FIA submitted a comment letter in response to the Options Clearing Corporation’s proposed rule change to enhance its intraday margin framework by incorporating actual positions and prices throughout the trading day. The proposal aims to better address evolving intraday risk exposures, particularly in light of the growing activity in zero-day-to-expiration (0DTE) options.
FIA supports the proposed enhancements, recognizing them as a meaningful improvement over the current reliance on conservative, estimated add-ons such as the Intraday Risk Charge, which is based on historical lookbacks. While acknowledging the operational challenges involved, FIA encourages OCC to prioritize implementation of the new real-time portfolio revaluation process and to reassess the need for the IRC once the new framework is in place.
Read full response here.
