May 1, 2014, the OCC Financial Guarantee changed the way the took risk deposits from the clearing members. Before that, I think it was based on open interest. In 2014, they changed that to a blended allocation formula, with open interest, total risk margin and volume accounting for 50%, 35% and 15%, respectively. That means effectively, that to cover your risk, they must post more of their capital. In late 2013, the members all knew this was coming, and I expect that is why many firms added more risk rules on top of the OCC requirements on PMA, including this risk fee from IB and the higher shocks from all clearing firms for higher risk strategies. They are not buying puts to protect themselves, they are getting paid for this capital they must put up.