August 29, 2019
Dear Mr. Kirkpatrick and Ms. Countryman:
It is my belief that the margin requirements on Single Stock Futures should be on par with other risk based margin in today's markets.
Lowering the requirement to 15% will help but it will still be higher for many equivalent positions in the equity market when Portfolio Margin is used.
OneChicago has a unique product that has the ability to compete with other Exchanges with respect to swaps/EFP's and as such they should have equivalent margin requirements for similar type positions.
thanks,
Mike Ianni
Private Investor