As an update to its application to be recognized as a Qualifying Central Counterparty, OCC submitted a comment letter on November 16th to the European Commission supporting their draft regulation to push back the effective date of the EU Capital Requirements Regulation from December 15, 2016, to June 15, 2017. The proposed delay would afford the EC and the U.S. Securities and Exchange Commission more time to negotiate an equivalency determination for the SEC's CCP regulatory regime. Without the delay, OCC's clearing members affiliated with European banks or other European financial institutions would be subject to significantly higher capital charges under the EU Capital Requirements Regulation.