Self-Regulatory Organizations; Chicago Board Options Exchange, Incorporated; Notice of Filing of Amendment No. 5 to a Proposed Rule Change To List and Trade Credit Default Options; and Order Granting Accelerated Approval of the Proposed Rule Change, as Modified by Amendment Nos. 3, 4, and 5, and Designating Credit Default Options as Standardized Options Under Rule 9b-1 of the Securities Exchange Act of 1934, 32372-32378 [E7-11273]
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Amex has requested that the
Commission waive the 30-day operative
delay. The Commission believes that
waiving the 30-day operative delay is
consistent with the protection of
investors and the public interest.9 The
Commission notes that the proposed
rule change is modeled on a recently
approved Philadelphia Stock Exchange
proposal.10 Amex’s proposal does not
appear to raise any novel regulatory
issues and will allow Amex without
undue delay to implement backup
trading arrangements for options—
particularly exclusively listed options—
in the event of a Disabling Event.
At any time within 60 days of the
filing of the proposed rule change, the
Commission may summarily abrogate
such rule change if it appears to the
Commission that such action is
necessary or appropriate in the public
interest, for the protection of investors,
or otherwise in the furtherance of the
purposes of the Act.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml) or
• Send an e-mail to rulecomments@sec.gov. Please include File
Number SR–Amex–2007–51 on the
subject line.
cprice-sewell on PROD1PC67 with NOTICES
Paper Comments
• Send paper comments in triplicate
to Nancy M. Morris, Secretary,
Securities and Exchange Commission,
100 F Street, NE., Washington, DC
20549–1090.
All submissions should refer to File
Number SR–Amex–2007–51. This file
number should be included on the
subject line if e-mail is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
9 For purposes only of waiving the operative
delay for this proposal, the Commission has
considered the proposed rule’s impact on
efficiency, competition, and capital formation. See
15 U.S.C. 78c(f).
10 See Exchange Act Release No. 51926 (June 27,
2005), 70 FR 38232 (July 1, 2005) (SR–PHLX–2004–
65).
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amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for inspection and copying in
the Commission’s Public Reference
Room. Copies of such filing also will be
available for inspection and copying at
the principal offices of the Exchange.
All comments received will be posted
without change; the Commission does
not edit personal identifying
information from submissions. You
should submit only information that
you wish to make available publicly. All
submissions should refer to File
Number SR–Amex–2007–51 and should
be submitted on or before July 3, 2007.
For the Commission, by the Division of
Market Regulation, pursuant to delegated
authority.11
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E7–11265 Filed 6–11–07; 8:45 am]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–55871; File No. SR–CBOE–
2006–84]
Self-Regulatory Organizations;
Chicago Board Options Exchange,
Incorporated; Notice of Filing of
Amendment No. 5 to a Proposed Rule
Change To List and Trade Credit
Default Options; and Order Granting
Accelerated Approval of the Proposed
Rule Change, as Modified by
Amendment Nos. 3, 4, and 5, and
Designating Credit Default Options as
Standardized Options Under Rule 9b–
1 of the Securities Exchange Act of
1934
June 6, 2007.
I. Introduction
On October 26, 2006, the Chicago
Board Options Exchange, Incorporated
(‘‘CBOE’’ or ‘‘Exchange’’) filed with the
Securities and Exchange Commission
(‘‘Commission’’) a proposed rule
change, pursuant to Section 19(b)(1) of
the Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2 to
permit CBOE to list and trade cashsettled, binary call options based on
11 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
1 15
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credit events in one or more debt
securities of an issuer, referred to as
credit default options. On December 21,
2006, CBOE filed Amendment No. 1 to
the proposed rule change; on January
16, 2007, CBOE filed Amendment No. 2
to the proposed rule change; on
February 2, 2007, CBOE filed
Amendment No. 3 to the proposed rule
change; 3 and on February 7, 2007,
CBOE filed Amendment No. 4 to the
proposed rule change. The proposed
rule change, as amended, was published
for comment in the Federal Register on
February 14, 2007.4 The Commission
received no comments on the proposal.
On March 28, 2007, CBOE filed
Amendment No. 5 to the proposed rule
change (‘‘Amendment No. 5’’). This
notice and order notices Amendment
No. 5; solicits comments from interested
persons on Amendment No. 5; approves
the proposed rule change, as amended,
on an accelerated basis; and designates
credit default options as ‘‘standardized
options’’ pursuant to Rule 9b–1 under
the Act.5
II. Description of the CBOE Proposal
A. Generally
CBOE proposes to list and trade credit
default options, which are cash-settled,
binary options 6 that are automatically
exercised upon the occurrence of
specified credit events or expire
worthless. A credit default option
would be referenced to the debt
securities issued by a specified public
company (‘‘Reference Entity’’) 7 and
would either have a fixed payout or
expire worthless, depending upon
whether or not a credit event (as
described below) occurs during the life
of the option. Upon confirmation of a
credit event prior to the last day of
3 Amendment No. 3 replaced the original filing,
as modified by Amendment Nos. 1 and 2, in its
entirety.
4 See Securities Exchange Act Release No. 55251
(February 7, 2007) (SR–CBOE–2006–84), 72 FR
7091 (‘‘CBOE Proposal’’).
5 See 17 CFR 240.9b–1. Pursuant to Rule 9b–
1(a)(4) under the Act, the Commission may, by
order, designate as ‘‘standardized options’’
securities that do not otherwise meet the definition
for ‘‘standardized options.’’ Standardized options
are defined in Rule 9b–1(a)(4) as: ‘‘[O]ptions
contracts trading on a national securities exchange,
an automated quotations system of a registered
securities association, or a foreign securities
exchange which relate to options classes the terms
of which are limited to specific expiration dates and
exercise prices, or such other securities as the
Commission may, by order, designate.’’ 17 CFR
240.9b–1(a)(4).
6 A binary option is a style of option having only
two possible payoff outcomes: Either a fixed
amount or nothing at all.
7 Proposed CBOE Rule 29.1(f) also includes as a
‘‘Reference Entity’’ the guarantor of the debt
security underlying the credit default option.
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trading of a credit default option series,8
the options positions existing as of that
time would be automatically exercised
and the holders of long options
positions would receive a fixed cash
payment of $100,000 per contract.9 If no
credit event is confirmed during the life
of the option, the final settlement price
would be $0.
Credit events that would trigger
automatic exercise include a failure to
make payment pursuant to the terms of
the underlying debt security and any
other event of default specified by CBOE
at the time the Exchange initially lists
a particular class of credit default
options. The events of default that
CBOE may specify must be defined in
accordance with the terms of the debt
security underlying the credit default
option (‘‘Reference Obligation’’) or any
other debt security of the Reference
Entity (collectively with the Reference
Obligation, ‘‘Relevant Obligations’’).10
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B. Listing Standards
A credit default option must conform
to the initial and continued listing
standards under proposed CBOE
Chapter XXIX. CBOE may list and trade
a credit default option that overlies a
debt security of a Reference Entity,
provided that such issuer or guarantor,
or its parent if a wholly owned
subsidiary, has at least one class of
securities that is registered under the
Act and is an ‘‘NMS stock’’ 11 as defined
in Rule 600 of Regulation NMS under
the Act.12 The registered equity
securities issued by the Reference Entity
also would have to satisfy the
requirements of CBOE Rule 5.4 for
continued options trading, which
requires, among other things, that an
equity security underlying an option be
itself widely held and actively traded.13
8 Proposed CBOE Rule 29.9 requires that CBOE
confirm the occurrence of a credit event through at
least two sources, which may include
announcements published via newswire services or
information service companies, the names of which
would be announced to the membership via a CBOE
regulatory circular, or information contained in any
order, decree, or notice of filing, however described,
of or filed with the courts, the Commission, an
exchange, an association, the Options Clearing
Corporation (‘‘OCC’’), or another regulatory agency
or similar authority.
9 The settlement amount would be $100,000 per
contract unless adjusted pursuant to proposed
CBOE Rule 29.4, as discussed below.
10 See proposed CBOE Rule 29.1(c).
11 ‘‘NMS stock’’ means any security, or class of
securities, other than an option for which
transaction reports are collected, processed, and
made available pursuant to an effective transaction
reporting plan, or an effective national market
system plan for reporting transaction in listed
options. See 17 CFR 242.600(b)(46) and (47).
12 See proposed CBOE Rule 5.3.11.
13 CBOE Rule 5.4 provides that, absent
exceptional circumstances, an underlying security
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The requirement that the equity
securities of an issuer of a debt security
underlying a credit default option meet
the criteria of Rule 5.4 is designed to
ensure that the issuer’s securities enjoy
widespread investor interest. The
requirement that the Reference Entity be
an issuer of a registered NMS stock will
help ensure that investors have access to
comprehensive public information
about the issuer, including the
registration statement filed under the
Securities Act of 1933 (‘‘Securities Act’’)
and other periodic reports.14
A credit default option could not be
exercised at the discretion of the
investor, but instead would have an
automatic payout only upon the
occurrence of a credit event. The
expiration date would be the fourth
business day after the last day of trading
of the series, which would be the third
Friday of the expiration month.15 A
credit default option generally would
expire up to 123 months from the time
it is listed, and the Exchange usually
would open one to four series for each
year up to 10.25 years from the current
expiration.16
C. Trading
Credit default options will trade on
CBOE’s Hybrid Trading System from
8:30 a.m. to 3 p.m. (Central Time) 17 in
a manner similar to the trading of equity
options. With limited distinctions, as
described more fully in the proposal,
CBOE’s equity option trading rules will
apply to credit default options.18 Also,
credit default options will be eligible for
trading as Flexible Exchange Options
(‘‘FLEX Options’’). A FLEX Option that
will not be deemed to meet the Exchange’s
requirements for continued approval when: (a)
There are fewer than 6,300,000 shares of the
underlying security held by persons other than
those who are required to report their security
holdings under Section 16(a) of the Act (15 U.S.C.
78p); (b) there are fewer than 1,600 holders of the
underlying security; (c) the trading volume (in all
markets in which the underlying security is traded)
was less than 1,800,000 shares in the preceding
twelve months; (d) the market price per share of the
underlying security closed below $3 on the
previous trading day as measured by the closing
price reported in the primary market in which the
underlying security traded; or (e) the underlying
security ceases to be an NMS stock.
14 Section 13 of the Act, 15 U.S.C. 78m, requires
that any issuer of a security registered pursuant to
Section 12 of the Act, 15 U.S.C. 78l, would file with
the Commission annual reports and information
and documents necessary to keep reasonably
current the information in its Section 12 registration
statement.
15 If a credit event is confirmed, the expiration
date would be the second business day after the
confirmation of a credit event. See proposed CBOE
Rule 29.1(d) and (e).
16 See proposed CBOE Rule 29.2(b)(1) and (2).
17 See proposed CBOE Rule 29.11.
18 See proposed CBOE Rules 29.11–29.17 and
29.19.
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32373
is a credit default option would be cashsettled and the exercise-by-exception
provisions of OCC Rule 805 19 would
not apply. Market-makers shall be
appointed to credit default options
pursuant to CBOE’s existing
requirements,20 as supplemented by
proposed CBOE Rule 29.17.
Additionally, CBOE represents that
there will be a maximum of one series
per quarterly expiration in a given credit
default option class, and that it, and the
Options Price Reporting Authority
(‘‘OPRA’’), have the necessary systems
capacity to handle the additional quote
volume anticipated to be associated
with credit default options.
Once a particular credit default option
class has been approved for listing and
trading, the Exchange would, from time
to time, open for trading a series of that
class. If a credit default option initially
approved for trading no longer meets
the Exchange’s requirements for
continued approval, the Exchange
would not open for trading any
additional series of options and, as
provided in CBOE Rule 5.4, could
prohibit any opening purchase
transactions in such series. The
proposed trading rules for credit default
options are designed to create an
environment that takes into account the
small number of transactions likely to
occur, while providing price
improvement and the transparency
benefits of competitive Exchange floor
bidding, as compared to the over-thecounter (‘‘OTC’’) market.
Upon the confirmation of a credit
event or the redemption of all Relevant
Obligations, the applicable credit
default option class would cease trading
and all outstanding contracts in that
class would be subject to automatic
exercise. In addition, the CBOE’s trading
halt procedures applicable to equity
options shall apply to credit default
options.21 When determining whether
to institute a trading halt in credit
default options, CBOE floor officials
would consider whether current
quotations for the Relevant Obligation(s)
or other securities of the Reference
Entity are unavailable or have become
unreliable. The Exchange’s board of
directors shall also have the power to
impose restrictions on transactions or
exercises in one or more series of credit
default options as the board, in its
judgment, determines advisable in the
interests of maintaining a fair and
orderly market or otherwise deems
19 OCC Rule 805 sets forth the expiration date
exercise procedures for options cleared and settled
by the OCC.
20 See Chapter VIII of CBOE’s Rules.
21 See CBOE Rules 6.3 and 6.3B; proposed CBOE
Rule 29.13.
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advisable in the public interest or for
the protection of investors.22
D. Clearance and Settlement
Because credit default options do not
have an exercise price, they do not, by
their terms, meet the definition of
‘‘standardized options’’ for purposes of
Rule 9b–1 under the Act.23 However, as
discussed herein, the Commission today
is using its authority pursuant to Rule
9b–1 to designate credit default options
as ‘‘standardized options’’ under Rule
9b–1. Consequently, credit default
option transactions would be eligible for
clearance and settlement by the OCC in
accordance with procedures that are
substantially similar to existing systems
and procedures for the clearance and
settlement of exchange-traded options.24
E. Adjustments
Credit default options will be subject
to adjustments in two circumstances.25
First, if the original Reference Entity is
succeeded by another entity in
accordance with the terms of the
underlying debt security, the related
credit default options would be replaced
by one or more credit default options
derived from the debt securities of the
successor entity or entities. To the
extent necessary and appropriate for the
protection of investors and the public
interest, all other terms and conditions
of the successor options would be the
same as the original credit default
options.
Second, if the specific debt security
(the Reference Obligation) is redeemed
during the life of the credit default
option, another debt security of the
Reference Entity would be specified as
the new Reference Obligation. In the
event that all debt securities of the
Reference Entity (i.e., all Relevant
Obligations) are redeemed during the
life of the credit default option, the
option would cease trading and,
assuming that CBOE has not confirmed
a credit event, the contract payout
would be $0.
22 See
proposed CBOE Rule 29.8.
17 CFR 240.9b–1.
24 On February 13, 2007, the OCC filed with the
Commission pursuant to Section 19(b)(1) of the Act,
15 U.S.C. 78s(b)(1), and Rule 19b–4 thereunder, 17
CFR 240.19b–4, a proposed rule change to enable
it to clear and settle credit default options proposed
to be listed by CBOE. The proposed rule change was
published for comment in the Federal Register on
February 27, 2007. Securities Exchange Act Release
No. 55362, 72 FR 9826 (March 5, 2007). On March
7, 2007, the OCC filed Amendment No. 1 to the
proposed rule change. See SR–OCC–2007–01 (as
amended, the ‘‘OCC Proposal’’). The Commission
has not yet taken action on the OCC proposal.
25 See CBOE Proposed Rule 29.4.
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23 See
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F. Position Limits
Pursuant to proposed CBOE Rule
29.5, credit default options will be
subject to a position limit equal to 5,000
contracts on the same side of the
market. Credit default options shall not
be aggregated with option contracts on
the same underlying security and will
not be subject to the hedge exemption
to CBOE’s standard position limits.
Instead, the following hedge exemption
strategies and positions shall be exempt
from CBOE’s position limits: (i) A credit
default option position ‘‘hedged’’ or
‘‘covered’’ by an appropriate amount of
cash to meet the cash settlement amount
obligation (e.g., $100,000 for a credit
default option with an exercise
settlement value of $100 multiplied by
a contract multiplier of 1,000); and (ii)
a credit default option position
‘‘hedged’’ or ‘‘covered’’ by an amount of
an underlying debt security(ies) that
serves as a Relevant Obligation(s) or
other securities, instruments, or
interests related to the Reference Entity
that is sufficient to meet the cash
settlement amount obligation.26 Also,
CBOE’s market-maker and firm
facilitation exemptions to position
limits will apply.27
G. Margin
The margin (both initial and
maintenance) required for writing short
and long positions in credit default
options will be as follows: 28
• For a qualified customer 29 carrying
a long position in credit default options,
the margin requirement will be 20% of
the current market value of the credit
default option.
• For a non-qualified customer
carrying a long position in a credit
default option, the margin requirement
will be 100% of the current market
value of the credit default option.
• For a non-qualified customer
carrying a short position in a credit
default option, the margin requirement
will be the cash settlement amount, i.e.,
$100,000 per contract.
• For a qualified customer carrying a
short position in a credit default option,
26 See
proposed CBOE Rule 29.5.
CBOE Rule 29.5 requires that for
purposes of its market-maker hedge exemption
(CBOE Rule 4.11.05) the position must be within
20% of the applicable limit before an exemption
would be granted. With respect to CBOE’s firm
facilitation exemption (CBOE Rule 4.11.06),
proposed CBOE Rule 29.5 provides that the
aggregate exemption position could not exceed
three times the standard limit of 5,000 contracts.
28 See proposed CBOE Rule 12.3(l); Amendment
No. 5.
29 Proposed CBOE Rule 12.3(l)(1)(i) defines
‘‘qualified customer’’ as a person or entity that
owns and invests on a discretionary basis no less
than $5,000,000 in investments.
27 Proposed
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the margin requirement will be the
lesser of the current market value plus
20% of the cash settlement amount or
the cash settlement amount.
These requirements may be satisfied by
a deposit of cash or marginable
securities. These requirements may not
be satisfied by presentation to the
member organization carrying the
customer’s account of a letter of credit
meeting the requirements of proposed
CBOE Rule 12.3(l)(1)(iii).30
A credit default option carried short
in a customer’s account will be deemed
a covered position, and eligible for the
cash account, provided any one of the
following is either held in the account
at the time the option is written or is
received into the account promptly
thereafter: (i) Cash or cash equivalents
equal to 100% of the cash settlement
amount or (ii) an escrow agreement. The
Exchange believes that these
requirements strike the appropriate
balance and adequately address
concerns that a member or its customer
may try to maintain an inordinately
large unhedged position in credit
default options. In addition, in
Amendment No. 5, the Exchange notes
that, in accordance with CBOE Rule
12.3(a)(3), an escrow agreement must be
issued in a form acceptable to the
Exchange, and that it has traditionally
recognized as acceptable the escrow
agreement forms of the OCC and the
New York Stock Exchange.
In Amendment No. 5, the Exchange
also represents the following:
‘‘As part of its regulatory oversight of
member organizations, the Exchange
generally reviews member organizations’
compliance with margin requirements
applicable to customer accounts. In the
future, the Exchange will include [c]redit
[d]efault [o]ption margin requirements as part
of this review. Additionally, the Exchange
will review member organizations’ internal
procedures for managing credit risk
associated with extending margin to
customers trading [c]redit [d]efault [o]ptions.
The Exchange also notes that, pursuant to
CBOE Rule 12.10, the Exchange may at any
time impose higher margin requirements
when it deems such higher margin
requirements advisable.’’
Lastly, in Amendment No. 5, the
Exchange makes non-substantive
changes to the text of CBOE Rule 12.5,
to clarify that a credit default option
that is carried for the account of a
qualified investor may be deemed to
30 In Amendment No. 5, CBOE deletes from
proposed rule 12.3(l)(1)(iii) the option of using a
letter of credit to satisfy margin requirements
applicable to credit default options and makes nonsubstantive corrections to the formatting of
proposed CBOE Rule 12.3(l)(1)(iii) and the
‘‘Interpretations and Policies’’ heading that
accompanies CBOE Rule 12.3.
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have market value for the purposes of
CBOE Rule 12.3(c).
84 and should be submitted on or before
July 3, 2007.
H. Surveillance
The Exchange has represented that it
will have in place adequate surveillance
procedures to monitor trading in credit
default options prior to listing and
trading such options.
IV. Discussion
III. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning Amendment No.
5, including whether Amendment No. 5
is consistent with the Act. Comments
may be submitted by any of the
following methods:
cprice-sewell on PROD1PC67 with NOTICES
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an e-mail to rulecomments@sec.gov. Please include File
Number SR–CBOE–2006–84 on the
subject line.
Paper Comments
• Send paper comments in triplicate
to Nancy M. Morris, Secretary,
Securities and Exchange Commission,
Station Place, 100 F Street, NE.,
Washington, DC 20549–1090.
All submissions should refer to
Amendment No. 5 to File Number SR–
CBOE–2006–84. This file number
should be included on the subject line
if e-mail is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for inspection and copying in
the Commission’s Public Reference
Room. Copies of such filing also will be
available for inspection and copying at
the principal office of the Exchange. All
comments received will be posted
without change; the Commission does
not edit personal identifying
information from submissions. You
should submit only information that
you wish to make available publicly. All
submissions should refer to Amendment
No. 5 of File Number SR–CBOE–2006–
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The Commission finds that the
proposed rule change is consistent with
the requirements of the Act and the
rules and regulations thereunder
applicable to a national securities
exchange.31 In particular, the
Commission finds that the proposal is
consistent with Section 6(b)(5) of the
Act,32 which requires, among other
things, that the rules of an exchange be
designed to prevent fraudulent and
manipulative acts and practices; to
promote just and equitable principles of
trade; to foster cooperation and
coordination with persons engaged in
regulating, clearing, processing
information with respect to, and
facilitating transactions in securities; to
remove impediments to and perfect the
mechanism of a free and open market
and a national market system; and, in
general to protect investors and the
public interest. The CBOE’s proposal, by
enabling CBOE to offer a security that
will be listed and traded on the
Exchange, as opposed to the OTC
market, would extend to investors the
benefits of a listed exchange market,
which include: A centralized market
center; an auction market with posted,
transparent market quotations and
transaction reporting; standardized
contract specifications; and the
guarantee of the OCC.
As a threshold matter, the
Commission finds that the credit default
options proposed by CBOE are
securities. Section 3(a)(10) of the Act 33
defines security to include, in part, ‘‘any
put, call, straddle, option or privilege on
any security, certificate of deposit, or
group or index of securities (including
any interest therein or based on the
value thereof).’’ After careful analysis,
the Commission finds that credit default
options are options 34 based on the value
of a security or securities and, therefore,
securities under Section 3(a)(10) of the
31 In approving this proposed rule change, the
Commission notes that it has considered the
proposed rule’s impact on efficiency, competition,
and capital formation. See 15 U.S.C. 78c(f).
32 15 U.S.C. 78f(b)(5).
33 15 U.S.C. 78c(a)(10).
34 Although credit default options do not share
every feature of a classic option, the Commission
nonetheless finds that credit default options are
option contracts. In particular, the Commission
notes that the buyer of a credit default option pays
to the seller a nonrefundable premium, has rights
but no further obligations under the contract, and
has no further risk exposure because the seller bears
all the risk of the credit event occurring. See United
States v. Bein, 728 F.2d 107, 112 (2d Cir. 1984)
(highlighting characteristics that distinguish
options from futures contracts).
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Act; 35 in addition, the Commission
finds that credit default options are
options on an interest in, or based on
the value of an interest in, a security or
securities and, therefore, are securities
under Section 3(a)(10) of the Act.36
The Commission interprets ‘‘based on
the value [of a security or securities]’’ in
Section 3(a)(10) of the Act 37 to include
options whose pricing in the secondary
market moves in relation to the value of
the underlying security or securities of
the option in question. Thus the fact
that the payout of a cash-settled option
will not increase or decrease based on
the price movement of the underlying
security of that option is not
dispositive.38
Because credit default options are not
currently traded, there is no empirical
data regarding their pricing in the
secondary market. However, credit
default options are essentially exchangetraded equivalents of single-name, OTC
credit default swaps.39 A single-name
35 15
U.S.C. 78c(a)(10).
U.S.C. 78c(a)(10). In determining whether a
derivative is a security, the Commission and the
courts have looked to the economic reality of the
product. See Caiola v. Citibank, N.A., New York,
295 F.3d 312, 325 (2d Cir. 2002), quoting United
Housing Foundation v. Foreman, 421 U.S. 837, 848
(1975) (‘‘In searching for the meaning and scope of
the word ‘security’ * * * the emphasis should be
on economic reality’’). Construing the definition of
a security in this manner permits the Commission
and the courts ‘‘sufficient flexibility to ensure that
those who market investments are not able to
escape the coverage of the Securities Acts by
creating new instruments that would not be covered
by a more determinate definition.’’ Reves v. Ernst
& Young, 494 U.S. 56, 63 n.2 (1990).
37 Id.
38 In addressing whether a ‘‘digital option’’ or a
‘‘binary option’’ with a fixed payout is an option
based on the value of a security or securities, the
court in Stechler v. Sidley, Austin Brown & Wood,
L.L.P., 382 F.Supp.2d 580, 596–97 (S.D.N.Y. 2005),
held that the issue ultimately turned on questions
of fact and declined to decide the issue on a motion
to dismiss. However, the court’s analysis made clear
that the existence of a fixed payout that is not tied
in a proportionate manner to the price of an
underlying security is not a determining factor in
deciding whether an instrument is an option on a
security. Rather, the court accepted that, in
evaluating the economic reality of an instrument, it
is appropriate to consider whether the resale value
of the instrument moves in relation to the
movement of an underlying reference.
39 Despite the similarities between credit default
options and OTC credit default swaps, the
Commission wishes to make two things clear. First,
because credit default options will be exchangetraded and not individually negotiated (and not
necessarily between eligible contract participants),
they are not qualifying swap agreements under
Section 206A of the Gramm-Leach-Bliley Act
(‘‘GLBA’’), 15 U.S.C. 78c note, and, therefore, not
excluded from the definition of security by Section
3A of the Act, 15 U.S.C. 78c–1. Second, certain OTC
credit default swaps are not securities. The finding
that credit default options are securities because
they are options based on the value of a security
might suggest that OTC credit default swaps are
also options based on the value of a security or
securities and, therefore, excluded from the
36 15
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credit default swap is an agreement
between a protection buyer and a
protection seller whereby the buyer
pays a periodic fee in return for a
contingent payment by the seller upon
the occurrence of a credit event with
respect to one or more reference
obligations of a reference entity. Credit
events typically include one or more of
the following: (1) Bankruptcy, (2)
obligation acceleration, (3) obligation
default, (4) a failure to pay, (5)
repudiation or moratorium, or (6)
restructuring. Similarly, as explained
above, each credit default option shall
specify (a) the Reference Entity, (b) the
specific debt security or securities that
serve as its Reference Obligation or
other Relevant Obligations, and (c) the
applicable events of default that trigger
payout (as determined in accordance
with the terms of the Reference
Obligation or other Relevant
Obligations), which could include such
events as a failure to pay, obligation
acceleration or default, and
restructuring. Hence, credit default
options have essentially the same
structure as credit default swaps.
In the case of a credit default swap,
the amount the buyer pays for
protection is based on a quoted spread
expressed in basis points on a notional
amount specified in the swap
agreement. This quoted spread is often
referred to as a ‘‘CDS spread’’ and is
principally based on the probability that
the Reference Entity will default (i.e., its
creditworthiness). More specifically, the
CDS spread represents the price
required by a swap counterparty to
compensate it for the credit risk
associated with the potential default on
a particular reference obligation or
obligations of an issuer. Similarly, the
value of a debt security is a function of
the issuer’s creditworthiness, which is
expressed in terms of a ‘‘yield spread’’
definition of swap agreement because Section
206A(b)(1) of the GLBA, 15 U.S.C. 78c note,
excludes from the definition of swap agreement
‘‘any put, call, straddle, option, or privilege on any
security, certificate of deposit, or group or index of
securities, including any interest therein or based
on the value thereof.’’ However, Congress
specifically enumerated ‘‘credit default swaps’’
(without defining the term) as one example of a
qualifying swap agreement. See Section 206A(a)(3)
of the GLBA, 15 U.S.C. 78c note. The Commission
views the specific enumeration of ‘‘credit default
swaps’’ as reflecting the intention of Congress to
exclude certain OTC credit default swaps from the
definition of security pursuant to Sections 206B &
C of the GLBA, 15 U.S.C. 78c note. Credit default
swaps that involve terms similar to credit default
options, but that are otherwise excluded from the
definition of security because they are qualifying
swap agreements, remain subject to the
Commission’s antifraud jurisdiction (including
authority over insider trading) as ‘‘security-based
swap agreements’’ under Section 206B of the GLBA,
15 U.S.C. 78c note.
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(sometimes called ‘‘credit spread’’). The
yield (or credit) spread is the difference
between the yield on the debt
instrument and the yield on a debt
security of similar maturity whose yield
represents pure interest rate risk, such
as U.S. Treasuries,40 and represents the
additional yield required by an investor
to compensate it for the credit risk
associated with the potential default on
the particular debt instrument of an
issuer.41 As a consequence of this
relationship between debt securities and
credit default swaps, the credit default
swap market enables more widespread
trading in an issuer’s creditworthiness
than was previously possible.
There is a close empirical correlation
between the price of a credit default
swap (as expressed in the CDS spread)
and the yield (or credit) spread of the
specific reference obligation or
obligations of that credit default swap.42
This correlation is to be expected
because the valuation of credit default
swaps and debt securities are each
based on credit risk, and because of the
potential for arbitrage between the
secondary bond market and the credit
default swap market.43 Similarly,
because credit default options are
exchange-traded equivalents of credit
default swaps, the Commission expects
that there will be a close empirical
correlation between the pricing of a
specific credit default option during the
life of the contract and the yield spread
of the Reference Obligation or other
Relevant Obligations of that credit
default option.
We further note, more generally, that
credit default options expressly
reference in their payout conditions a
term of an underlying security that is
material to the value of that security. A
credit default option will pay out if
40 Some academics have hypothesized that there
may be some deviation between the yield on U.S.
Treasuries and pure interest rate risk because bond
interest is subject to state tax but U.S. Treasuries are
not. See, e.g., Haibin Zhu, An Empirical
Comparison of Credit Spreads between the Bond
Market and the Credit Default Swap Market, BIS
Working Papers No. 160 (August 2004) (also noting
that transparency and the widespread use of U.S.
Treasuries as collateral could explain apparent
deviations).
41 While the terms of both corporate securities
and credit default swaps are established when
parties enter into the respective contracts, the fair
market value of these contracts can vary over the
life of the contracts in response to changing
perceptions of the creditworthiness of an issuer.
42 See, e.g., Roberto Blanco, Simon Brennan, and
Ian W. Marsh, An Empirical Analysis of the
Dynamic Relation between Investment-Grade Bonds
and Credit Default Swaps, The Journal of
Economics, Volume LX, No. 5 (Oct. 2005) (finding
credit default swap spreads to be quite close to
bond yield spreads).
43 See Zhu, An Empirical Comparison of Credit
Spreads between the Bond Market and the Credit
Default Swap Market, supra note 40.
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there is a failure to pay or other default
event under the terms of the underlying
debt security.
For these reasons, credit default
options are options ‘‘based on the value
[of a security or securities]’’ and,
therefore, securities.
In addition, the Commission has
determined that credit default options
are options on an ‘‘interest in,’’ or based
on the value of an interest in, a security
or securities within the meaning of
Section 3(a)(10) of the Act.44 A security
is a collection of rights (and obligations)
running between the issuer and the
holder of the security. The concept of an
‘‘interest in’’ a security plainly includes
rights generating a pecuniary interest in
a security, such as the right to a
dividend payment or bond (coupon)
payment. One relevant ‘‘interest in’’ a
debt security underlying a credit default
option is the right to receive (coupon)
payments under the terms of that debt
security. When a (coupon) payment is
not made, impairing the value of that
interest, the protection seller must make
a payment to the protection buyer.
Similarly, a specified default event may
trigger other rights of a holder of the
debt security. The default events that
trigger exercise and payment under the
credit default option are meaningful
only because they are material terms of
a security, essential to the debt holder’s
rights and interests in that security.45
The credit default option payout is
contingent on these security-dependent
events. For these reasons, credit default
options are options on an interest in, or
based on the value of an interest in, a
security or securities.46
Moreover, the economic reality of
credit default options supports the
conclusion that credit default options
are securities. Taking a short position
(i.e., taking on the role of a protection
seller) via credit default options would
be akin to purchasing the corporate
bond that is the Reference Obligation or
other Relevant Obligations of that credit
44 15
U.S.C. 78c(a)(10).
certain default events trigger the
exercise and payment of a credit default option, it
would not be accurate to describe these options as
options on ‘‘an event’’. There is no event delivered
upon exercise of the option, rather a payment is
delivered. The crucial question is what causes the
option to be in-the-money and pay out. In the case
of credit default options, it is an event that is
created by a security.
46 It is important to note that merely because the
option does not transfer ownership of the interest
or right in a security—but instead becomes in-themoney and provides a cash payment if certain
security rights are triggered—does not mean the
option is not on an interest in a security. Cf. Caiola,
295 F.3d 312 (2d Cir. 2002) (including within the
definition of ‘‘security’’ an option that did not
deliver an actual security or interest in a security,
but merely a cash payment).
45 Although
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default option with the interest rate risk
fully hedged. Both give the investor the
same risk exposure to creditworthiness
of an issuer. Indeed, credit default
options may even more closely reflect
the financial condition of an SECregistered issuer because, unlike
corporate bonds, which reflect both an
issuer’s creditworthiness and general
interest rate risk, credit default options
would only reflect an issuer’s
creditworthiness. That ability to isolate
and transfer credit risk, backed by the
guarantee of a central counterparty and
the transparency of an exchange, should
provide investors with additional
opportunities to gain exposure to the
public debt market.
For these reasons, the Commission
finds that credit default options are
options based on the value of, and
options on interests in or based on the
value of interests in, a security or
securities of the Reference Entity and,
therefore, securities under Section
3(a)(10) of the Act.47
Further, the Commission believes that
the listing rules proposed by CBOE for
credit default options are reasonable
and consistent with the Act. The
Commission notes in particular that a
credit default option must be based on
a Reference Obligation issued by an
entity that issues registered equity
securities that are NMS stocks and that
meet the Exchange’s standards for
listing an equity option. These
requirements are reasonably designed to
facilitate investors’ access to
information about the Reference Entity
that may be necessary to price a credit
default option appropriately.
The Commission believes that the
proposed position limits and margin
rules for credit default options are
reasonable and consistent with the Act.
The proposed position limit of 5,000
contracts in any credit default option
class appears to reasonably balance the
promotion of a free and open market for
these securities with minimization of
incentives for market manipulation and
insider trading. The proposed margin
rules appear reasonably designed to
deter a member or its customer from
assuming an imprudent position in
credit default options.
In support of this proposal, the
Exchange made the following
representations:
• The Exchange will have in place
adequate surveillance procedures to
monitor trading in credit default options
prior to listing and trading such options,
thereby helping to ensure the
maintenance of a fair and orderly
47 15
U.S.C. 78c(a)(10).
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market for trading in credit default
options.
• The Exchange and the OPRA will
have the necessary systems capacity to
accommodate the additional volume
associated with credit default options as
proposed.
This approval order is conditioned on
CBOE’s adherence to these
representations.
For the foregoing reasons, the
Commission finds that the proposed
rule is consistent with the Act.
V. Accelerated Approval
The Commission finds good cause for
approving the proposed rule change, as
modified by Amendment No. 5, prior to
the thirtieth day after publishing notice
of Amendment No. 5 in the Federal
Register pursuant to Section 19(b)(2) of
the Act.48 In Amendment No. 5, CBOE:
(1) Modified the text of the proposed
margin requirements applicable to
credit default options contained in
proposed Rules 12.3 and 12.5; (2) made
corresponding changes to the discussion
sections of the Form 19b–4 and the
Exhibit 1 thereto; and (3) inserted
information in the discussion sections
of the Form 19b–4 and the Exhibit 1
thereto regarding the form of escrow
agreements and the Exchange’s
supervision of member organizations
that extend margin to customers trading
Credit Default Options.49 The
Commission believes that Amendment
No. 5 raises no significant regulatory
issues. The Commission therefore finds
good cause exists to accelerate approval
of the proposed change, as modified by
Amendment No. 5, pursuant to Section
19(b)(2) of the Act.
VI. Designation of Credit Default
Options Pursuant to Rule 9b–1
Rule 9b–1 establishes a disclosure
framework for standardized options that
are traded on a national securities
exchange and cleared through a
registered clearing agency. Under this
framework, the exchange on which a
standardized option is listed and traded
must prepare an Options Disclosure
Document (‘‘ODD’’) that, among other
things, identifies the issuer and
describes the uses, mechanics, and risks
of options trading, in language that can
be easily understood by the general
investing public. The ODD is treated as
a substitute for the traditional
48 15 U.S.C. 78s(b)(2). Pursuant to Section 19(b)(2)
of the Act, the Commission may not approve any
proposed rule change, or amendment thereto, prior
to the thirtieth day after the date of publication of
the notice thereof, unless the Commission finds
good cause for so doing.
49 The changes pursuant to Amendment No. 5 are
discussed more fully in Section II.G, supra.
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32377
prospectus. A broker-dealer must
provide a copy of the ODD to each
customer at or before approving of the
customer’s account for trading any
standardized option.50 Any amendment
to the ODD must be distributed to each
customer whose account is approved for
trading the options class for which the
ODD relates.51
Under Rule 9b–1, use of the ODD is
limited to ‘‘standardized options’’ for
which there is an effective registration
statement on Form S–20 under the
Securities Act or that are exempt from
registration.52 The Commission
specifically reserved in Rule 9b–1 the
ability to designate as standardized
options other securities ‘‘that the
Commission believes should be
included within the options disclosure
framework.’’ 53
The Commission hereby designates
credit default options, as defined in the
OCC Proposal,54 as standardized
options for purposes of Rule 9b–1 under
the Act. Credit default options do not
meet the definition of ‘‘standardized
options,’’ because they do not have an
exercise price. However, they resemble
50 See
17 CFR 240.9b–1(d)(1).
17 CFR 240.9b–1(d)(2).
52 See 17 CFR 240.9b–1(b)(1) and (c)(8). See also
17 CFR 230.238. Rule 238 under the Securities Act
provides an exemption from the Securities Act for
any standardized option, as defined by Rule 9b–
1(a)(4) under the Act, with limited exceptions. Rule
238 does not exempt standardized options from the
antifraud provisions of Section 17 of the Securities
Act, 15 U.S.C. 77q. Also, offers and sales of
standardized options by or on behalf of the issuer
of the underlying security or securities, an affiliate
of the issuer, or an underwriter, will constitute an
offer or sale of the underlying security or securities
as defined in Section 2(a)(3) of the Securities Act,
15 U.S.C. 77b(a)(3). See also Securities Act Release
No. 8171 (December 23, 2002), 68 FR 188 (January
2, 2003) (Exemption for Standardized Options From
Provisions of the Securities Act of 1933 and From
Registration Requirements of the Exchange Act of
1934).
53 See Securities Exchange Act Release No. 19055
and Securities Act Release No. 6426 (September 16,
1982), 47 FR 41950, 41954 (September 23, 1982).
54 For purposes of its proposal, OCC would define
the term ‘‘credit default option’’ as an option that
is automatically exercised upon receipt by the OCC
of a credit event confirmation with respect to the
reference obligation(s) of a reference entity. Credit
default options have only two possible payoff
outcomes: Either a fixed automatic exercise
settlement amount or nothing at all. See proposed
Section 1.C.(2) of Article XIV of the OCC By-Laws.
• I11‘‘Credit event’’ would be as defined in the
rules of the exchange on which the credit default
options are listed, with respect to a reference
obligation for such option. See proposed Section
1.C.(3) of Article XIV of the OCC By-Laws.
• I11‘‘Reference entity’’ would mean the issuer or
guarantor of the reference obligation(s). See
proposed Section 1.R.(1) of Article XIV of the OCC
By-Laws.
• I11‘‘Reference obligations’’ would mean one or
more debt securities the terms of which define a
credit event for a class of credit default options, as
provided in the rules of the listing exchange. See
id.
51 See
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Federal Register / Vol. 72, No. 112 / Tuesday, June 12, 2007 / Notices
standardized options in other significant
respects. Credit default options have an
underlying security and an expiration
date. Like other standardized options,
credit default options have standardized
terms relating to exercise procedures,
contract adjustments, time of issuance,
effect of closing transactions,
restrictions, and other matters
pertaining to the rights and obligations
of holders and writers. Further, credit
default options are designed to provide
market participants with the ability to
hedge their exposure to an underlying
security. The fact that credit default
options lack a specified exercise price
does not detract from this option-like
benefit. The Commission believes that
the fact that the OCC, the clearing
agency for all standardized options, is
willing to serve as issuer of credit
default options supports the view that
adding credit default options to the
standardized option disclosure
framework is reasonable.
Therefore, the Commission hereby
designates credit default options, such
as those proposed by CBOE, as
standardized options for purposes of
Rule 9b–1 under the Act.
VII. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,55 that the
proposed rule change (SR–CBOE–2006–
84) as modified by Amendment Nos. 3,
4, and 5, be, and hereby is approved on
an accelerated basis.
It is further ordered, pursuant to Rule
9b–1(a)(4) under the Act, the credit
default options, as defined in proposed
rule change (SR–OCC–2007–01) are
designated as standardized options.
By the Commission.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E7–11273 Filed 6–11–07; 8:45 am]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
cprice-sewell on PROD1PC67 with NOTICES
[Release No. 34–55864; File No. SR–ISE–
2007–35]
Self-Regulatory Organizations;
International Securities Exchange,
LLC; Notice of Filing and Order
Granting Accelerated Approval of a
Proposed Rule Change to Permanently
Extend the Pilot Program for
Preferenced Orders
June 5, 2007.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that on May 9,
2007, the International Securities
Exchange, LLC (‘‘ISE’’ or ‘‘Exchange’’)
filed with the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change as described in
Items I and II below, which Items have
been prepared by the Exchange. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons and is
approving the proposal on an
accelerated basis.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The ISE is proposing to make
permanent its pilot program for
Preferenced Orders. The text of the
proposed rule change is available on
ISE’s Web site at https://www.ise.com, at
the Exchange’s principal office, and at
the Commission’s Public Reference
Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
Exchange included statements
concerning the purpose of and basis for
the proposed rule change and discussed
any comments it received on the
proposed rule change. The text of these
statements may be examined at the
places specified in Item III below. The
Exchange has prepared summaries, set
forth in Sections A, B, and C below, of
the most significant aspects of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The purpose of the proposed rule
change is to make permanent the
Exchange’s pilot program for
preferenced orders as provided in
paragraph .03 of the Supplementary
Material to Rule 713. The proposal
amends ISE’s procedure for allocating
trades among market makers and noncustomer orders under Rule 713 to
provide an enhanced allocation to a
‘‘Preferred Market Maker’’ when it is
quoting at the national best bid or offer
(‘‘NBBO’’). Specifically, an Electronic
Access Member may designate any
market maker appointed to an options
class to be a Preferred Market Maker on
orders it enters into the Exchange’s
1 15
55 15
U.S.C. 78s(b)(2).
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system (‘‘Preferenced Orders’’). If the
Preferred Market Maker is not quoting at
the NBBO at the time the Preferenced
Order is received, the Exchange’s
existing allocation and execution
procedures will be applied to the
execution.3 The proposed rule is subject
to a pilot program that is currently set
to expire on June 10, 2007.4
Under the proposal, if a Preferred
Market Maker is quoting at the NBBO at
the time a Preferenced Order is
received, the allocation procedure is
modified so that the Preferred Market
Maker will receive an enhanced
allocation instead of the Primary Market
Maker 5 equal to the greater of: (i) The
proportion of the total size at the best
price represented by the size of its
quote; or (ii) sixty percent of the
contracts to be allocated if there is only
one other Non-Customer Order or
market maker quotation at the best price
and forty percent if there are two or
more other Non-Customer Orders and/or
market maker quotes at the best price.6
Unexecuted contracts remaining after
the Preferred Market Maker’s allocation
would be allocated pro-rata based on
size as described above.
Pursuant to this proposed rule change
seeking permanent approval of the pilot
program, the Exchange also proposes to
delete from the Notes section in its
Schedule of Fees a reference to the
Preferenced Orders pilot program that
was adopted when the Exchange
initiated a payment for order flow
program for Competitive Market
Makers.7
The Exchange believes the proposed
rule change is a necessary competitive
response to the preferencing rules
adopted by other options exchanges and
will help the ISE attract and retain order
flow. This order flow will add depth
and liquidity to the Exchange’s markets
and enable the Exchange to continue to
compete effectively with other options
exchanges.
3 Marketable customer orders are not
automatically executed at prices inferior to the
NBBO. If the ISE best bid or offer is inferior to the
NBBO, it is handled by the Primary Market Maker
according to Rule 803(c).
4 See Securities Exchange Act Release No. 53921
(June 1, 2006), 71 FR 33019 (June 7, 2006).
5 A Primary Market Maker may be the Preferenced
Market Maker, in which case such market maker
would receive the enhanced allocation for
Preferenced Market Makers.
6 All allocations are automatically performed by
the Exchange’s system.
7 See Securities Exchange Act Release No. 53127
(January 13, 2006), 71 FR 3582 (January 23, 2006)
(Notice of Filing and Immediate Effectiveness of
Proposed Rule Change Relating to Payment for
Order Flow Fee Changes).
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Agencies
[Federal Register Volume 72, Number 112 (Tuesday, June 12, 2007)]
[Notices]
[Pages 32372-32378]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E7-11273]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-55871; File No. SR-CBOE-2006-84]
Self-Regulatory Organizations; Chicago Board Options Exchange,
Incorporated; Notice of Filing of Amendment No. 5 to a Proposed Rule
Change To List and Trade Credit Default Options; and Order Granting
Accelerated Approval of the Proposed Rule Change, as Modified by
Amendment Nos. 3, 4, and 5, and Designating Credit Default Options as
Standardized Options Under Rule 9b-1 of the Securities Exchange Act of
1934
June 6, 2007.
I. Introduction
On October 26, 2006, the Chicago Board Options Exchange,
Incorporated (``CBOE'' or ``Exchange'') filed with the Securities and
Exchange Commission (``Commission'') a proposed rule change, pursuant
to Section 19(b)(1) of the Securities Exchange Act of 1934 (``Act'')
\1\ and Rule 19b-4 thereunder,\2\ to permit CBOE to list and trade
cash-settled, binary call options based on credit events in one or more
debt securities of an issuer, referred to as credit default options. On
December 21, 2006, CBOE filed Amendment No. 1 to the proposed rule
change; on January 16, 2007, CBOE filed Amendment No. 2 to the proposed
rule change; on February 2, 2007, CBOE filed Amendment No. 3 to the
proposed rule change; \3\ and on February 7, 2007, CBOE filed Amendment
No. 4 to the proposed rule change. The proposed rule change, as
amended, was published for comment in the Federal Register on February
14, 2007.\4\ The Commission received no comments on the proposal. On
March 28, 2007, CBOE filed Amendment No. 5 to the proposed rule change
(``Amendment No. 5''). This notice and order notices Amendment No. 5;
solicits comments from interested persons on Amendment No. 5; approves
the proposed rule change, as amended, on an accelerated basis; and
designates credit default options as ``standardized options'' pursuant
to Rule 9b-1 under the Act.\5\
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ Amendment No. 3 replaced the original filing, as modified by
Amendment Nos. 1 and 2, in its entirety.
\4\ See Securities Exchange Act Release No. 55251 (February 7,
2007) (SR-CBOE-2006-84), 72 FR 7091 (``CBOE Proposal'').
\5\ See 17 CFR 240.9b-1. Pursuant to Rule 9b-1(a)(4) under the
Act, the Commission may, by order, designate as ``standardized
options'' securities that do not otherwise meet the definition for
``standardized options.'' Standardized options are defined in Rule
9b-1(a)(4) as: ``[O]ptions contracts trading on a national
securities exchange, an automated quotations system of a registered
securities association, or a foreign securities exchange which
relate to options classes the terms of which are limited to specific
expiration dates and exercise prices, or such other securities as
the Commission may, by order, designate.'' 17 CFR 240.9b-1(a)(4).
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II. Description of the CBOE Proposal
A. Generally
CBOE proposes to list and trade credit default options, which are
cash-settled, binary options \6\ that are automatically exercised upon
the occurrence of specified credit events or expire worthless. A credit
default option would be referenced to the debt securities issued by a
specified public company (``Reference Entity'') \7\ and would either
have a fixed payout or expire worthless, depending upon whether or not
a credit event (as described below) occurs during the life of the
option. Upon confirmation of a credit event prior to the last day of
[[Page 32373]]
trading of a credit default option series,\8\ the options positions
existing as of that time would be automatically exercised and the
holders of long options positions would receive a fixed cash payment of
$100,000 per contract.\9\ If no credit event is confirmed during the
life of the option, the final settlement price would be $0.
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\6\ A binary option is a style of option having only two
possible payoff outcomes: Either a fixed amount or nothing at all.
\7\ Proposed CBOE Rule 29.1(f) also includes as a ``Reference
Entity'' the guarantor of the debt security underlying the credit
default option.
\8\ Proposed CBOE Rule 29.9 requires that CBOE confirm the
occurrence of a credit event through at least two sources, which may
include announcements published via newswire services or information
service companies, the names of which would be announced to the
membership via a CBOE regulatory circular, or information contained
in any order, decree, or notice of filing, however described, of or
filed with the courts, the Commission, an exchange, an association,
the Options Clearing Corporation (``OCC''), or another regulatory
agency or similar authority.
\9\ The settlement amount would be $100,000 per contract unless
adjusted pursuant to proposed CBOE Rule 29.4, as discussed below.
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Credit events that would trigger automatic exercise include a
failure to make payment pursuant to the terms of the underlying debt
security and any other event of default specified by CBOE at the time
the Exchange initially lists a particular class of credit default
options. The events of default that CBOE may specify must be defined in
accordance with the terms of the debt security underlying the credit
default option (``Reference Obligation'') or any other debt security of
the Reference Entity (collectively with the Reference Obligation,
``Relevant Obligations'').\10\
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\10\ See proposed CBOE Rule 29.1(c).
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B. Listing Standards
A credit default option must conform to the initial and continued
listing standards under proposed CBOE Chapter XXIX. CBOE may list and
trade a credit default option that overlies a debt security of a
Reference Entity, provided that such issuer or guarantor, or its parent
if a wholly owned subsidiary, has at least one class of securities that
is registered under the Act and is an ``NMS stock'' \11\ as defined in
Rule 600 of Regulation NMS under the Act.\12\ The registered equity
securities issued by the Reference Entity also would have to satisfy
the requirements of CBOE Rule 5.4 for continued options trading, which
requires, among other things, that an equity security underlying an
option be itself widely held and actively traded.\13\ The requirement
that the equity securities of an issuer of a debt security underlying a
credit default option meet the criteria of Rule 5.4 is designed to
ensure that the issuer's securities enjoy widespread investor interest.
The requirement that the Reference Entity be an issuer of a registered
NMS stock will help ensure that investors have access to comprehensive
public information about the issuer, including the registration
statement filed under the Securities Act of 1933 (``Securities Act'')
and other periodic reports.\14\
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\11\ ``NMS stock'' means any security, or class of securities,
other than an option for which transaction reports are collected,
processed, and made available pursuant to an effective transaction
reporting plan, or an effective national market system plan for
reporting transaction in listed options. See 17 CFR 242.600(b)(46)
and (47).
\12\ See proposed CBOE Rule 5.3.11.
\13\ CBOE Rule 5.4 provides that, absent exceptional
circumstances, an underlying security will not be deemed to meet the
Exchange's requirements for continued approval when: (a) There are
fewer than 6,300,000 shares of the underlying security held by
persons other than those who are required to report their security
holdings under Section 16(a) of the Act (15 U.S.C. 78p); (b) there
are fewer than 1,600 holders of the underlying security; (c) the
trading volume (in all markets in which the underlying security is
traded) was less than 1,800,000 shares in the preceding twelve
months; (d) the market price per share of the underlying security
closed below $3 on the previous trading day as measured by the
closing price reported in the primary market in which the underlying
security traded; or (e) the underlying security ceases to be an NMS
stock.
\14\ Section 13 of the Act, 15 U.S.C. 78m, requires that any
issuer of a security registered pursuant to Section 12 of the Act,
15 U.S.C. 78l, would file with the Commission annual reports and
information and documents necessary to keep reasonably current the
information in its Section 12 registration statement.
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A credit default option could not be exercised at the discretion of
the investor, but instead would have an automatic payout only upon the
occurrence of a credit event. The expiration date would be the fourth
business day after the last day of trading of the series, which would
be the third Friday of the expiration month.\15\ A credit default
option generally would expire up to 123 months from the time it is
listed, and the Exchange usually would open one to four series for each
year up to 10.25 years from the current expiration.\16\
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\15\ If a credit event is confirmed, the expiration date would
be the second business day after the confirmation of a credit event.
See proposed CBOE Rule 29.1(d) and (e).
\16\ See proposed CBOE Rule 29.2(b)(1) and (2).
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C. Trading
Credit default options will trade on CBOE's Hybrid Trading System
from 8:30 a.m. to 3 p.m. (Central Time) \17\ in a manner similar to the
trading of equity options. With limited distinctions, as described more
fully in the proposal, CBOE's equity option trading rules will apply to
credit default options.\18\ Also, credit default options will be
eligible for trading as Flexible Exchange Options (``FLEX Options''). A
FLEX Option that is a credit default option would be cash-settled and
the exercise-by-exception provisions of OCC Rule 805 \19\ would not
apply. Market-makers shall be appointed to credit default options
pursuant to CBOE's existing requirements,\20\ as supplemented by
proposed CBOE Rule 29.17. Additionally, CBOE represents that there will
be a maximum of one series per quarterly expiration in a given credit
default option class, and that it, and the Options Price Reporting
Authority (``OPRA''), have the necessary systems capacity to handle the
additional quote volume anticipated to be associated with credit
default options.
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\17\ See proposed CBOE Rule 29.11.
\18\ See proposed CBOE Rules 29.11-29.17 and 29.19.
\19\ OCC Rule 805 sets forth the expiration date exercise
procedures for options cleared and settled by the OCC.
\20\ See Chapter VIII of CBOE's Rules.
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Once a particular credit default option class has been approved for
listing and trading, the Exchange would, from time to time, open for
trading a series of that class. If a credit default option initially
approved for trading no longer meets the Exchange's requirements for
continued approval, the Exchange would not open for trading any
additional series of options and, as provided in CBOE Rule 5.4, could
prohibit any opening purchase transactions in such series. The proposed
trading rules for credit default options are designed to create an
environment that takes into account the small number of transactions
likely to occur, while providing price improvement and the transparency
benefits of competitive Exchange floor bidding, as compared to the
over-the-counter (``OTC'') market.
Upon the confirmation of a credit event or the redemption of all
Relevant Obligations, the applicable credit default option class would
cease trading and all outstanding contracts in that class would be
subject to automatic exercise. In addition, the CBOE's trading halt
procedures applicable to equity options shall apply to credit default
options.\21\ When determining whether to institute a trading halt in
credit default options, CBOE floor officials would consider whether
current quotations for the Relevant Obligation(s) or other securities
of the Reference Entity are unavailable or have become unreliable. The
Exchange's board of directors shall also have the power to impose
restrictions on transactions or exercises in one or more series of
credit default options as the board, in its judgment, determines
advisable in the interests of maintaining a fair and orderly market or
otherwise deems
[[Page 32374]]
advisable in the public interest or for the protection of
investors.\22\
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\21\ See CBOE Rules 6.3 and 6.3B; proposed CBOE Rule 29.13.
\22\ See proposed CBOE Rule 29.8.
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D. Clearance and Settlement
Because credit default options do not have an exercise price, they
do not, by their terms, meet the definition of ``standardized options''
for purposes of Rule 9b-1 under the Act.\23\ However, as discussed
herein, the Commission today is using its authority pursuant to Rule
9b-1 to designate credit default options as ``standardized options''
under Rule 9b-1. Consequently, credit default option transactions would
be eligible for clearance and settlement by the OCC in accordance with
procedures that are substantially similar to existing systems and
procedures for the clearance and settlement of exchange-traded
options.\24\
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\23\ See 17 CFR 240.9b-1.
\24\ On February 13, 2007, the OCC filed with the Commission
pursuant to Section 19(b)(1) of the Act, 15 U.S.C. 78s(b)(1), and
Rule 19b-4 thereunder, 17 CFR 240.19b-4, a proposed rule change to
enable it to clear and settle credit default options proposed to be
listed by CBOE. The proposed rule change was published for comment
in the Federal Register on February 27, 2007. Securities Exchange
Act Release No. 55362, 72 FR 9826 (March 5, 2007). On March 7, 2007,
the OCC filed Amendment No. 1 to the proposed rule change. See SR-
OCC-2007-01 (as amended, the ``OCC Proposal''). The Commission has
not yet taken action on the OCC proposal.
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E. Adjustments
Credit default options will be subject to adjustments in two
circumstances.\25\ First, if the original Reference Entity is succeeded
by another entity in accordance with the terms of the underlying debt
security, the related credit default options would be replaced by one
or more credit default options derived from the debt securities of the
successor entity or entities. To the extent necessary and appropriate
for the protection of investors and the public interest, all other
terms and conditions of the successor options would be the same as the
original credit default options.
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\25\ See CBOE Proposed Rule 29.4.
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Second, if the specific debt security (the Reference Obligation) is
redeemed during the life of the credit default option, another debt
security of the Reference Entity would be specified as the new
Reference Obligation. In the event that all debt securities of the
Reference Entity (i.e., all Relevant Obligations) are redeemed during
the life of the credit default option, the option would cease trading
and, assuming that CBOE has not confirmed a credit event, the contract
payout would be $0.
F. Position Limits
Pursuant to proposed CBOE Rule 29.5, credit default options will be
subject to a position limit equal to 5,000 contracts on the same side
of the market. Credit default options shall not be aggregated with
option contracts on the same underlying security and will not be
subject to the hedge exemption to CBOE's standard position limits.
Instead, the following hedge exemption strategies and positions shall
be exempt from CBOE's position limits: (i) A credit default option
position ``hedged'' or ``covered'' by an appropriate amount of cash to
meet the cash settlement amount obligation (e.g., $100,000 for a credit
default option with an exercise settlement value of $100 multiplied by
a contract multiplier of 1,000); and (ii) a credit default option
position ``hedged'' or ``covered'' by an amount of an underlying debt
security(ies) that serves as a Relevant Obligation(s) or other
securities, instruments, or interests related to the Reference Entity
that is sufficient to meet the cash settlement amount obligation.\26\
Also, CBOE's market-maker and firm facilitation exemptions to position
limits will apply.\27\
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\26\ See proposed CBOE Rule 29.5.
\27\ Proposed CBOE Rule 29.5 requires that for purposes of its
market-maker hedge exemption (CBOE Rule 4.11.05) the position must
be within 20% of the applicable limit before an exemption would be
granted. With respect to CBOE's firm facilitation exemption (CBOE
Rule 4.11.06), proposed CBOE Rule 29.5 provides that the aggregate
exemption position could not exceed three times the standard limit
of 5,000 contracts.
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G. Margin
The margin (both initial and maintenance) required for writing
short and long positions in credit default options will be as follows:
\28\
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\28\ See proposed CBOE Rule 12.3(l); Amendment No. 5.
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For a qualified customer \29\ carrying a long position in
credit default options, the margin requirement will be 20% of the
current market value of the credit default option.
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\29\ Proposed CBOE Rule 12.3(l)(1)(i) defines ``qualified
customer'' as a person or entity that owns and invests on a
discretionary basis no less than $5,000,000 in investments.
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For a non-qualified customer carrying a long position in a
credit default option, the margin requirement will be 100% of the
current market value of the credit default option.
For a non-qualified customer carrying a short position in
a credit default option, the margin requirement will be the cash
settlement amount, i.e., $100,000 per contract.
For a qualified customer carrying a short position in a
credit default option, the margin requirement will be the lesser of the
current market value plus 20% of the cash settlement amount or the cash
settlement amount.
These requirements may be satisfied by a deposit of cash or marginable
securities. These requirements may not be satisfied by presentation to
the member organization carrying the customer's account of a letter of
credit meeting the requirements of proposed CBOE Rule
12.3(l)(1)(iii).\30\
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\30\ In Amendment No. 5, CBOE deletes from proposed rule
12.3(l)(1)(iii) the option of using a letter of credit to satisfy
margin requirements applicable to credit default options and makes
non-substantive corrections to the formatting of proposed CBOE Rule
12.3(l)(1)(iii) and the ``Interpretations and Policies'' heading
that accompanies CBOE Rule 12.3.
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A credit default option carried short in a customer's account will
be deemed a covered position, and eligible for the cash account,
provided any one of the following is either held in the account at the
time the option is written or is received into the account promptly
thereafter: (i) Cash or cash equivalents equal to 100% of the cash
settlement amount or (ii) an escrow agreement. The Exchange believes
that these requirements strike the appropriate balance and adequately
address concerns that a member or its customer may try to maintain an
inordinately large unhedged position in credit default options. In
addition, in Amendment No. 5, the Exchange notes that, in accordance
with CBOE Rule 12.3(a)(3), an escrow agreement must be issued in a form
acceptable to the Exchange, and that it has traditionally recognized as
acceptable the escrow agreement forms of the OCC and the New York Stock
Exchange.
In Amendment No. 5, the Exchange also represents the following:
``As part of its regulatory oversight of member organizations,
the Exchange generally reviews member organizations' compliance with
margin requirements applicable to customer accounts. In the future,
the Exchange will include [c]redit [d]efault [o]ption margin
requirements as part of this review. Additionally, the Exchange will
review member organizations' internal procedures for managing credit
risk associated with extending margin to customers trading [c]redit
[d]efault [o]ptions. The Exchange also notes that, pursuant to CBOE
Rule 12.10, the Exchange may at any time impose higher margin
requirements when it deems such higher margin requirements
advisable.''
Lastly, in Amendment No. 5, the Exchange makes non-substantive
changes to the text of CBOE Rule 12.5, to clarify that a credit default
option that is carried for the account of a qualified investor may be
deemed to
[[Page 32375]]
have market value for the purposes of CBOE Rule 12.3(c).
H. Surveillance
The Exchange has represented that it will have in place adequate
surveillance procedures to monitor trading in credit default options
prior to listing and trading such options.
III. Solicitation of Comments
Interested persons are invited to submit written data, views, and
arguments concerning Amendment No. 5, including whether Amendment No. 5
is consistent with the Act. Comments may be submitted by any of the
following methods:
Electronic Comments
Use the Commission's Internet comment form (https://
www.sec.gov/rules/sro.shtml); or
Send an e-mail to rule-comments@sec.gov. Please include
File Number SR-CBOE-2006-84 on the subject line.
Paper Comments
Send paper comments in triplicate to Nancy M. Morris,
Secretary, Securities and Exchange Commission, Station Place, 100 F
Street, NE., Washington, DC 20549-1090.
All submissions should refer to Amendment No. 5 to File Number SR-CBOE-
2006-84. This file number should be included on the subject line if e-
mail is used. To help the Commission process and review your comments
more efficiently, please use only one method. The Commission will post
all comments on the Commission's Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the submission, all subsequent amendments,
all written statements with respect to the proposed rule change that
are filed with the Commission, and all written communications relating
to the proposed rule change between the Commission and any person,
other than those that may be withheld from the public in accordance
with the provisions of 5 U.S.C. 552, will be available for inspection
and copying in the Commission's Public Reference Room. Copies of such
filing also will be available for inspection and copying at the
principal office of the Exchange. All comments received will be posted
without change; the Commission does not edit personal identifying
information from submissions. You should submit only information that
you wish to make available publicly. All submissions should refer to
Amendment No. 5 of File Number SR-CBOE-2006-84 and should be submitted
on or before July 3, 2007.
IV. Discussion
The Commission finds that the proposed rule change is consistent
with the requirements of the Act and the rules and regulations
thereunder applicable to a national securities exchange.\31\ In
particular, the Commission finds that the proposal is consistent with
Section 6(b)(5) of the Act,\32\ which requires, among other things,
that the rules of an exchange be designed to prevent fraudulent and
manipulative acts and practices; to promote just and equitable
principles of trade; to foster cooperation and coordination with
persons engaged in regulating, clearing, processing information with
respect to, and facilitating transactions in securities; to remove
impediments to and perfect the mechanism of a free and open market and
a national market system; and, in general to protect investors and the
public interest. The CBOE's proposal, by enabling CBOE to offer a
security that will be listed and traded on the Exchange, as opposed to
the OTC market, would extend to investors the benefits of a listed
exchange market, which include: A centralized market center; an auction
market with posted, transparent market quotations and transaction
reporting; standardized contract specifications; and the guarantee of
the OCC.
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\31\ In approving this proposed rule change, the Commission
notes that it has considered the proposed rule's impact on
efficiency, competition, and capital formation. See 15 U.S.C.
78c(f).
\32\ 15 U.S.C. 78f(b)(5).
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As a threshold matter, the Commission finds that the credit default
options proposed by CBOE are securities. Section 3(a)(10) of the Act
\33\ defines security to include, in part, ``any put, call, straddle,
option or privilege on any security, certificate of deposit, or group
or index of securities (including any interest therein or based on the
value thereof).'' After careful analysis, the Commission finds that
credit default options are options \34\ based on the value of a
security or securities and, therefore, securities under Section
3(a)(10) of the Act; \35\ in addition, the Commission finds that credit
default options are options on an interest in, or based on the value of
an interest in, a security or securities and, therefore, are securities
under Section 3(a)(10) of the Act.\36\
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\33\ 15 U.S.C. 78c(a)(10).
\34\ Although credit default options do not share every feature
of a classic option, the Commission nonetheless finds that credit
default options are option contracts. In particular, the Commission
notes that the buyer of a credit default option pays to the seller a
nonrefundable premium, has rights but no further obligations under
the contract, and has no further risk exposure because the seller
bears all the risk of the credit event occurring. See United States
v. Bein, 728 F.2d 107, 112 (2d Cir. 1984) (highlighting
characteristics that distinguish options from futures contracts).
\35\ 15 U.S.C. 78c(a)(10).
\36\ 15 U.S.C. 78c(a)(10). In determining whether a derivative
is a security, the Commission and the courts have looked to the
economic reality of the product. See Caiola v. Citibank, N.A., New
York, 295 F.3d 312, 325 (2d Cir. 2002), quoting United Housing
Foundation v. Foreman, 421 U.S. 837, 848 (1975) (``In searching for
the meaning and scope of the word `security' * * * the emphasis
should be on economic reality''). Construing the definition of a
security in this manner permits the Commission and the courts
``sufficient flexibility to ensure that those who market investments
are not able to escape the coverage of the Securities Acts by
creating new instruments that would not be covered by a more
determinate definition.'' Reves v. Ernst & Young, 494 U.S. 56, 63
n.2 (1990).
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The Commission interprets ``based on the value [of a security or
securities]'' in Section 3(a)(10) of the Act \37\ to include options
whose pricing in the secondary market moves in relation to the value of
the underlying security or securities of the option in question. Thus
the fact that the payout of a cash-settled option will not increase or
decrease based on the price movement of the underlying security of that
option is not dispositive.\38\
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\37\ Id.
\38\ In addressing whether a ``digital option'' or a ``binary
option'' with a fixed payout is an option based on the value of a
security or securities, the court in Stechler v. Sidley, Austin
Brown & Wood, L.L.P., 382 F.Supp.2d 580, 596-97 (S.D.N.Y. 2005),
held that the issue ultimately turned on questions of fact and
declined to decide the issue on a motion to dismiss. However, the
court's analysis made clear that the existence of a fixed payout
that is not tied in a proportionate manner to the price of an
underlying security is not a determining factor in deciding whether
an instrument is an option on a security. Rather, the court accepted
that, in evaluating the economic reality of an instrument, it is
appropriate to consider whether the resale value of the instrument
moves in relation to the movement of an underlying reference.
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Because credit default options are not currently traded, there is
no empirical data regarding their pricing in the secondary market.
However, credit default options are essentially exchange-traded
equivalents of single-name, OTC credit default swaps.\39\ A single-name
[[Page 32376]]
credit default swap is an agreement between a protection buyer and a
protection seller whereby the buyer pays a periodic fee in return for a
contingent payment by the seller upon the occurrence of a credit event
with respect to one or more reference obligations of a reference
entity. Credit events typically include one or more of the following:
(1) Bankruptcy, (2) obligation acceleration, (3) obligation default,
(4) a failure to pay, (5) repudiation or moratorium, or (6)
restructuring. Similarly, as explained above, each credit default
option shall specify (a) the Reference Entity, (b) the specific debt
security or securities that serve as its Reference Obligation or other
Relevant Obligations, and (c) the applicable events of default that
trigger payout (as determined in accordance with the terms of the
Reference Obligation or other Relevant Obligations), which could
include such events as a failure to pay, obligation acceleration or
default, and restructuring. Hence, credit default options have
essentially the same structure as credit default swaps.
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\39\ Despite the similarities between credit default options and
OTC credit default swaps, the Commission wishes to make two things
clear. First, because credit default options will be exchange-traded
and not individually negotiated (and not necessarily between
eligible contract participants), they are not qualifying swap
agreements under Section 206A of the Gramm-Leach-Bliley Act
(``GLBA''), 15 U.S.C. 78c note, and, therefore, not excluded from
the definition of security by Section 3A of the Act, 15 U.S.C. 78c-
1. Second, certain OTC credit default swaps are not securities. The
finding that credit default options are securities because they are
options based on the value of a security might suggest that OTC
credit default swaps are also options based on the value of a
security or securities and, therefore, excluded from the definition
of swap agreement because Section 206A(b)(1) of the GLBA, 15 U.S.C.
78c note, excludes from the definition of swap agreement ``any put,
call, straddle, option, or privilege on any security, certificate of
deposit, or group or index of securities, including any interest
therein or based on the value thereof.'' However, Congress
specifically enumerated ``credit default swaps'' (without defining
the term) as one example of a qualifying swap agreement. See Section
206A(a)(3) of the GLBA, 15 U.S.C. 78c note. The Commission views the
specific enumeration of ``credit default swaps'' as reflecting the
intention of Congress to exclude certain OTC credit default swaps
from the definition of security pursuant to Sections 206B & C of the
GLBA, 15 U.S.C. 78c note. Credit default swaps that involve terms
similar to credit default options, but that are otherwise excluded
from the definition of security because they are qualifying swap
agreements, remain subject to the Commission's antifraud
jurisdiction (including authority over insider trading) as
``security-based swap agreements'' under Section 206B of the GLBA,
15 U.S.C. 78c note.
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In the case of a credit default swap, the amount the buyer pays for
protection is based on a quoted spread expressed in basis points on a
notional amount specified in the swap agreement. This quoted spread is
often referred to as a ``CDS spread'' and is principally based on the
probability that the Reference Entity will default (i.e., its
creditworthiness). More specifically, the CDS spread represents the
price required by a swap counterparty to compensate it for the credit
risk associated with the potential default on a particular reference
obligation or obligations of an issuer. Similarly, the value of a debt
security is a function of the issuer's creditworthiness, which is
expressed in terms of a ``yield spread'' (sometimes called ``credit
spread''). The yield (or credit) spread is the difference between the
yield on the debt instrument and the yield on a debt security of
similar maturity whose yield represents pure interest rate risk, such
as U.S. Treasuries,\40\ and represents the additional yield required by
an investor to compensate it for the credit risk associated with the
potential default on the particular debt instrument of an issuer.\41\
As a consequence of this relationship between debt securities and
credit default swaps, the credit default swap market enables more
widespread trading in an issuer's creditworthiness than was previously
possible.
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\40\ Some academics have hypothesized that there may be some
deviation between the yield on U.S. Treasuries and pure interest
rate risk because bond interest is subject to state tax but U.S.
Treasuries are not. See, e.g., Haibin Zhu, An Empirical Comparison
of Credit Spreads between the Bond Market and the Credit Default
Swap Market, BIS Working Papers No. 160 (August 2004) (also noting
that transparency and the widespread use of U.S. Treasuries as
collateral could explain apparent deviations).
\41\ While the terms of both corporate securities and credit
default swaps are established when parties enter into the respective
contracts, the fair market value of these contracts can vary over
the life of the contracts in response to changing perceptions of the
creditworthiness of an issuer.
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There is a close empirical correlation between the price of a
credit default swap (as expressed in the CDS spread) and the yield (or
credit) spread of the specific reference obligation or obligations of
that credit default swap.\42\ This correlation is to be expected
because the valuation of credit default swaps and debt securities are
each based on credit risk, and because of the potential for arbitrage
between the secondary bond market and the credit default swap
market.\43\ Similarly, because credit default options are exchange-
traded equivalents of credit default swaps, the Commission expects that
there will be a close empirical correlation between the pricing of a
specific credit default option during the life of the contract and the
yield spread of the Reference Obligation or other Relevant Obligations
of that credit default option.
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\42\ See, e.g., Roberto Blanco, Simon Brennan, and Ian W. Marsh,
An Empirical Analysis of the Dynamic Relation between Investment-
Grade Bonds and Credit Default Swaps, The Journal of Economics,
Volume LX, No. 5 (Oct. 2005) (finding credit default swap spreads to
be quite close to bond yield spreads).
\43\ See Zhu, An Empirical Comparison of Credit Spreads between
the Bond Market and the Credit Default Swap Market, supra note 40.
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We further note, more generally, that credit default options
expressly reference in their payout conditions a term of an underlying
security that is material to the value of that security. A credit
default option will pay out if there is a failure to pay or other
default event under the terms of the underlying debt security.
For these reasons, credit default options are options ``based on
the value [of a security or securities]'' and, therefore, securities.
In addition, the Commission has determined that credit default
options are options on an ``interest in,'' or based on the value of an
interest in, a security or securities within the meaning of Section
3(a)(10) of the Act.\44\ A security is a collection of rights (and
obligations) running between the issuer and the holder of the security.
The concept of an ``interest in'' a security plainly includes rights
generating a pecuniary interest in a security, such as the right to a
dividend payment or bond (coupon) payment. One relevant ``interest in''
a debt security underlying a credit default option is the right to
receive (coupon) payments under the terms of that debt security. When a
(coupon) payment is not made, impairing the value of that interest, the
protection seller must make a payment to the protection buyer.
Similarly, a specified default event may trigger other rights of a
holder of the debt security. The default events that trigger exercise
and payment under the credit default option are meaningful only because
they are material terms of a security, essential to the debt holder's
rights and interests in that security.\45\ The credit default option
payout is contingent on these security-dependent events. For these
reasons, credit default options are options on an interest in, or based
on the value of an interest in, a security or securities.\46\
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\44\ 15 U.S.C. 78c(a)(10).
\45\ Although certain default events trigger the exercise and
payment of a credit default option, it would not be accurate to
describe these options as options on ``an event''. There is no event
delivered upon exercise of the option, rather a payment is
delivered. The crucial question is what causes the option to be in-
the-money and pay out. In the case of credit default options, it is
an event that is created by a security.
\46\ It is important to note that merely because the option does
not transfer ownership of the interest or right in a security--but
instead becomes in-the-money and provides a cash payment if certain
security rights are triggered--does not mean the option is not on an
interest in a security. Cf. Caiola, 295 F.3d 312 (2d Cir. 2002)
(including within the definition of ``security'' an option that did
not deliver an actual security or interest in a security, but merely
a cash payment).
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Moreover, the economic reality of credit default options supports
the conclusion that credit default options are securities. Taking a
short position (i.e., taking on the role of a protection seller) via
credit default options would be akin to purchasing the corporate bond
that is the Reference Obligation or other Relevant Obligations of that
credit
[[Page 32377]]
default option with the interest rate risk fully hedged. Both give the
investor the same risk exposure to creditworthiness of an issuer.
Indeed, credit default options may even more closely reflect the
financial condition of an SEC-registered issuer because, unlike
corporate bonds, which reflect both an issuer's creditworthiness and
general interest rate risk, credit default options would only reflect
an issuer's creditworthiness. That ability to isolate and transfer
credit risk, backed by the guarantee of a central counterparty and the
transparency of an exchange, should provide investors with additional
opportunities to gain exposure to the public debt market.
For these reasons, the Commission finds that credit default options
are options based on the value of, and options on interests in or based
on the value of interests in, a security or securities of the Reference
Entity and, therefore, securities under Section 3(a)(10) of the
Act.\47\
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\47\ 15 U.S.C. 78c(a)(10).
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Further, the Commission believes that the listing rules proposed by
CBOE for credit default options are reasonable and consistent with the
Act. The Commission notes in particular that a credit default option
must be based on a Reference Obligation issued by an entity that issues
registered equity securities that are NMS stocks and that meet the
Exchange's standards for listing an equity option. These requirements
are reasonably designed to facilitate investors' access to information
about the Reference Entity that may be necessary to price a credit
default option appropriately.
The Commission believes that the proposed position limits and
margin rules for credit default options are reasonable and consistent
with the Act. The proposed position limit of 5,000 contracts in any
credit default option class appears to reasonably balance the promotion
of a free and open market for these securities with minimization of
incentives for market manipulation and insider trading. The proposed
margin rules appear reasonably designed to deter a member or its
customer from assuming an imprudent position in credit default options.
In support of this proposal, the Exchange made the following
representations:
The Exchange will have in place adequate surveillance
procedures to monitor trading in credit default options prior to
listing and trading such options, thereby helping to ensure the
maintenance of a fair and orderly market for trading in credit default
options.
The Exchange and the OPRA will have the necessary systems
capacity to accommodate the additional volume associated with credit
default options as proposed.
This approval order is conditioned on CBOE's adherence to these
representations.
For the foregoing reasons, the Commission finds that the proposed
rule is consistent with the Act.
V. Accelerated Approval
The Commission finds good cause for approving the proposed rule
change, as modified by Amendment No. 5, prior to the thirtieth day
after publishing notice of Amendment No. 5 in the Federal Register
pursuant to Section 19(b)(2) of the Act.\48\ In Amendment No. 5, CBOE:
(1) Modified the text of the proposed margin requirements applicable to
credit default options contained in proposed Rules 12.3 and 12.5; (2)
made corresponding changes to the discussion sections of the Form 19b-4
and the Exhibit 1 thereto; and (3) inserted information in the
discussion sections of the Form 19b-4 and the Exhibit 1 thereto
regarding the form of escrow agreements and the Exchange's supervision
of member organizations that extend margin to customers trading Credit
Default Options.\49\ The Commission believes that Amendment No. 5
raises no significant regulatory issues. The Commission therefore finds
good cause exists to accelerate approval of the proposed change, as
modified by Amendment No. 5, pursuant to Section 19(b)(2) of the Act.
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\48\ 15 U.S.C. 78s(b)(2). Pursuant to Section 19(b)(2) of the
Act, the Commission may not approve any proposed rule change, or
amendment thereto, prior to the thirtieth day after the date of
publication of the notice thereof, unless the Commission finds good
cause for so doing.
\49\ The changes pursuant to Amendment No. 5 are discussed more
fully in Section II.G, supra.
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VI. Designation of Credit Default Options Pursuant to Rule 9b-1
Rule 9b-1 establishes a disclosure framework for standardized
options that are traded on a national securities exchange and cleared
through a registered clearing agency. Under this framework, the
exchange on which a standardized option is listed and traded must
prepare an Options Disclosure Document (``ODD'') that, among other
things, identifies the issuer and describes the uses, mechanics, and
risks of options trading, in language that can be easily understood by
the general investing public. The ODD is treated as a substitute for
the traditional prospectus. A broker-dealer must provide a copy of the
ODD to each customer at or before approving of the customer's account
for trading any standardized option.\50\ Any amendment to the ODD must
be distributed to each customer whose account is approved for trading
the options class for which the ODD relates.\51\
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\50\ See 17 CFR 240.9b-1(d)(1).
\51\ See 17 CFR 240.9b-1(d)(2).
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Under Rule 9b-1, use of the ODD is limited to ``standardized
options'' for which there is an effective registration statement on
Form S-20 under the Securities Act or that are exempt from
registration.\52\ The Commission specifically reserved in Rule 9b-1 the
ability to designate as standardized options other securities ``that
the Commission believes should be included within the options
disclosure framework.'' \53\
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\52\ See 17 CFR 240.9b-1(b)(1) and (c)(8). See also 17 CFR
230.238. Rule 238 under the Securities Act provides an exemption
from the Securities Act for any standardized option, as defined by
Rule 9b-1(a)(4) under the Act, with limited exceptions. Rule 238
does not exempt standardized options from the antifraud provisions
of Section 17 of the Securities Act, 15 U.S.C. 77q. Also, offers and
sales of standardized options by or on behalf of the issuer of the
underlying security or securities, an affiliate of the issuer, or an
underwriter, will constitute an offer or sale of the underlying
security or securities as defined in Section 2(a)(3) of the
Securities Act, 15 U.S.C. 77b(a)(3). See also Securities Act Release
No. 8171 (December 23, 2002), 68 FR 188 (January 2, 2003) (Exemption
for Standardized Options From Provisions of the Securities Act of
1933 and From Registration Requirements of the Exchange Act of
1934).
\53\ See Securities Exchange Act Release No. 19055 and
Securities Act Release No. 6426 (September 16, 1982), 47 FR 41950,
41954 (September 23, 1982).
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The Commission hereby designates credit default options, as defined
in the OCC Proposal,\54\ as standardized options for purposes of Rule
9b-1 under the Act. Credit default options do not meet the definition
of ``standardized options,'' because they do not have an exercise
price. However, they resemble
[[Page 32378]]
standardized options in other significant respects. Credit default
options have an underlying security and an expiration date. Like other
standardized options, credit default options have standardized terms
relating to exercise procedures, contract adjustments, time of
issuance, effect of closing transactions, restrictions, and other
matters pertaining to the rights and obligations of holders and
writers. Further, credit default options are designed to provide market
participants with the ability to hedge their exposure to an underlying
security. The fact that credit default options lack a specified
exercise price does not detract from this option-like benefit. The
Commission believes that the fact that the OCC, the clearing agency for
all standardized options, is willing to serve as issuer of credit
default options supports the view that adding credit default options to
the standardized option disclosure framework is reasonable.
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\54\ For purposes of its proposal, OCC would define the term
``credit default option'' as an option that is automatically
exercised upon receipt by the OCC of a credit event confirmation
with respect to the reference obligation(s) of a reference entity.
Credit default options have only two possible payoff outcomes:
Either a fixed automatic exercise settlement amount or nothing at
all. See proposed Section 1.C.(2) of Article XIV of the OCC By-Laws.
I11``Credit event'' would be as defined in the rules of
the exchange on which the credit default options are listed, with
respect to a reference obligation for such option. See proposed
Section 1.C.(3) of Article XIV of the OCC By-Laws.
I11``Reference entity'' would mean the issuer or
guarantor of the reference obligation(s). See proposed Section
1.R.(1) of Article XIV of the OCC By-Laws.
I11``Reference obligations'' would mean one or more
debt securities the terms of which define a credit event for a class
of credit default options, as provided in the rules of the listing
exchange. See id.
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Therefore, the Commission hereby designates credit default options,
such as those proposed by CBOE, as standardized options for purposes of
Rule 9b-1 under the Act.
VII. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\55\ that the proposed rule change (SR-CBOE-2006-84) as modified by
Amendment Nos. 3, 4, and 5, be, and hereby is approved on an
accelerated basis.
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\55\ 15 U.S.C. 78s(b)(2).
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It is further ordered, pursuant to Rule 9b-1(a)(4) under the Act,
the credit default options, as defined in proposed rule change (SR-OCC-
2007-01) are designated as standardized options.
By the Commission.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E7-11273 Filed 6-11-07; 8:45 am]
BILLING CODE 8010-01-P