ANALYSIS: Avoiding Common Pitfalls of Poorly Managed Policies

The SEC and the CFTC announced a settlement with the Options Clearing Corporation for mismanagement of the clearing firm’s policies. Unfortunately for the OCC, the penalties weren’t limited to a hefty $20 million fine—the firm also had to complete various remedial measures. The SEC’s order also charged the OCC with changing certain policies without obtaining approval from the regulator.

According to the OCC’s statement on the September 4 settlement, the clearing firm replaced a number of its executives. These changes included hiring a new Chief Executive Officer, Chief Operating Officer, head of Financial Risk Management, Chief Information Officer, and Chief ...