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Comment for Industry Filing 22-001

  • From: Matthew Paul
    Organization(s):
    City Assets LLC

    Comment No: 66961
    Date: 3/16/2022

    Comment Text:

    General Comment - have been on the platform for a little over a year. Have always found the people behind it to be diligent, methodical, honest and open. The platform technology itself is highly reliable and usable.

    In specific terms, the low liquidity on the platform leads to wide spreads and long times to fill. Which is not good either as a seller of those options, or as a buyer - in fact it increases risk on both sides because it's difficult to hedge effectively. So, I am a big supporter of adding margin as long as it is not allowed to get out of hand, and this proposal does seem to guard against that. Buyers would be able to open more complex, hedged positions, and some sellers would be able to leverage large holdings to do the same. For myself, I would not expect to use any margin in the longer term, although some short term flexibility might be useful in the short term.

    All in all, a good proposal by reliable and honest people. Hope it is approved.

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