September 2, 2024

Ms. Vanessa A. Countryman
Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090

Re: Release No. 34-100664; File No. SR-OCC-2024-010; Margin Add-On Charge to Help
Mitigate the Risks Arising from Intraday and Overnight Trading Activity.

Dear Ms. Vanessa A. Countryman,

The Security Traders Association1 (“STA”) appreciates the opportunity to provide comments
to the aforementioned rule change (“Proposal”) proposed by the Options Clearing
Corporation, (“OCC”) to a margin add-on charge that would be applied to all clearing
member accounts to help mitigate the risks arising from intraday and overnight trading
activity. More specifically OCC proposes to capture the risks associated with overnight and
intraday activity by: (1) establishing an Intraday Risk Charge add-on, and (2) establishing
monitoring and escalation criteria for Clearing Members whose intraday activity exceeds
certain thresholds relative to its Intraday Risk Charge (“Intraday Monitoring Thresholds”).

Download the full comment letter here.