Dear Mr. Fields:
BOX Options Exchange (“BOX”) appreciates this opportunity to comment on the above-referenced filing made by The Options Clearing Corporation (“OCC”) concerning a proposed capital plan for raising additional capital that would support the OCC’s function as a systemically important financial market utility (the “Proposed Capital Plan” or “Plan”). BOX appreciates that the OCC needs to raise additional capital to comply with new Securities Exchange Commission (the “SEC” or “Commission”) requirements. However, BOX believes additional clarity on the Plan is needed.