OCC, along with 10 firms, submitted a comment letter to the U.S. Securities and Exchange Commission (SEC) regarding the proposal to amend Rule 15b9-1 under the Securities Exchange Act of 1934. The proposal would amend the rule to require broker-dealers that engage in off-exchange trading and non-member exchange trading to become members of FINRA. Through its impact on options market making firms, the letter addresses the disproportionate impact the proposal will have on the options markets and investors in those markets. The letter offers alternatives for the SEC to consider with regard to the proposal's application to options market making firms should the SEC decide to move forward with it.