January 30, 2012
Safe Haven Advisors, LLC (SHA), is a Massachusetts-based SEC-registered investment advisor specializing in products and services for single stock risk management. Our firm's focus in this practice area led us to appreciate the importance of long-dated equity options and swaps that are traded infrequently over-the-counter by a relatively few market participants. This traditional market is difficult and expensive to access for individual investors and smaller institutions.
SHA supports and urges approval of the OCC's Proposed Rule Change, as Modified by Amendment No. 1 Thereto, Relating to the Clearance and Settlement of Over-the-Counter Options (File No. SR-OCC-2011-19).
Our reason for supporting this proposal is that it establishes an important structural framework by which clearing may be accomplished for a variety of equity-linked options and swap transactions. We urge the prompt extension of this framework to accommodate clearing of over-the-counter options on other issues and of equity-linked swaps that are not offered for trading by exchanges. Together, these products form a rich set of standardized investment management tools that enable investment advisors and managers to craft customized solutions for investors.
Once these products are made available on a standardized basis for clearing through OCC, larger numbers of advisors and liquidity providers will be able to participate. The availability of clearing will definitely lead to easier access and reduced costs, especially for smaller sized transactions. It should also lead to improved market transparency, although the rule is silent on that topic.
Thank you for the opportunity to comment on the proposed rule.