Options Clearing Corp Eyes Commercial Paper
Published Date: 6/8/2026
Notice
Summary
The Options Clearing Corporation (OCC) wants to start a commercial paper program to help manage its money and make sure it can pay what it owes on time. This change affects traders and financial firms relying on OCC’s smooth operations. If approved, the program will boost OCC’s financial strength and keep things running safely, with details open for public comment now.
Analyzed Economic Effects
5 provisions identified: 1 benefits, 1 costs, 3 mixed.
OCC Commercial Paper Program Up to $1B
OCC proposes a Commercial Paper Program to privately sell unsecured short-term Notes to institutional investors in an aggregate amount not to exceed $1,000,000,000. OCC says it expects to be able to issue new debt and receive proceeds on the same day, with individual Notes having maturities not to exceed 180 days and no early redemption or automatic rollovers.
Clearing Fund May Repay Commercial Paper
OCC would count Commercial Paper proceeds as qualifying Base Liquidity Resources up to a Board-approved cap (OCC expects to initially limit these proceeds to no more than 5% of Base Liquidity Resources). OCC would also provide that OCC may use the Clearing Fund to repay Notes if proceeds are used to cover losses or liquidity shortfalls.
Commercial Paper Excluded from Cover 2 Prefunded Measure
OCC proposes to exclude Commercial Paper Program proceeds from its definition of "Pre-Funded Financial Resources" used for Cover 2 credit monitoring and to exclude those proceeds from its LNAFBE (liquid net assets funded by equity) calculation. OCC explains the proceeds are prefunded liquidity used for shortfalls, not for covering general business losses.
Proceeds Held in Federal Reserve Account
OCC would hold Commercial Paper Program proceeds in a Federal Reserve Bank account (with a segregated subaccount) and would not invest those proceeds; interest earned on the proceeds held at the Federal Reserve would accrue to OCC. OCC states this safeguards the prefunded cash and reduces custody risk.
Private Placement Notes and Dealer/Agent Roles
The Notes would be privately placed under Section 4(a)(2) of the Securities Act to institutional investors, using placement dealers and an issuing and paying agent. OCC would treat those dealers and the agent as "Financial Institutions" under its Third-Party Risk Management Framework rather than as liquidity providers under its committed facilities.
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