OCC Tweaks Margin Calls for Better Intraday Risk Control
Published Date: 6/2/2025
Notice
Summary
The Options Clearing Corporation (OCC) is updating how it checks the value of members’ portfolios during the day to make sure margin calls happen at the right time. This helps OCC better manage risks and keep things safe for everyone involved. These changes mainly affect OCC’s clearing members and aim to improve risk control without changing costs immediately.
Analyzed Economic Effects
6 provisions identified: 2 benefits, 2 costs, 2 mixed.
OCC shifts to near real-time IPL runs
OCC will replace its start-of-day revaluation with an Intraday Profit & Loss (IPL) process that revalues Clearing Member current positions with current prices every five minutes during regular trading hours. The IPL gives OCC authority to issue intraday margin calls based on current positions and prices while generally continuing to collect margin at a single collection time at or around 12:00 p.m. Central Time.
More calls overall, smaller average call size
OCC's one-year backtest (Feb 2024–Jan 2025) shows margin calls would rise by 34%, from 93 to 125 calls, and total margin call amount would increase from $6,448.7 million to $6,991.4 million. Average call size would fall by about 19.3% from $69.3 million to $55.9 million, the minimum call remains $500,000, and the largest call would be reduced by 21.8% to $682.7 million.
Key thresholds and STANS unchanged
OCC will not change the 50% intraday unrealized loss threshold for issuing intraday margin calls, will keep the minimum intraday margin call at $500,000, and will not change STANS margin calculations or ETH margin call procedures. Approval and escalation procedures for intraday calls (e.g., Executive Director or above; Senior Management after 1:30 p.m. CT) remain in place.
Exclusion for CME cross-margin accounts
The amended IPL process will apply to all margin accounts except cross-margin accounts in OCC's cross-margining program with the Chicago Mercantile Exchange (CME), because those accounts do not currently support intraday position feeds.
Implementation tied to Ovation launch
OCC will implement the IPL changes when its Ovation system becomes the system of record, planned for the first half of 2026 and no later than June 30, 2026, and will post an Information Memorandum at least two weeks before the implementation date.
Policy wording and term clarifications
OCC proposes to remove the phrase "start-of-day" from Margin Policy references and to replace the term "total risk charges" with "total margin charges" (which will continue to consist of expected shortfall, stress test charges, and add-on charges) for purposes of intraday margin calls.
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