OCC and the U.S. Securities Markets Coalition submitted a letter to the Department of the Treasury and the Internal Revenue Service addressing certain issues raised for listed options by the final section 871(m) regulations issued on September 18, 2015. In the letter, the Coalition acknowledges the tremendous effort that went into crafting the final regulations, but recommends certain clarifications and improvements to them as they apply to listed options to help lessen the compliance burdens imposed on broker-dealers. The letter includes a recommendation that the regulations permit the deltas of listed options to be determined based on the prior day's closing prices and permit broker-dealers and other parties to use end-of-day deltas generated by OCC.