FIA agrees with the Options Clearing Corporation’s objective to better align Clearing Fund contributions with the stress exposures that drive its sizing and views the proposal as broadly consistent with international central counterparty practices.
FIA supports OCC’s proposal though some members questioned the sharp reduction in the margin‑based weighting and the potential overlap between Stress Loss Over Initial Margin and OCC’s stress‑based initial margin add‑ons, FIA does not see these concerns as undermining the overall merits of the stress‑aligned approach.
FIA recognises that a more stress‑driven methodology may increase contributions during volatile periods but supports OCC’s use of smoothing mechanisms, including the extended lookback and temporary freezing of weights.
Overall, FIA views the proposal as a constructive enhancement that improves fairness, strengthens incentives and better aligns Clearing Fund contributions with actual risk.
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