OCC fee holiday December 2025: Fee relief lands as clearing concentration risk bites
TL;DR
The OCC fee holiday December 2025 waives fees for Dec. 1–31 under an immediately effective SEC notice. The move lands amid higher volumes and concentrated intermediation, which could pressure capacity and risk management. Watch routing, margins, and post‑December adjustments.
OCC fee holiday December 2025: context and filing
The OCC fee holiday December 2025 became effective after the SEC posted SR‑OCC‑2025‑019 on Nov. 28 as a notice of immediate effectiveness under sec release 34-104274. According to the filing, the holiday spans Dec. 1 through Dec. 31, 2025.
In practice, the occ fee holiday 2025 reduces clearing costs during December, though the filing governs precise mechanics. Therefore, firms may adjust routing to capture relief while monitoring liquidity and capital effects.
Zoom in: SR‑OCC‑2025‑019; sec release 34-104274; window: Dec. 1–31.
Concentration risk in U.S. options clearing
A small set of bank‑affiliated intermediaries has outsized influence over options clearing. According to available reports, the top five OCC clearing members provided nearly half of the default fund in Q2 2025, concentrating exposures across the system. Industry voices have warned about fragility if a key intermediary reaches limits.
That us options clearing concentration risk is now a central talking point. One senior leader put it plainly: “I think there is significant concentration risk in clearing intermediation.” According to available reports, Bank of America, Goldman Sachs, and ABN Amro are frequently cited among the largest intermediaries.[1]
Volume surge and self‑clearing pressures
OCC activity has accelerated. Notably, occ average daily volume october 2025 rose 52% year over year, intensifying operational and balance‑sheet pressures at major clearing banks. As volumes climb, bottlenecks can emerge in onboarding, risk checks, and capital allocation.
Consequently, more market makers are exploring options market self-clearing. However, options market self-clearing can add risk if firms are less capitalized or have thinner risk controls than banks. As a result, supervisors and venues will likely scrutinize liquidity and margin practices in December.[1]
By the numbers:
- occ average daily volume october 2025: +52% year over year.
- Top five OCC clearing members: nearly half of the default fund (Q2 2025).
- All listed U.S. options: centrally cleared at OCC.
Timeline: OCC fee holiday December 2025 and recent developments
- October 2025: occ average daily volume october 2025 rose 52% year over year.
- Nov. 28, 2025: SEC posts SR‑OCC‑2025‑019 as immediately effective; see sec release 34-104274.[2]
- Dec. 1–31, 2025: OCC fee holiday window. The occ fee holiday 2025 aligns with month‑end expirations and settlement cycles that merit close monitoring.
All listed U.S. options clear at OCC
All listed U.S. options trades are centrally cleared at OCC. Therefore, capacity or outage risks at a few intermediaries can propagate system‑wide. In that context, us options clearing concentration risk is not academic, it’s a stability discussion.[1]
How the OCC fee holiday December 2025 intersects with concentration risk
Fee waivers can influence routing. If the holiday pulls more flow to OCC in December, higher peaks could strain the same banks that dominate intermediation. Conversely, the holiday may relieve some cost pressure on firms that are near limits.
Importantly, the occ fee holiday 2025 arrives via sec release 34-104274 and a notice of immediate effectiveness.[2] That timing means firms have little lead time to re‑architect internal limits. Additionally, any shift toward options market self-clearing to capture economics should be weighed against liquidity and default‑management obligations.
The upshot: Clearing is a tightly coupled system. When volumes spike and roles concentrate, modest policy changes can reshape incentives and intra‑month risk profiles.
What’s next: oversight, capacity, and OCC actions
- Monitor December settlement flows, intraday margin moves, and any new OCC circulars. If needed, updates could clarify the holiday’s interaction with operational thresholds.
- Track bank capacity decisions and routing behavior. If limits bind, more firms may consider options market self-clearing.
- Expect continued regulatory focus. As December data arrives, attention on us options clearing concentration risk will likely intensify, especially if a single intermediary processes a disproportionate share of holiday‑driven flow.
