BOX submitted a comment letter on February 19, 2015 (“BOX Letter”) in response to the Options Clearing Corporation’s (“OCC”) rule filing to implement a new 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”). The BOX Letter raised concerns about the structure of the recapitalization, the burden on competition and asked for clarity on additional issues, including the Plans duration, estimated dividend payments, cessation of the clearing member refund, available alternatives, current shareholder equity figures, how end user customers will benefit and how the plan will align the interests of shareholder exchanges and clearing members.
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BOX’s Second Comment Letter On SR-OCC-2015-02
Date 05/03/2015