Cboe seeks SEC pass on binary bet margin madness
Published Date: 9/29/2026
Notice
Summary
Cboe Clear U.S., LLC wants special permission from the SEC to treat customer margin for binary options the same way it’s done for other options. This change affects broker-dealers who clear trades through Cboe Clear and could make margin handling simpler and more consistent. The SEC is asking for public comments before deciding, so this could impact how margin rules work soon.
Analyzed Economic Effects
4 provisions identified: 2 benefits, 1 costs, 1 mixed.
CCUS asks to treat binary-option margin like OCC
On September 18, 2026, Cboe Clear U.S., LLC (CCUS) asked the SEC for permission to let broker-dealers include margin held at CCUS for customer binary options in the Item 13 debit of the Rule 15c3-3 customer reserve computation, the same way margin held at the Options Clearing Corporation (OCC) is treated today. If the SEC grants the exemption, broker-dealers that clear through CCUS could count margin on deposit at CCUS toward their Item 13 debit for binary options.
Risk of reserve computation penalty if exemption denied
CCUS says that if the SEC does not allow margin held at CCUS to be treated like OCC margin, CCUS Clearing Members could face a customer reserve computation penalty for clearing customer binary options at CCUS. CCUS warns that such a penalty could hinder the development of cleared trading in the binary options it expects to clear.
Proposed protections: segregation and daily margining
CCUS proposes that, as a condition of any exemption, it would (1) keep customer margin for binary options separate from Clearing Members' proprietary margin and (2) clear fully margined binary options with daily and intraday margin collection, a guaranty fund, and a default waterfall. These measures would apply only if the Commission grants the requested relief and CCUS registers as a clearing agency.
Relief limited to customer binary options margin
CCUS proposes the exemption apply only to margin required and on deposit with CCUS for customer positions in binary options. The requested relief would not apply to other products or margin held for other types of option contracts.
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