The Options Clearing Corporation

Summary: The Options Clearing Corporation (OCC) generally supports the proposed regulatory capital rule, specifically praising the treatment of client-facing STM derivatives and the net basis for the noninterest component of the business indicator. However, the OCC requests specific clarifications and revisions to ensure that the rule does not discourage the use of central clearing, including requests for functional equivalence for certain non-linear index contracts and agreement-specific allocation factors for cross-margining.