Self-Regulatory Organizations; The Depository Trust Company; Order Approving Proposed Rule Change, as Modified by Amendment No. 1, To Amend Its Operational Arrangements as It Applies to Structured Securities, 16403-16405 [E8-6256]
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Federal Register / Vol. 73, No. 60 / Thursday, March 27, 2008 / Notices
organization that: (i) Does not
significantly affect the protection of
investors or the public interest; (ii) does
not impose any significant burden on
competition; and (iii) does not have the
effect of limiting the access to or
availability of the system. The rule
change is simply a language clarification
of an existing NSX rule. Furthermore,
the rule change raises no novel issues
for the Commission and is consistent
with odd-lot order handling as
contemplated by Regulation NMS.
Accordingly, the proposal is effective
upon Commission receipt of the filing.
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 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:
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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–NSX–2008–07 on the
subject line.
provisions of 5 U.S.C. 552, will be
available for inspection and copying in
the Commission’s Public Reference
Room, on official business days between
the hours of 10 a.m. and 3 p.m. Copies
of such filing also will be available for
inspection and copying at the principal
office of the NSX. 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–NSX–
2008–07 and should be submitted on or
before April 17, 2008.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.13
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E8–6248 Filed 3–26–08; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–57542; File No. SR–DTC–
2007–11]
Self-Regulatory Organizations; The
Depository Trust Company; Order
Approving Proposed Rule Change, as
Modified by Amendment No. 1, To
Amend Its Operational Arrangements
as It Applies to Structured Securities
March 20, 2008.
I. Introduction
On September 7, 2007, The
Depository Trust Company (‘‘DTC’’)
Paper Comments
filed with the Securities and Exchange
• Send paper comments in triplicate
Commission (‘‘Commission’’) proposed
to Nancy Morris, Secretary, Securities
rule change SR–DTC–2007–11 pursuant
and Exchange Commission, 100 F
to Section 19(b)(1) of the Securities
Street, NE., Washington, DC 20549–
Exchange Act of 1934 (‘‘Act’’).1 The
1090.
proposed rule change was published for
All submissions should refer to File
comment in the Federal Register on
Number SR–NSX–2008–07. This file
November 26, 2007.2 The Commission
number should be included on the
received four comments to the proposed
subject line if e-mail is used. To help the rule change.3 On December 14, 2007,
Commission process and review your
13 17 CFR 200.30–3(a)(12).
comments more efficiently, please use
1 15 U.S.C. 78s(b)(1).
only one method. The Commission will
2 Securities Exchange Act Release No. 56795
post all comments on the Commission’s
(November 15, 2007), 72 FR 66009.
Internet Web site (https://www.sec.gov/
3 Simon Griffiths, Vice President, JP Morgan
rules/sro.shtml). Copies of the
(December 10, 2007); Tom Migneron, Principal,
submission, all subsequent
Edward Jones (December 11, 2007); Dan W.
Schneider, Baker & McKenzie LLP, Counsel to the
amendments, all written statements
Association of Global Custodians, Chicago, Illinois
with respect to the proposed rule
(December 12, 2007); Norman Eaker, Chairman,
change that are filed with the
Securities Industry and Financial Markets
Commission, and all written
Association, Operations Committee, Gussie Tate,
President, Securities Industry and Financial
communications relating to the
Markets Association, Dividend Division, and
proposed rule change between the
Chairman, Securities
Commission and any person, other than Thomas Hamilton, ViceMarkets Association, MBS
Industry and Financial
those that may be withheld from the
and Securitized Products Division Executive
Committee (December 19, 2007).
public in accordance with the
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16403
DTC filed Amendment No. 1 to the
proposed rule change.4 The proposed
rule change, as Modified by
Amendment No. 1, was published for
comment in the Federal Register.5 The
Commission received one comment to
Amendment No. 1.6 For the reasons
discussed below, the Commission is
approving the proposed rule change, as
amended.
II. Description
DTC’s Operational Arrangements is a
contractual agreement between DTC,
issuers, and paying agents that outlines
the procedural and operational
requirements for an issue to become and
remain DTC eligible. The proposed rule
change amends DTC’s ‘‘Operational
Arrangements Necessary for an Issue to
Become and Remain Eligible for DTC
Services’’ (‘‘Operational Arrangements’’)
as it applies to Structured Securities in
order to: extend the deadline by which
paying agents of such securities must
submit periodic payment rate
information to DTC; establish
Structured Securities classifications;
establish an exception processing fee
applied to certain Structured Securities
whose features prevent paying agents
from complying with the extended
deadline; and provide that DTC track
and make publicly available reports on
paying agent performance as it relates to
timeliness and accuracy of Structured
Securities payment rate information
submitted to DTC.
A Structured Security, such as a
collateralized mortgage obligation or
asset-backed security, is a bond backed
by a pool of underlying financial assets.
The underlying assets generally consist
of receivables such as mortgages, credit
card receivables, or student or other
bank loans for which the timing of
principal payments by the underlying
obligors may be variable and
unpredictable. A Structured Security
may also incorporate credit
enhancements or other rights that affect
the amount and timing of payments to
investors.
Communication of periodic payment
rates of principal and interest (‘‘P&I’’) to
the end investors in Structured
Securities depends on application of
4 As explained below, Amendment No. 1 replaced
and superseded the original filing in its entirety.
Amendment No. 1 removed reference to the
imposition of a processing fee on January 1, 2008,
and corrected the identity of the party that will
identify an issue as conforming or non-conforming
and will submit a written attestation giving the
reason for non-conformance.
5 Securities Exchange Act Release No. 57283
(February 6, 2008), 73 FR 8384.
6 Carol A. Jameson, Vice President and Senior
Counsel, The Depository Trust Company (March 5,
2008).
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Federal Register / Vol. 73, No. 60 / Thursday, March 27, 2008 / Notices
stringent time frames for information
reporting and significant
interdependencies among servicers of
the underlying assets, specifically
trustees, custodians, paying agents on
the securities, DTC, and the financial
intermediaries that act on behalf of the
investors. Given the complexity of
structure and calculations of cash flow
from the underlying assets through the
issuer to the end investor and given the
interdependencies on timeliness and
accuracy of performance throughout the
chain of servicers and intermediaries,
timely and accurate submission of
payment rate information on Structured
Securities may be difficult to achieve.
As a result, payment rates typically are
announced late on a significant number
of issues, and the number of postpayable adjustments made to correct
inaccurate payments resulting from
inaccurate payment rate information is
higher than for any other security type.
Furthermore, the volume of P&I
payments for Structured Securities
processed through DTC has grown
rapidly in recent years and currently
represents approximately 25% of all P&I
payments processed through DTC.
Incorrect and late payment rate
reporting causes increased operations
processing costs, inefficient cash
management, and loss of income.
pwalker on PROD1PC71 with NOTICES
1. Extending the Deadline for Reporting
on Payment Detail
Currently, the majority of Structured
Securities have features that prevent
paying agents from being able to meet
the current Operational Arrangements
payment rate reporting deadline. DTC is
amending the Operational
Arrangements to require that the
payment notification regarding
Structured Securities be provided to
DTC by the paying agent preferably five
business days but no later than one
business day prior to the payable date.7
In addition, DTC is extending its current
processing deadline for receipt of
payment rate files from 7:00 p.m. to
11:30 p.m. The extended reporting
period deadlines should allow paying
agents to provide payment rates in a
timely and accurate fashion for a
majority of Structured Securities issues
and should permit the securities to
remain eligible for DTC’s services while
still providing DTC with adequate time
to process the information and make
timely payments to its participants.
7 Prior to this filing, payment notifications
regarding Structured Securities had to be provided
to DTC by the paying agent preferably five business
days but no later than two business day prior to the
payable date.
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16:08 Mar 26, 2008
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2. Securities Classifications
Due to the complexity of certain
Structured Securities, it is anticipated
that the paying agents for certain issues
will still not be able to meet the
amended Operational Arrangements
requirements for timely payment rate
reporting even with the extended
reporting period.8 Therefore, DTC is
categorizing Structured Securities as
‘‘conforming’’ or ‘‘non-conforming.’’
Non-conforming Structured Securities
will be issues for which the underwriter
and paying agent have concluded that
the security has features that will likely
preclude the paying agent from
submitting payment rate information to
DTC in conformity with the
requirements of the Operational
Arrangements. The conforming/nonconforming identification will be made
at the time the security is made eligible
at DTC. For each Structured Securities
underwriting that the underwriter and
paying agent identify as nonconforming, the underwriter and paying
agent shall submit a written attestation
giving the reason(s) why the paying
agent will be unable to submit payment
rate information to DTC in conformity
with the requirements of the
Operational Arrangements. DTC will in
turn identify non-conforming Structured
Securities to participants and other
relevant parties and will add an
indicator to the appropriate DTC
systems functions to denote nonconforming securities. Paying agents
also shall be required to evaluate their
entire portfolio of Structured Securities
that have previously been made eligible
and are currently on deposit at DTC to
identify non-conforming securities.
3. Exception Processing Fee Applicable
to Non-Conforming Securities
Late payment rate reporting leads to
increased costs to DTC and to servicers
and intermediaries. In order to recoup
the increased processing costs, DTC is
imposing an exception processing fee to
the managing underwriter of each nonconforming issue at the time of
underwriting. No exception processing
fee will be charged retroactively for
issues already on deposit at DTC prior
to the implementation of the fee. The
exception processing fee of $4,200 per
CUSIP was calculated based upon
anticipated additional costs of P&I
8 Although approximately 15% of Structured
Security issues currently fail to have rates
submitted to DTC in a timely manner, it is
estimated that approximately only half of these
have structural impediments to meeting the new
requirements. Late reporting in other instances is
believed to be curable by improved servicing and
reporting on the securities.
PO 00000
Frm 00160
Fmt 4703
Sfmt 4703
processing for non-conforming
Structured Securities.9
The aggregate net amount of the
exception processing fees will be
allocated and rebated on a pro rata basis
annually to the DTC participants for
whom DTC processed Structured
Securities P&I allocations. For each
participant, DTC will compare the
participant’s total number of allocations
to the total number of all participants’
allocations, and the resulting percentage
would be applied against the total
exception processing fund with the
resulting amount being rebated to the
participant. The total exception
processing fund will be the sum of all
exception processing fees less DTC’s
cost to administer the program.
4. Evaluation and Publication of Paying
Agent Performance
DTC will track and evaluate paying
agent performance with regard to
timeliness and accuracy of payment rate
reporting on Structured Securities and
make these evaluations available to DTC
participants and to the public. The
purpose of these evaluations is to
identify poor reporting and payment
performance by paying agents.
DTC plans to expand its paying agent
evaluation reports (‘‘Report Cards’’) that
are currently used to compare rate
submission performance and accuracy
of Structured Securities paying agents.
Currently the Report Cards are only
distributed among the paying agents
being compared. DTC will now make
the Report Cards available on its Web
site. The Report Cards will track and
will report on a monthly basis
performance by paying agent with
respect to the number of collateralized
mortgage obligations and asset-backed
securities announcements processed,
the number of late and amended
announcements, the payment dollars,
late payment dollars, the number of
payments, and the number of late
payments. Timeliness of payment rate
notification on non-conforming
Structured Securities will not be
included in the Report Cards. With
respect to all the other items set forth
above, paying agent performance
information for both conforming and
non-conforming Structured Securities
will be included in the Report Cards.
III. Comment Letters
The Commission received five
comments to the proposed rule
change.10 Four of the comment letters
9 The fee was filed with the Commission as part
of DTC’s annual establishment of fees. Securities
Exchange Act Release No. 34–57193 (January 24,
2008), 73 FR 5614.
10 Supra notes 3 and 4.
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Federal Register / Vol. 73, No. 60 / Thursday, March 27, 2008 / Notices
were from industry participants, and
one was from DTC in response to the
other four comment letters. While all of
the four industry commenters generally
supported the proposal, two raised
issues or sought clarification about the
proposal.
The comment letters submitted by JP
Morgan and Edward Jones both
expressed their support for the: (1)
Extension of the deadline for reporting
on payment detail, (2) creation of the
conforming and non-conforming
securities classifications, (3) creation of
the exception processing fee for nonconforming securities, and (4)
evaluation and publication of paying
agent performance.
The comment letter written on behalf
of the Association of Global Custodians
expressed its support for the: (1)
Creation of the conforming and nonconforming securities classifications
and (2) evaluation and publication of
paying agent performance. Although the
commenter expressed support for the
extension of the deadline for reporting
payment detail, the commenter stated
that DTC should monitor paying agent
performance to determine if the
reporting of payment detail trends
toward last-minute reporting or if the
extended deadline does not correlate
with a reduced incidence of errors and
adjustments. Although the commenter
expressed support for the creation of the
exception processing fee for nonconforming securities, it suggested that
the aggregate net amount of the
exception processing fee should be
rebated to participants based on their
transactions in non-conforming
securities only rather than to
participants based on their transactions
in all Structured Securities.
The comment letter written on behalf
of the Securities Industry and Financial
Markets Association expressed support
for the: (1) Extension of the deadline for
reporting on payment detail and (2)
evaluation and publication of paying
agent performance. Although the
commenter expressed support for the
creation of the conforming and nonconforming securities classifications, it
requested guidance on the criteria to be
used to determine whether a Structured
Security is non-conforming, whether an
issue’s classification can be changed,
and when the classification
determination will be required to be
submitted to DTC. The commenter
questioned whether it was appropriate
to require the underwriter to sign the
classification attestation rather than
allowing the underwriter to rely on the
paying agent’s attestation.
While the Securities Industry and
Financial Markets Association
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16:08 Mar 26, 2008
Jkt 214001
expressed support for the creation of the
exception processing fee, it questioned
whether the underwriter is the
appropriate party to pay the fee. It stated
its belief that the costs created by late
and erroneous submissions from
conforming issues should not be borne
by non-conforming issue underwriters.
The commenter also suggested that the
aggregate net amount of the exception
processing fee should be rebated to
participants based on their transactions
in non-conforming securities only rather
than to participants based on their
transactions in all Structured Securities.
In its comment letter, DTC stated that
the criteria for categorizing an issue as
‘‘non-conforming’’ would consist of a
general good-faith expectation, based on
information available at the time, as to
whether it is anticipated that DTC’s
deadlines for submission of rate
information will be met. It also stated
that both the paying agent and the
underwriter will be responsible to sign
the classification attestation and that
imposing the exception processing fee
on the underwriter is equitable and
consistent with DTC’s general practice.
Finally, the commenter confirmed that
while it will allocate exception
processing fee revenue pro rata to DTC
participants for whom DTC processed
any Structured Securities, it will review
the policy toward the end of 2008 to
determine whether future allocations
should be directed to participants based
only on their transactions in nonconforming securities.
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 registered clearing
agency. In particular, the Commission
believes the proposal is consistent with
the requirements of Section
17A(b)(3)(F),11 which, among other
things, requires that the rules of a
clearing agency are designed to remove
impediments to and perfect the
mechanisms of a national system for the
prompt and accurate clearance and
settlement of securities transactions.
The Commission finds that by enabling
more Structured Securities to be DTCeligible and by helping to make the
reporting of information about
Structured Securities more accurate and
timely, the proposed rule change, which
should make the communication of
payment rate information on Structured
Securities quicker and more efficient, is
consistent with this statutory obligation.
11 15
PO 00000
U.S.C. 78q–1(b)(3)(F).
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Fmt 4703
Sfmt 4703
16405
IV. Conclusion
On the basis of the foregoing, the
Commission finds that the proposal is
consistent with the requirements of the
Act and in particular with the
requirements of section 17A of the
Act 12 and the rules and regulations
thereunder.
It is therefore ordered, pursuant to
section 19(b)(2) of the Act,13 that the
proposed rule change (File No. SR–
DTC–2007–11), as modified by
Amendment No. 1, be, and hereby is,
approved.14
For the Commission by the Division of
Trading and Markets, pursuant to delegated
authority.15
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E8–6256 Filed 3–26–08; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–57543; File No. SR–OCC–
2008–03]
Self-Regulatory Organizations; The
Options Clearing Corporation; Notice
of Filing and Immediate Effectiveness
of a Proposed Rule Change Relating to
Cross-Margining
March 20, 2008.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 notice is hereby given that on
January 29, 2008, The Options Clearing
Corporation (‘‘OCC’’) filed with the
Securities and Exchange Commission
(‘‘Commission’’) the proposed rule
change as described in Items I, II, and
III below, which items have been
prepared primarily by OCC. OCC filed
the proposed rule change pursuant to
Section 19(b)(3)(A)(iii) of the Act 2 and
Rule 19b–4(f)(4) 3 thereunder so that the
proposal was effective upon filing with
the Commission. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The proposed rule change amends
Article VI, Clearance of Exchange
12 15
U.S.C. 78q–1.
U.S.C. 78s(b)(2).
14 In approving the proposed rule change, the
Commission considered the proposal’s impact on
efficiency, competition, and capital formation. 15
U.S.C. 78c(f).
15 17 CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 15 U.S.C. 78s(b)(3)(A)(iii).
3 17 CFR 240.19b–4(f)(4).
13 15
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Agencies
[Federal Register Volume 73, Number 60 (Thursday, March 27, 2008)]
[Notices]
[Pages 16403-16405]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-6256]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-57542; File No. SR-DTC-2007-11]
Self-Regulatory Organizations; The Depository Trust Company;
Order Approving Proposed Rule Change, as Modified by Amendment No. 1,
To Amend Its Operational Arrangements as It Applies to Structured
Securities
March 20, 2008.
I. Introduction
On September 7, 2007, The Depository Trust Company (``DTC'') filed
with the Securities and Exchange Commission (``Commission'') proposed
rule change SR-DTC-2007-11 pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (``Act'').\1\ The proposed rule change
was published for comment in the Federal Register on November 26,
2007.\2\ The Commission received four comments to the proposed rule
change.\3\ On December 14, 2007, DTC filed Amendment No. 1 to the
proposed rule change.\4\ The proposed rule change, as Modified by
Amendment No. 1, was published for comment in the Federal Register.\5\
The Commission received one comment to Amendment No. 1.\6\ For the
reasons discussed below, the Commission is approving the proposed rule
change, as amended.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ Securities Exchange Act Release No. 56795 (November 15,
2007), 72 FR 66009.
\3\ Simon Griffiths, Vice President, JP Morgan (December 10,
2007); Tom Migneron, Principal, Edward Jones (December 11, 2007);
Dan W. Schneider, Baker & McKenzie LLP, Counsel to the Association
of Global Custodians, Chicago, Illinois (December 12, 2007); Norman
Eaker, Chairman, Securities Industry and Financial Markets
Association, Operations Committee, Gussie Tate, President,
Securities Industry and Financial Markets Association, Dividend
Division, and Thomas Hamilton, Vice Chairman, Securities Industry
and Financial Markets Association, MBS and Securitized Products
Division Executive Committee (December 19, 2007).
\4\ As explained below, Amendment No. 1 replaced and superseded
the original filing in its entirety. Amendment No. 1 removed
reference to the imposition of a processing fee on January 1, 2008,
and corrected the identity of the party that will identify an issue
as conforming or non-conforming and will submit a written
attestation giving the reason for non-conformance.
\5\ Securities Exchange Act Release No. 57283 (February 6,
2008), 73 FR 8384.
\6\ Carol A. Jameson, Vice President and Senior Counsel, The
Depository Trust Company (March 5, 2008).
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II. Description
DTC's Operational Arrangements is a contractual agreement between
DTC, issuers, and paying agents that outlines the procedural and
operational requirements for an issue to become and remain DTC
eligible. The proposed rule change amends DTC's ``Operational
Arrangements Necessary for an Issue to Become and Remain Eligible for
DTC Services'' (``Operational Arrangements'') as it applies to
Structured Securities in order to: extend the deadline by which paying
agents of such securities must submit periodic payment rate information
to DTC; establish Structured Securities classifications; establish an
exception processing fee applied to certain Structured Securities whose
features prevent paying agents from complying with the extended
deadline; and provide that DTC track and make publicly available
reports on paying agent performance as it relates to timeliness and
accuracy of Structured Securities payment rate information submitted to
DTC.
A Structured Security, such as a collateralized mortgage obligation
or asset-backed security, is a bond backed by a pool of underlying
financial assets. The underlying assets generally consist of
receivables such as mortgages, credit card receivables, or student or
other bank loans for which the timing of principal payments by the
underlying obligors may be variable and unpredictable. A Structured
Security may also incorporate credit enhancements or other rights that
affect the amount and timing of payments to investors.
Communication of periodic payment rates of principal and interest
(``P&I'') to the end investors in Structured Securities depends on
application of
[[Page 16404]]
stringent time frames for information reporting and significant
interdependencies among servicers of the underlying assets,
specifically trustees, custodians, paying agents on the securities,
DTC, and the financial intermediaries that act on behalf of the
investors. Given the complexity of structure and calculations of cash
flow from the underlying assets through the issuer to the end investor
and given the interdependencies on timeliness and accuracy of
performance throughout the chain of servicers and intermediaries,
timely and accurate submission of payment rate information on
Structured Securities may be difficult to achieve. As a result, payment
rates typically are announced late on a significant number of issues,
and the number of post-payable adjustments made to correct inaccurate
payments resulting from inaccurate payment rate information is higher
than for any other security type. Furthermore, the volume of P&I
payments for Structured Securities processed through DTC has grown
rapidly in recent years and currently represents approximately 25% of
all P&I payments processed through DTC. Incorrect and late payment rate
reporting causes increased operations processing costs, inefficient
cash management, and loss of income.
1. Extending the Deadline for Reporting on Payment Detail
Currently, the majority of Structured Securities have features that
prevent paying agents from being able to meet the current Operational
Arrangements payment rate reporting deadline. DTC is amending the
Operational Arrangements to require that the payment notification
regarding Structured Securities be provided to DTC by the paying agent
preferably five business days but no later than one business day prior
to the payable date.\7\ In addition, DTC is extending its current
processing deadline for receipt of payment rate files from 7:00 p.m. to
11:30 p.m. The extended reporting period deadlines should allow paying
agents to provide payment rates in a timely and accurate fashion for a
majority of Structured Securities issues and should permit the
securities to remain eligible for DTC's services while still providing
DTC with adequate time to process the information and make timely
payments to its participants.
---------------------------------------------------------------------------
\7\ Prior to this filing, payment notifications regarding
Structured Securities had to be provided to DTC by the paying agent
preferably five business days but no later than two business day
prior to the payable date.
---------------------------------------------------------------------------
2. Securities Classifications
Due to the complexity of certain Structured Securities, it is
anticipated that the paying agents for certain issues will still not be
able to meet the amended Operational Arrangements requirements for
timely payment rate reporting even with the extended reporting
period.\8\ Therefore, DTC is categorizing Structured Securities as
``conforming'' or ``non-conforming.'' Non-conforming Structured
Securities will be issues for which the underwriter and paying agent
have concluded that the security has features that will likely preclude
the paying agent from submitting payment rate information to DTC in
conformity with the requirements of the Operational Arrangements. The
conforming/non-conforming identification will be made at the time the
security is made eligible at DTC. For each Structured Securities
underwriting that the underwriter and paying agent identify as non-
conforming, the underwriter and paying agent shall submit a written
attestation giving the reason(s) why the paying agent will be unable to
submit payment rate information to DTC in conformity with the
requirements of the Operational Arrangements. DTC will in turn identify
non-conforming Structured Securities to participants and other relevant
parties and will add an indicator to the appropriate DTC systems
functions to denote non-conforming securities. Paying agents also shall
be required to evaluate their entire portfolio of Structured Securities
that have previously been made eligible and are currently on deposit at
DTC to identify non-conforming securities.
---------------------------------------------------------------------------
\8\ Although approximately 15% of Structured Security issues
currently fail to have rates submitted to DTC in a timely manner, it
is estimated that approximately only half of these have structural
impediments to meeting the new requirements. Late reporting in other
instances is believed to be curable by improved servicing and
reporting on the securities.
---------------------------------------------------------------------------
3. Exception Processing Fee Applicable to Non-Conforming Securities
Late payment rate reporting leads to increased costs to DTC and to
servicers and intermediaries. In order to recoup the increased
processing costs, DTC is imposing an exception processing fee to the
managing underwriter of each non-conforming issue at the time of
underwriting. No exception processing fee will be charged retroactively
for issues already on deposit at DTC prior to the implementation of the
fee. The exception processing fee of $4,200 per CUSIP was calculated
based upon anticipated additional costs of P&I processing for non-
conforming Structured Securities.\9\
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\9\ The fee was filed with the Commission as part of DTC's
annual establishment of fees. Securities Exchange Act Release No.
34-57193 (January 24, 2008), 73 FR 5614.
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The aggregate net amount of the exception processing fees will be
allocated and rebated on a pro rata basis annually to the DTC
participants for whom DTC processed Structured Securities P&I
allocations. For each participant, DTC will compare the participant's
total number of allocations to the total number of all participants'
allocations, and the resulting percentage would be applied against the
total exception processing fund with the resulting amount being rebated
to the participant. The total exception processing fund will be the sum
of all exception processing fees less DTC's cost to administer the
program.
4. Evaluation and Publication of Paying Agent Performance
DTC will track and evaluate paying agent performance with regard to
timeliness and accuracy of payment rate reporting on Structured
Securities and make these evaluations available to DTC participants and
to the public. The purpose of these evaluations is to identify poor
reporting and payment performance by paying agents.
DTC plans to expand its paying agent evaluation reports (``Report
Cards'') that are currently used to compare rate submission performance
and accuracy of Structured Securities paying agents. Currently the
Report Cards are only distributed among the paying agents being
compared. DTC will now make the Report Cards available on its Web site.
The Report Cards will track and will report on a monthly basis
performance by paying agent with respect to the number of
collateralized mortgage obligations and asset-backed securities
announcements processed, the number of late and amended announcements,
the payment dollars, late payment dollars, the number of payments, and
the number of late payments. Timeliness of payment rate notification on
non-conforming Structured Securities will not be included in the Report
Cards. With respect to all the other items set forth above, paying
agent performance information for both conforming and non-conforming
Structured Securities will be included in the Report Cards.
III. Comment Letters
The Commission received five comments to the proposed rule
change.\10\ Four of the comment letters
[[Page 16405]]
were from industry participants, and one was from DTC in response to
the other four comment letters. While all of the four industry
commenters generally supported the proposal, two raised issues or
sought clarification about the proposal.
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\10\ Supra notes 3 and 4.
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The comment letters submitted by JP Morgan and Edward Jones both
expressed their support for the: (1) Extension of the deadline for
reporting on payment detail, (2) creation of the conforming and non-
conforming securities classifications, (3) creation of the exception
processing fee for non-conforming securities, and (4) evaluation and
publication of paying agent performance.
The comment letter written on behalf of the Association of Global
Custodians expressed its support for the: (1) Creation of the
conforming and non-conforming securities classifications and (2)
evaluation and publication of paying agent performance. Although the
commenter expressed support for the extension of the deadline for
reporting payment detail, the commenter stated that DTC should monitor
paying agent performance to determine if the reporting of payment
detail trends toward last-minute reporting or if the extended deadline
does not correlate with a reduced incidence of errors and adjustments.
Although the commenter expressed support for the creation of the
exception processing fee for non-conforming securities, it suggested
that the aggregate net amount of the exception processing fee should be
rebated to participants based on their transactions in non-conforming
securities only rather than to participants based on their transactions
in all Structured Securities.
The comment letter written on behalf of the Securities Industry and
Financial Markets Association expressed support for the: (1) Extension
of the deadline for reporting on payment detail and (2) evaluation and
publication of paying agent performance. Although the commenter
expressed support for the creation of the conforming and non-conforming
securities classifications, it requested guidance on the criteria to be
used to determine whether a Structured Security is non-conforming,
whether an issue's classification can be changed, and when the
classification determination will be required to be submitted to DTC.
The commenter questioned whether it was appropriate to require the
underwriter to sign the classification attestation rather than allowing
the underwriter to rely on the paying agent's attestation.
While the Securities Industry and Financial Markets Association
expressed support for the creation of the exception processing fee, it
questioned whether the underwriter is the appropriate party to pay the
fee. It stated its belief that the costs created by late and erroneous
submissions from conforming issues should not be borne by non-
conforming issue underwriters. The commenter also suggested that the
aggregate net amount of the exception processing fee should be rebated
to participants based on their transactions in non-conforming
securities only rather than to participants based on their transactions
in all Structured Securities.
In its comment letter, DTC stated that the criteria for
categorizing an issue as ``non-conforming'' would consist of a general
good-faith expectation, based on information available at the time, as
to whether it is anticipated that DTC's deadlines for submission of
rate information will be met. It also stated that both the paying agent
and the underwriter will be responsible to sign the classification
attestation and that imposing the exception processing fee on the
underwriter is equitable and consistent with DTC's general practice.
Finally, the commenter confirmed that while it will allocate exception
processing fee revenue pro rata to DTC participants for whom DTC
processed any Structured Securities, it will review the policy toward
the end of 2008 to determine whether future allocations should be
directed to participants based only on their transactions in non-
conforming securities.
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 registered clearing agency. In particular,
the Commission believes the proposal is consistent with the
requirements of Section 17A(b)(3)(F),\11\ which, among other things,
requires that the rules of a clearing agency are designed to remove
impediments to and perfect the mechanisms of a national system for the
prompt and accurate clearance and settlement of securities
transactions. The Commission finds that by enabling more Structured
Securities to be DTC-eligible and by helping to make the reporting of
information about Structured Securities more accurate and timely, the
proposed rule change, which should make the communication of payment
rate information on Structured Securities quicker and more efficient,
is consistent with this statutory obligation.
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\11\ 15 U.S.C. 78q-1(b)(3)(F).
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IV. Conclusion
On the basis of the foregoing, the Commission finds that the
proposal is consistent with the requirements of the Act and in
particular with the requirements of section 17A of the Act \12\ and the
rules and regulations thereunder.
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\12\ 15 U.S.C. 78q-1.
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It is therefore ordered, pursuant to section 19(b)(2) of the
Act,\13\ that the proposed rule change (File No. SR-DTC-2007-11), as
modified by Amendment No. 1, be, and hereby is, approved.\14\
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\13\ 15 U.S.C. 78s(b)(2).
\14\ In approving the proposed rule change, the Commission
considered the proposal's impact on efficiency, competition, and
capital formation. 15 U.S.C. 78c(f).
For the Commission by the Division of Trading and Markets,
pursuant to delegated authority.\15\
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\15\ 17 CFR 200.30-3(a)(12).
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Florence E. Harmon,
Deputy Secretary.
[FR Doc. E8-6256 Filed 3-26-08; 8:45 am]
BILLING CODE 8011-01-P