Options Clearing Corp Boosts Loss Fee Ceiling Quietly
Published Date: 12/31/2025
Notice
Summary
The Options Clearing Corporation (OCC) just updated the maximum fee it can charge for unexpected operational losses. This change affects traders and firms using OCC’s services by adjusting the fee limits to better manage risks. The new fee schedule took effect immediately on December 19, 2025, helping OCC keep its financial safety net strong without surprise costs.
Analyzed Economic Effects
4 provisions identified: 1 benefits, 3 costs, 0 mixed.
Maximum Operational Loss Fee Raised to $219M
OCC updated the maximum aggregate Operational Loss Fee in its fee schedule from $211,000,000 to $219,000,000 (less any previously charged and not refunded). If that fee were charged across 106 Clearing Members (the number as of November 20, 2025), the maximum per-Clearing Member amount would be about $2.07 million.
Trigger Thresholds Based on $323M Target
OCC's 2026 Board-approved Target Capital Requirement is $323,000,000. A Trigger Event occurs if OCC's LNAFBE falls below $290,700,000 (90% of $323,000,000) at any time or stays below $323,000,000 for 90 consecutive days; if triggered, OCC would seek to raise LNAFBE to 110% of the Target (about $355,300,000).
Fees Allocated Equally Across Clearing Members
If OCC charges an Operational Loss Fee, it would be allocated in equal shares to all Clearing Members (not based on usage or size). OCC says this equal-share approach is similar to certain Clearing Fund contingent obligations.
Filing Effective Dec 19, 2025; Implementation Delayed
OCC filed the fee change and it became effective upon filing on December 19, 2025, but OCC will not make the fee operative until the change is certified under CFTC Regulation 40.6. That means the new maximum is set now, but OCC cannot charge it until the CFTC process completes.
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