SEC Grants Temporary Margin-Accounting Relief to Clearing Firms
Published Date: 10/28/2026
Notice
Summary
The SEC is giving special permission to Cboe Clear U.S. and its broker-dealer members to treat customer margin deposits differently when calculating reserve requirements. This change lets these members count margin held at Cboe Clear just like they do with the Options Clearing Corporation, making the process smoother and more consistent. This relief is temporary and lasts for 18 months, helping firms manage their money better during this period.
Analyzed Economic Effects
3 provisions identified: 3 benefits, 0 costs, 0 mixed.
Broker-Dealers May Count CCUS Margin
The SEC allows broker-dealers that are clearing members of Cboe Clear U.S. (CCUS) to include the amount of customer margin required and on deposit with CCUS as a debit in Item 13 of the customer and PAB reserve computations under Exhibit A to Rule 15c3-3a for binary options. The order grants this conditional exemptive relief relative to the prior Item 13 limitation referencing only the Options Clearing Corporation (OCC); CCUS was noted as temporarily registered with the Commission for a period of 18 months.
Customer Margin Must Be Segregated and Fully Margined
The exemption is allowed only if CCUS is registered as a clearing agency and the relief applies solely to customer positions in binary options that are margined by CCUS consistent with Rule 17Ad-22(e). Customer margin held at CCUS must be maintained separately from a member's proprietary margin, and only the same types of collateral allowed under Note F (cash, proprietary qualified securities, and letters of credit collateralized by customers' securities) may be included.
Supports Competition and Access to Clearing
The Commission found the relief would help promote competition between clearing agencies and facilitate access to central clearing and settlement for binary security options, and may reduce capital constraints and inefficiencies for clearing members that could otherwise limit their willingness to clear customer option positions.
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