The Options Clearing Corporation (OCC) wields significant authority over its clearing members, with broad discretion to impose restrictions, mandate operational changes, and enforce penalties. In the past two years, this power has been exercised with greater frequency and assertiveness, often without deference to the downstream impacts on members’ businesses or their clients. Once viewed primarily as a backstop for market stability, the OCC has increasingly demonstrated a willingness to intervene directly in members’ activities, using rules that can reshape trading strategies, limit exposures, or compel costly operational adjustments. For some members, these measures can feel less like safeguards and more like sudden, disruptive mandates—underscoring just how decisive the OCC’s influence can be.

The below examples are merely a subset of these broad authorities:

If, in the eyes of the clearinghouse, a position were to increase credit or liquidity risk, a prohibition on these transactions could be put in place. Rule 307B

Reduce or eliminate positions which the clearing house deems to be presenting a liquidity or credit risk. This is based on the CCP’s view which discounts non-cleared or OTC positions which may impact a firms risk profile. A forced hedge too would be based on the OCC cleared position set. Rule 307B

Require such a member to transfer any existing positions or accounts to another Clearing Member. Rule 307B

Could be required to add personnel or execute an agreement with a third party to bolster staff to OCC’s satisfaction. Rule 307B

The Corporation may impose a fine on any Member for conduct deemed embarrassing the operations of the Corporation. Rule 1201