November 06, 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 (“Intraday Risk Charge”) that
would be applied to all clearing member accounts to help mitigate the risks arising from
intraday and overnight trading activity.

This letter is in addition to our previous comment letter dated September 2, 20253 where
STA made certain preliminary remarks and expressed its view that the Proposal impacts all
option industry participants including clearing members, agency executing brokers,
interdealer brokers, market makers, retail participants and their brokers. STA requested an
extension of the deadline to submit comments to enable us to gather broader industry
input including possible alternatives that could achieve the Proposal’s intended goals in a
more efficient manner. In the time since our last letter, we have solicited input and are
pleased to offer the below general remarks and recommendations.

Download the full comment letter here.