PTG Responds to CCUS Clearing Agency Application
Sep 8, 2026
In a letter filed today with the Securities and Exchange Commission (SEC), PTG expresses qualified support for Cboe Clear U.S. (CCUS) receiving temporary registration as a clearing agency for Binary KPI Options, but strongly opposes any effort to make that registration permanent. PTG views CCUS as a short-term solution that can help bring innovative products to market while the Options Clearing Corporation (OCC) develops the capability to clear them. The letter argues that OCC remains the appropriate long-term clearing venue and notes that OCC has already established a framework for clearing binary options, making a permanent alternative clearing structure unnecessary.
PTG’s primary concern is the broader market structure precedent that approval of CCUS could create. Because CCUS is affiliated with Cboe, PTG warns that a permanent arrangement could lead to a vertically integrated model in which exchanges control listing, trading, and clearing of their own products. PTG argues that such a trend could fragment the options market into exchange-specific clearing silos, reduce competition, limit product fungibility, and undermine the centralized clearing system that has historically supported efficient risk management and liquidity in U.S. options markets. PTG notes that Cboe’s public statements suggest CCUS may be intended as a broader platform for future products, increasing these concerns.
The letter also highlights the costs and risks associated with a more fragmented clearing landscape. PTG argues that multiple clearing venues would increase operational and capital burdens for clearing members as well as market participants by requiring separate margin, default fund contributions, and technology investments, while eliminating many portfolio-margining benefits that currently reduce costs. In addition, PTG warns that directing new products to exchange-affiliated clearinghouses could introduce operational and systemic risks by moving activity away from OCC’s long-established infrastructure. PTG therefore urges the SEC to carefully consider the long-term implications for competition, capital efficiency, and market stability before granting any registration beyond a strictly temporary basis.