameritrade, Inc., OCC submitted a comment letter to the Department of Labor to address the testimony given by Gary Katz, President and CEO of the International Securities Exchange. The comment letter requests a revision of the BIC Exemption Proposal to add exchange-traded options to the list of permissible asset types, to clarify that education or other support that does not rise to the level of a recommendation under FINRA rules would not cause firms to be consider fiduciaries under the Proposal, and to clarify that the process firms required to follow under FINRA and options exchange rules to allow customers to trade listed options would not cause such firms to be considered fiduciaries under the Proposal.

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