April 30, 2011
To Whom it May Concern,
SR-C2-2011-008 is a very welcome, and long overdue, proposal. Two points expressed by an earlier comment are quite valid though: 1.) what was the rationale for the NSX being abandoned? To use the NSX as an example of success seems a bit of paradox if it ultimately was abandoned. 2.) If C2 launches this program, then it makes sense for the CBOE contracts to follow suit in a similar program AND be fungible.
The rationale of the AM program is no longer valid furthermore I believe bringing C2 (and hopefully CBOE) options to PM settlement would lead to greater liquidity in a current marketplace that has been dispersed into dark pools, crossing mechanisms, and deep otc markets. Furthermore there are many other vehicles present at the close now. An increasingly important player being the creation/redemption mechanism of ETF shares.
Still an active participant in the options marketplace, I find AM settlement, more than anything, a nuisance. I think you would find a welcome reception for this pilot program. Given it being a pilot program, give it ample evaluation and if it introduces more complexities, simply abandon it (again).
I see very little reason not to allow this to exist as a pilot program.
Trader, San Francisco, CA