Effective December 1, 2009, FINRA has implemented increased customer margin requirements for leveraged Exchange Traded Funds (ETFs) and uncovered options underlying leveraged ETFs (see NASD Rule 2520 and NYSE Rule 431). 

Leveraged ETFs are a subset of ETFs which are intended to generate performance in multiples of that of the underlying index or benchmark (e.g. 200%, 300% or greater). In addition certain of these ETFs seek to a generate performance which is not only a multiple of but also the inverse of the underlying index or benchmark (e.g., a short ETF). These leveraged funds typically include among their holdings derivative instruments such as options, futures or swaps which are intended to provide the desired leverage and/or inverse performance. 

The regulatory objective with respect to this margin increase is to recognize the leverage embedded in these instruments and establish a margin rate which is commensurate with that level of leverage (not to exceed 100% of the ETF value). Thus, for example, whereas the base strategy-based maintenance margin requirement for a non-leveraged long ETF will remain at 25% and a short non-leveraged ETF at 30%, examples of the maintenance margin change for leveraged ETFs are as follows:

1. Long an ETF having a 200% leverage factor: 50% (= 2 x 25%) 

2. Short an ETF having a 300% leverage factor: 90% (= 3 x 30%) 

A similar scaling in margin will also take effect for options. Thus, for example, whereas the base strategy-based maintenance margin requirement for a non-leveraged listed and uncovered broad based ETF index option will remain at 100% of the option premium plus 15% of the ETF market value less any out-of-the-money amount (to a minimum of 10% of ETF market value in the case of calls and 10% of the option strike price in the case of puts), that 15% rate will increase by the leverage factor of the ETF. 

In the case of portfolio margin accounts, the effect will be similar, with the scan ranges by which the leveraged ETF positions will be stress tested increasing by the ETF leverage factor. 

Clients maintaining positions in these ETFs should be aware that IB's standard liquidation policies will remain in effect upon the implementation of this new margin requirement and thereafter and any account which reports a margin deficit is subject to immediate liquidation. 

A list of the leveraged ETF products impacted by this change are outlined below

There are many different formulas used to calculate the margin requirement on options.  Which formula is used will depend on the option type or strategy determined by the system.  There are a significant number of detailed formulas that are applied to various strategies.  To find this information go to the IB home page at www.interactivebrokers.com.  Go to the Trading menu and click on Margin.  From the Margin Requirements page, click on the Options tab.  There is a table on this page which will list all possible strategies, and the various formulas used to calculate margin on each.

When an account is in margin deficit, it is subject to liquidation in real-time.  Any and all positions can be immediately liquidated.  Automated liquidations are accomplished with market orders, and any/all positions in the account can be liquidated.  The system which determines whether an account is in margin violation is entirely automated, and governed by a mathematical algorithm.  Once an account is determined to be in margin violation, either the system will automatically liquidate positions based on a proprietary algorithm or, if market conditions are better served by  manual liquidations in specific instruments, then liquidation orders will be manually transmitted.  Liquidations can occur at any market interval, whether positive or negative for the account holder.

Portfolio Margining accounts reporting net liquidating equity below USD 100,000 are limited to entering trades which serve solely to reduce the margin requirement until such time as either: 1) the equity increases to above 100,000 or 2) the account holder requests a downgrade to Reg T style margining through Account Management (select the Trading Access and then trading Configuration menu options).

If a Portfolio Margining eligible account reporting net liquidating equity below USD 100,000 enters an order which, if executed, would serve to increase the margin requirement, the following TWS message will be displayed: "Your order is not accepted, margin requirement increase not allowed. Equity with loan value is less than 100,000.00 USD." 

IMPORTANT NOTICE

Please note that requests to downgrade to reg T will become effective the following business day if submitted prior to 4:00 ET.  Also note that as the Reg T margining methodology generally affords less leverage than does Portfolio Margining, requesting a downgrade may lead to the automatic liquidation of positions in your account in order to comply with Reg T.  You will receive a warning message if that is the case at the time you request the downgrade.