Resilient Capital Levels
To that end, over the past several years we have increased the capital on our balance sheet significantly to meet the challenges that come with marketplace growth and complexity, volatility and technological innovation.
As of year-end 2022, OCC maintained equity capital (separate from our clearing fund capital) above our target level of $268 million. In 2022, OCC’s persistent minimum level of ‘skin-in-the-game’ (SITG) – funds available in the unlikely event of a Clearing Member default – included a minimum level of OCC's own capital of $59 million. When combined with the unvested funds held under our Executive Deferred Compensation Program, OCC's persistent minimum SITG in 2022 amounted to $67 million, which is at least 25 percent of OCC's target regulatory capital per our Capital Management Policy.
These steps further enhance our alignment with clearing firms and market participants to operate a resilient and robust risk management framework that can withstand significant market events. At the end of 2022, we held $180 billion in margin on behalf of our customers and approximately $13 billion in our clearing fund.
As we continue to transform our technology infrastructure, we are investing in the Cloud, new hardware and upgraded data centers to power our forthcoming Ovation system and to ensure that ENCORE is robust and resilient until Ovation launches in 2025. We are also investing a great deal in other areas, including testing and training to support a smooth transition. As such, while our financial position is strong, it is incumbent upon us to make these necessary investments in our vital market infrastructure.
Our goal, outlined in our Capital Management Policy, is to ensure that our capital remains at approximately 110 percent of our regulatory requirement in order to maintain appropriate financial resources and continue providing critical services to the marketplace. When our capital level is above that 110 percent threshold after making needed capital investments, we assess the suitability of tools such as fee holidays, clearing fee reductions or refunds to Clearing Members.
Since we rolled out our Capital Management Policy in 2020, we have focused on maintaining an appropriate clearing fee based on actual volumes and expenses incurred. Given the necessary investments we must make in our technology and operational resiliency, we did not issue a Clearing Member refund for 2022. We did, however, leave the clearing fee at the current historically low rate of two cents, which has been in place since June 2021.
