The Options Clearing Corporation (“OCC") appreciates the opportunity to submit these comments to the Commodity Futures Trading Commission (“CFTC” or “Commission”) on the above-referenced proposal (“Proposal” or “Proposed Rules”) under the Commodity Exchange Act (“CEA”). The Proposal would define the conditions under which a futures commission merchant (“FCM”) could permissibly treat separate accounts of a single customer as accounts of separate legal entities for purposes of certain Commission regulations (“Separate Account Treatment”).
As detailed below, OCC supports the Proposal with a minor modification to clarify the responsibilities of a DCO whose members offer Separate Account Treatment.