Clearing‑rules Clash

The fight that broke into public view this week looks technical. It is not. It is a battle over who pays for safety in the US options market, and that means it is also a battle over who gets to make markets cheaply enough to dominate them. The center of the dispute is the Options Clearing Corporation, or OCC, the Chicago clearinghouse that stands behind every listed US options trade and clears for 16 exchanges. As of December 31, 2025, it held about $392.1 billion of initial margin and a $21.68 billion guaranty fund to absorb losses if a member fails (theocc.com). That guaranty fund is mutualized. If one clearing member blows up and its own margin and fund contribution are not enough, OCC can use money posted by everyone else. OCC says that is exactly why the fund should be allocated using the same kind of stress logic used to size it in the first place. In a filing first submitted on September 26, 2025, OCC proposed changing Rule 1003 so contributions would better track the stress exposures each member brings to the clearinghouse, rather than leaning on older measures like open interest and short-term activity snapshots (sec.gov; sec.gov). The details matter because the old formula spread costs in a way that many large liquidity providers believed understated the risk created by concentrated market-making books. A March 2026 letter from FIA, the main derivatives trade group, described the new mix as 85% based on margin and 15% based on cleared volume, with the open-interest component removed and the lookback period stretched from one month to three. That is a quiet but important shift. It moves the bill toward firms whose portfolios generate the biggest stress losses in OCC’s models, and away from firms that simply process a lot of smaller retail business (fia.org). That is why Goldman Sachs, Bank of America and Citadel Securities lined up behind the change. In a support letter filed with the SEC, clearing members and liquidity providers argued that the proposal would align contributions with “actual risk posed” and stop some firms from being subsidized by others through the mutualized pool (sec.gov). Citadel has an obvious stake here. It says it is the largest on-exchange options market maker in the US, with about 30% share, and that it executes more than 35% of total US retail market volume across products (citadelsecurities.com). The opposition came from the retail side of the market, and it was unusually blunt. Robinhood asked the SEC in December 2025 to delay implementation and reopen comment, warning that the amendment had been adopted too quickly and would reshape clearing costs for brokers serving individual investors (sec.gov). By March 2026, the comment file had filled out with objections from Fidelity, Charles Schwab, LPL Financial, the American Securities Association and PTG, while SEC staff logged meetings with Fidelity and Schwab on March 9 and with Goldman on February 27 (sec.gov; sec.gov). The procedural path shows how contested this became. The SEC’s trading staff approved the OCC change on December 11, 2025. Fidelity then petitioned for review, and on February 13, 2026 the Commission granted that petition and reopened the fight at the full-Commission level (sec.gov; sec.gov). That does not mean the rule is doomed. It means the real argument is now impossible to ignore: in a market built on razor-thin spreads and giant scale, clearing formulas are not back-office plumbing. They are industrial policy written in risk language. The current SEC comment page for SR-OCC-2025-018 now reads like a map of the options business itself, with Citadel and Goldman on one side and Robinhood, Schwab and Fidelity on the other (sec.gov).