Letter on Listed Options Transactions

OCC submitted this letter on behalf of the U.S Securities Markets Coalition to the staff of the Federal Reserve Board (FRB) as a follow up to a meeting with the FRB staff on the impact of the risk weighted capital rules on the listed options market. In the letter, we provide details regarding typical trading practices in the listed options market. This information relates to our observation, discussed at the meeting, that the risk weighted capital rules may be particularly ill-suited when applied to the risk-limited trading strategies that characterize the listed options market. We then offer further thoughts in the letter regarding the potential for interpretive relief.