The US options market is poised to set a sixth consecutive annual trading volume record, but industry leaders are growing increasingly concerned about the market's heavy reliance on a handful of banks to guarantee trades for major market makers. All US-listed options must be cleared through the Options Clearing Corporation (OCC), which processes over 70 million contracts daily during peak periods. While dozens of institutions serve as OCC members—acting as both clearing facilitators and guarantors in case of client defaults—the top five members accounted for nearly half of OCC's default fund contributions in Q2 2025. Market participants identify Bank of America, Goldman Sachs, and ABN Amro as the primary guarantors for most market makers, who serve as counterparties to virtually every options trade. This concentration creates systemic risk, warns Cboe Global Markets CEO Craig Donohue, who experienced the fallout from MF Global's 2011 collapse while leading CME Group Inc. The strain is intensifying as OCC's October daily volume surged 52% YoY, pushing some market makers toward self-clearing—a risky alternative given their lower capital buffers. Only a few clearing brokers currently offer cross-margining between futures and options, a capital-efficient practice that nets offsetting positions. OCC CEO Andrej Bolkovic acknowledges the bottleneck, stating market makers "want this to change." Regulatory fragmentation exacerbates the issue, with banks facing conflicting capital requirements from the Fed, SEC, and CFTC. The explosion of 0DTE options and retail trading further strains the system, while potential 24/7 trading would raise barriers to entry. Bank of America has reportedly raised per-trade clearing fees to $0.04 amid rising costs. OCC proposes reforming its $20 billion default fund to better reflect members' portfolio risks, seeking SEC approval to stress-test for extreme scenarios like the 1987 crash. Donohue advocates for greater competition in clearing, arguing diversified participation would strengthen market resilience.
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