Temporary Exemptions for Eligible Credit Default Swaps To Facilitate Operation of Central Counterparties To Clear and Settle Credit Default Swaps, 3967-3975 [E9-1123]
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BILLING CODE 4910–13–P
SECURITIES AND EXCHANGE
COMMISSION
17 CFR PARTS 230, 240 and 260
[Release Nos. 33–8999; 34–59246; 39–2549;
File No. S7–02–09]
RIN 3235–AK26
Temporary Exemptions for Eligible
Credit Default Swaps To Facilitate
Operation of Central Counterparties To
Clear and Settle Credit Default Swaps
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AGENCY: Securities and Exchange
Commission.
ACTION: Interim final temporary rules;
request for comments.
SUMMARY: We are adopting interim final
temporary rules providing exemptions
under the Securities Act of 1933, the
Securities Exchange Act of 1934, and
the Trust Indenture Act of 1939 for
certain credit default swaps to facilitate
the operation of one or more central
counterparties for those credit default
swaps. The interim final temporary
rules define such credit default swaps as
‘‘eligible credit default swaps’’ and
exempt them from all provisions of the
Securities Act, other than the Section
17(a) anti-fraud provisions, as well as
from Exchange Act registration
requirements and from the provisions of
the Trust Indenture Act, provided
certain conditions are met. Our interim
final temporary rules also define as a
‘‘qualified purchaser,’’ for purposes of
the ‘‘covered securities’’ provisions of
Section 18 of the Securities Act, any
‘‘eligible contract participant,’’ as
defined in Section 1a(12) of the
Commodity Exchange Act (‘‘CEA’’),
other than a person who is an eligible
contract participant under Section
1a(12)(C) of the CEA, to whom a sale of
a eligible credit default swap is made in
reliance on the interim final temporary
Securities Act exemption.
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14:54 Jan 21, 2009
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DATES: Effective Date: The interim final
temporary rules are effective January 22,
2009 until September 25, 2009.
Comment Date: Comments on the
interim final temporary rules should be
received on or before March 23, 2009.
ADDRESSES: Comments may be
submitted by any of the following
methods:
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/interim-final-temp.shtml);
• Send an e-mail to rulecomments@sec.gov. Please include File
Number S7–02–09 on the subject line;
or
• Use the Federal Rulemaking Portal
(https://www.regulations.gov). Follow the
instructions for submitting comments.
Paper Comments
• Send paper comments in triplicate
to Elizabeth M. Murphy, Secretary,
Securities and Exchange Commission,
100 F Street, NE., Washington, DC
20549–1090.
All submissions should refer to File
Number S7–02–09. This file number
should be included on the subject line
if e-mail is used. To help us 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/interim-finaltemp.shtml). Comments are also
available for public inspection and
copying in the Commission’s Public
Reference Room, 100 F Street, NE.,
Washington, DC 20549, on official
business days between the hours of 10
a.m. and 3 p.m. All comments received
will be posted without change; we do
not edit personal identifying
information from submissions. You
should submit only information that
you wish to make available publicly.
FOR FURTHER INFORMATION CONTACT:
Amy M. Starr, Senior Special Counsel,
or Kim McManus, Special Counsel,
Office of Chief Counsel, Division of
Corporation Finance, at (202) 551–3500,
U.S. Securities and Exchange
Commission, 100 F Street, NE.,
Washington, DC 20549–3628.
SUPPLEMENTARY INFORMATION: We are
adopting interim final temporary Rule
239T and a temporary amendment to
Rule 146 under the Securities Act of
1933 (‘‘Securities Act’’).1 We are also
adopting interim final temporary Rule
12a–10T and Rule 12h–1(h)T under the
Securities Exchange Act of 1934
(‘‘Exchange Act’’) 2 and interim final
1 15
2 15
PO 00000
U.S.C. 77a et seq.
U.S.C. 78a et seq.
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3967
temporary Rule 4d–11T under the Trust
Indenture Act of 1939 (‘‘Trust Indenture
Act’’).3
I. Background
In response to the recent turmoil in
the financial markets, we have taken
multiple actions to protect investors and
ensure the integrity of the nation’s
securities markets.4 Today we are taking
further action designed to address
concerns related to the market in credit
default swaps (‘‘CDS’’). The over-thecounter (‘‘OTC’’) market for CDS has
been a source of concerns to us and
other financial regulators. These
concerns include the systemic risk
posed by CDS, highlighted by the
possible inability of parties to meet their
obligations as counterparties and the
potential resulting adverse effects on
other markets and the financial system.5
Recent credit market events have
demonstrated the seriousness of these
risks in a CDS market operating without
meaningful regulation, transparency,6 or
3 15
U.S.C. 77aaa et seq.
nonexclusive list of the Commission’s actions
to stabilize financial markets during this credit
crisis include: adopting a package of measures to
strengthen investor protections against naked short
selling, including rules requiring a hard T+3 closeout, eliminating the options market maker
exception of Regulation SHO, and expressly
targeting fraud in short selling transactions (See
Securities Exchange Act Release No. 58572
(September 17, 2008), 73 FR 54875 (September 23,
2008)); issuing an emergency order to enhance
protections against naked short selling in the
securities of primary dealers, Federal National
Mortgage Association (‘‘Fannie Mae’’), and Federal
Home Loan Mortgage Corporation (‘‘Freddie Mac’’)
(See Securities Exchange Act Release No. 58166
(July 15, 2008), 73 FR 42379 (July 21, 2008)); taking
temporary emergency action to ban short selling in
financial securities (See Securities Exchange Act
Release No. 58592 (September 18, 2008), 73 FR
55169 (September 24, 2008)); approving emergency
rulemaking to ensure disclosure of short positions
by hedge funds and other institutional money
managers (See Securities Exchange Act Release No.
58591A (September 21, 2008), 73 FR 55557
(September 25, 2008)); proposing rules to
strengthen the regulation of credit rating agencies
and making the limits and purposes of credit ratings
clearer to investors (See Securities Exchange Act
Release No. 57967 (June 16, 2008), 73 FR 36212
(June 25, 2008); entering into a Memorandum of
Understanding with the Board of Governors of the
Federal Reserve System (‘‘FRB’’) to make sure key
federal financial regulators share information and
coordinate regulatory activities in important areas
of common interest (See Memorandum of
Understanding Between the U.S. Securities and
Exchange Commission and the Board of Governors
of the Federal Reserve System Regarding
Coordination and Information Sharing in Areas of
Common Regulatory and Supervisory Interest (July
7, 2008), https://www.sec.gov/news/press/2008/
2008-134_mou.pdf).
5 In addition to the potential systemic risks that
CDS pose to financial stability, we are concerned
about other potential risks in this market, including
operational risks, risks relating to manipulation and
fraud, and regulatory arbitrage risks.
6 See Policy Objectives for the OTC Derivatives
Market, The President’s Working Group on
4A
Continued
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central counterparties (‘‘CCPs’’).7 These
events have emphasized the need for
CCPs as mechanisms to help control
such risks.8 A CCP for CDS could be an
important step in reducing the
counterparty risks inherent in the CDS
market, and thereby help mitigate
potential systemic impacts. In
November 2008, the President’s
Working Group on Financial Markets
stated that the implementation of a CCP
for CDS was a top priority 9 and, in
furtherance of this recommendation, the
Commission, the FRB and the
Commodity Futures Trading
Commission (‘‘CFTC’’) signed a
Memorandum of Understanding 10 that
establishes a framework for consultation
and information sharing on issues
related to CCPs for CDS. Given the
continued uncertainty in this market,
taking action to help foster the prompt
development of CCPs, including
granting conditional exemptions from
certain provisions of the federal
securities laws, is in the public interest.
The interim final temporary rules we are
adopting are intended to facilitate the
ability of one or more CCPs for CDS to
operate by providing exemptions from
certain regulatory provisions that might
otherwise prevent them from engaging
in such activities.
A CDS is a bilateral contract between
two parties, known as counterparties.
The value of this financial contract is
based on underlying obligations
(‘‘reference obligations’’) of a single
entity (a ‘‘reference entity’’) or on a
particular security or other debt
obligation (‘‘reference security’’), or an
Financial Markets (November 14, 2008), https://
www.ustreas.gov/press/releases/reports/
policyobjectives.pdf (‘‘Public reporting of prices,
trading volumes and aggregate open interest should
be required to increase market transparency for
participants and the public.’’).
7 See The Role of Credit Derivatives in the U.S.
Economy Before the H. Agric. Comm., 110th Cong.
(2008) (Statement of Erik Sirri, Director of the
Division of Trading and Markets, Commission).
8 See id.
9 See Policy Objectives for the OTC Derivatives
Market, The President’s Working Group on
Financial Markets (November 14, 2008), https://
www.ustreas.gov/press/releases/reports/
policyobjectives.pdf. See also Policy Statement on
Financial Market Developments, The President’s
Working Group on Financial Markets (March 13,
2008), https://www.treas.gov/press/releases/reports/
pwgpolicystatemktturmoil_03122008.pdf; Progress
Update on March Policy Statement on Financial
Market Developments, The President’s Working
Group on Financial Markets (October 2008),
https://www.treas.gov/press/releases/reports/
q4progress%20update.pdf.1
10 See Memorandum of Understanding Between
the Board of Governors of the Federal Reserve
System, the U.S. Commodity Futures Trading
Commission and the U.S. Securities and Exchange
Commission Regarding Central Counterparties for
Credit Default Swaps (November 14, 2008), https://
www.treas.gov/press/releases/reports/finalmou.pdf
(‘‘MOU’’).
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index of several such entities, securities,
or obligations. The obligation of a seller
to make payments under a CDS contract
is triggered by a default or other credit
event as to such entity or entities or
such security or securities. Investors
may use CDS for a variety of reasons,
including to offset or insure against risk
in their fixed-income portfolios, to take
synthetic positions in bonds or in
segments of the debt market as
represented by an index, or to capitalize
on the volatility in credit spreads during
times of economic uncertainty. In recent
years, CDS market volumes have rapidly
increased.11 This growth has coincided
with a significant rise in the types and
number of entities participating in the
CDS market.12
The operation of a well-regulated CCP
can significantly reduce counterparty
risks by preventing the failure of a
single market participant from having a
disproportionate effect on the overall
market. A CCP would novate bilateral
trades, which would result in the CCP
entering into separate contractual
arrangements with both
counterparties—becoming buyer to one
and seller to the other.13 Today, CDS
agreements generally are negotiated and
entered into bilaterally, but both parties
may agree that one party may novate the
agreement and substitute another party
to take responsibility for performance,
by acting as the counterparty, under the
agreement. In a CCP arrangement, both
parties entering a CDS would novate
their trades to the CCP, and the CCP
would stand in as the counterparty to all
parties of the CDS it clears. Through this
novation process, the counterparty risk
of a CDS would be effectively
concentrated in the CCP.
In companion actions to these interim
final temporary rules, we are
temporarily exempting, subject to
conditions, a clearing agency acting as
a CCP from the requirement to register
as a clearing agency under Section 17A
of the Exchange Act 14 solely to perform
11 See Semiannual OTC derivatives statistics at
end-December 2007, Bank for International
Settlements (‘‘BIS’’), available at https://
www.bis.org/statistics/otcder/dt1920a.pdf.
12 CDS were initially created to meet the demand
of banking institutions looking to hedge and
diversify the credit risk attendant with their lending
activities. However, financial institutions such as
insurance companies, pension funds, securities
firms and hedge funds have entered the CDS
market.
13 ‘‘Novation’’ is a ‘‘process through which the
original obligation between a buyer and seller is
discharged through the substitution of the CCP as
seller to buyer and buyer to seller, creating two new
contracts.’’ Committee on Payment and Settlement
Systems, Technical Committee of the International
Organization of Securities Commissioners,
Recommendations for Central Counterparties
(November 2004) at 66.
14 15 U.S.C. 78q–1.
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the functions of a clearing agency for
certain CDS transactions, and also
certain eligible contract participants 15
and others from certain Exchange Act
requirements with respect to certain
CDS.16 We also are temporarily
exempting any exchange that effects
transactions in certain CDS from the
requirements under Sections 5 and 6 of
the Exchange Act 17 to register as a
national securities exchange, and any
broker or dealer that effects transactions
on an exchange in certain CDS from the
requirements of Section 5 of the
Exchange Act.
In connection with these actions to
facilitate the operation of these CCPs for
the CDS market, we believe that it is
appropriate and necessary to provide
temporary exemptions from certain
provisions of the Securities Act, the
Exchange Act and the Trust Indenture
Act, subject to certain conditions
described in the companion exemptive
orders and in the exemptions
themselves. We believe that these
interim final temporary rules, and the
exemptive orders we are providing
under the Exchange Act, will facilitate
the operation of one or more CCPs that
will clear and settle CDS transactions
while enabling us to provide oversight
to the CDS market.
We believe that the operation of one
or more CCPs in accordance with our
exemptions likely would improve the
efficiency and effectiveness of the CDS
market, provide for increased
transparency of exposures to particular
reference entities or reference securities,
and increase available information
about reference entities or reference
securities. The conditions in the
companion exemptive orders will
enable us to oversee the development of
CDS CCPs and exchanges as they
evolve, and to take such additional
action as we may deem necessary to
promote the public interest and the
protection of investors. Moreover, the
limited duration of the exemptions and
the interim final temporary rules
provided today will enable one or more
CCPs and CDS exchanges to become
operational while we gain useful
experience with the CDS market and
evaluate the public input, including
comments, we receive on the temporary
rules and exemptions.
II. Discussion of the Interim Final
Temporary Rules and Amendments
We are adopting interim final
temporary rules and amendments to
15 See
7 U.S.C. 1a(12).
Securities Exchange Act Release Nos.
59164 and 59165 (December 24, 2008).
17 15 U.S.C. 78e and 78f.
16 See
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existing rules (collectively, ‘‘interim
final temporary rules’’) to provide
certain conditional exemptions under
the Securities Act, the Exchange Act
and the Trust Indenture Act.
A. Scope of the Interim Final Temporary
Rules
Our authority over the OTC market for
CDS is limited. Specifically, Section 2A
of the Securities Act and Section 3A of
the Exchange Act limit our authority
over ‘‘swap agreements’’ as defined in
Section 206A of the Gramm-LeachBliley Act.18 For those CDS that are
swap agreements, the exclusion from
the definition of security in Section 2A
of the Securities Act and Section 3A of
the Exchange Act and related provisions
will continue to apply. Our action today
does not affect these CDS, and these
interim final temporary rules do not
apply to them. For those CDS that are
not swap agreements (‘‘non-excluded
CDS’’), our action today provides certain
conditional exemptions from the
provisions of the Securities Act, the
Exchange Act, and the Trust Indenture
Act and is designed to encourage the
development and operation of one or
more CDS CCPs and CDS exchanges.19
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B. Securities Act Rule 239T
We are adopting interim final
temporary Securities Act Rule 239T to
exempt certain CDS (‘‘eligible CDS’’) 20
18 15 U.S.C. 77b(b)–1 and 15 U.S.C. 78c–1.
Section 2A of the Securities Act and Section 3A of
the Exchange Act excludes both a non-securitybased and a security-based ‘‘swap agreement’’ from
the definition of ‘‘security’’ under Section 2(a)(1) of
the Securities Act, 15 U.S.C. 77b(a)(1) and Section
3(a)(10) of the Exchange Act, 15 U.S.C. 78c(a)(10).
Section 206A of the Gramm-Leach-Bliley Act
defines a ‘‘swap agreement’’ as ‘‘any agreement,
contract, or transaction between eligible contract
participants (as defined in section 1a(12) of the
Commodity Exchange Act * * *) * * * the
material terms of which (other than price and
quantity) are subject to individual negotiation.
* * *’’ 15 U.S.C. 78c note.
19 Section 28 of the Securities Act authorizes us
to exempt any person, security or transaction from
any provision of the Securities Act by rule or
regulation to the extent that the exemption is
necessary or appropriate in the public interest and
consistent with the protection of investors. 15
U.S.C. 77z–3. Similarly, Section 36 of the Exchange
Act gives us the authority to exempt any person,
security or transaction from any Exchange Act
provision by rule, regulation or order, to the extent
that the exemption is necessary or appropriate in
the public interest and consistent with the
protection of investors. 15 U.S.C. 78mm. Finally,
Section 304(d) of the Trust Indenture Act authorizes
us to exempt conditionally or unconditionally any
person, security or transaction from any Trust
Indenture Act provision by rules or regulation to
the extent that the exemption is necessary or
appropriate in the public interest and consistent
with the protection of investors and the purposes
fairly intended by the Trust Indenture Act. 15
U.S.C. 77ddd(d).
20 As we discuss below, we have included a
definition of ‘‘eligible credit default swap’’ in
interim final temporary Securities Act Rule 239T.
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that are being or will be issued or
cleared by a CCP satisfying the
conditions set forth in the companion
exemptions, or registered as a clearing
agency under Section 17A of the
Exchange Act (‘‘Registered or Exempt
CCP’’), to eligible contract participants
from all provisions of the Securities Act,
except the anti-fraud provisions of
Section 17(a) of the Securities Act.21
Securities Act Rule 239T will permit the
offer and sale of such eligible CDS that
are or will be issued or cleared by a
Registered or Exempt CCP without
requiring compliance with Section 5 of
the Securities Act, and communications
used in connection with such offers and
sales will not be subject to Section
12(a)(2) liability under the Securities
Act.
Absent this exemption, the Securities
Act may require registration of the offer
and sale of eligible CDS that are or will
be issued or cleared by a Registered or
Exempt CCP. We believe that the
interim final temporary rules exempting
offers and sales of such eligible CDS by
a Registered or Exempt CCP will
facilitate the use by eligible contract
participants of CCPs for eligible CDS.
Indeed, without also exempting the
offers and sales of the eligible CDS by
a Registered or Exempt CCP from the
registration requirements of the
Securities Act and the Exchange Act
and the provisions of the Trust
Indenture Act, we believe that the CCPs
would not be able to operate in the
manner contemplated by the Exchange
Act exemptive orders. In addition, the
Securities Act, Exchange Act and Trust
Indenture Act exemptions should
encourage market participants to clear
their CDS through the CCPs.
Under Securities Act Rule 239T, an
eligible CDS would be exempt from the
registration requirements of the
Securities Act if it is or will be issued
or cleared by a Registered or Exempt
CCP, and if the eligible CDS is offered
and sold only to an ‘‘eligible contract
participant’’ (as defined in Section
1a(12) of the CEA as in effect on the date
of adoption of this rule, other than a
person who is an eligible contract
participant under Section 1a(12)(C) of
the CEA).22 We have included a
definition of eligible CDS solely for
purposes of the interim final temporary
21 15 U.S.C. § 77q. This exemption is consistent
with the Securities Act exemptions for standardized
options and security futures products. See Section
3(a)(14) [15 U.S.C. § 77c(a)(14)] and Securities Act
Rule 238 [17 CFR 230.238].
22 See 7 U.S.C. 1(a)(12). The exemption would be
limited to those persons defined as eligible contract
participants in the statute and would not extend to
those persons that are included in the definition
through regulatory action by the CFTC. See 7 U.S.C.
1(a)(12)(C).
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rules. Under this definition, an eligible
CDS is a bilateral executory derivative
contract not subject to individual
negotiation (1) in which a buyer makes
payments to the seller and, in return,
receives a payout if there is a default or
other credit event involving the
reference obligation(s) or reference
entity(ies) within a certain time, and (2)
the agreement for which includes the:
• Specification of the reference
obligation or obligor; or, in the case of
a reference group or index thereof, all of
the reference obligations or obligors
comprising any such group or index);
• Term of the agreement;
• Notional amount upon which
payment obligations are calculated;
• Credit-related events that trigger a
settlement obligation; and
• Obligations to be delivered if there
is a credit-related event or, if it is a cash
settlement, the obligations whose value
is to be used to determine the amount
of settlement obligation under the
eligible credit default swap.
Securities Act Rule 239T will permit
the offer and sale of eligible CDS that
are or will be issued or cleared by a
Registered or Exempt CCP without
requiring compliance with Section 5 of
the Securities Act, while assuring the
availability of information to buyers and
sellers of CDS, due to certain
information conditions in the
companion exemptive orders,23 and
preserving anti-fraud liability under
Section 17(a) of the Securities Act,
which currently applies to securitybased swap agreements. Securities Act
Rule 239T also provides an exemption
from the liability provisions of
Securities Act Section 12. Thus, oral or
written communications used in
connection with the offer and sale of
eligible CDS that are or will be issued
or cleared by a Registered or Exempt
CCP in reliance on the rule will not be
23 We note that among the conditions of the
exemptions, or representations in the exemptive
requests on which we are relying, from clearing
registration are that: (1) Information is available
about the terms of the CDS, the creditworthiness of
the CCP or any guarantor, and the clearing and
settlement process for the CDS; and (2) the
reference entity, the issuer of the reference security,
or the reference security is one of the following: an
entity reporting under the Exchange Act, providing
Securities Act Rule 144A(d)(4) information, or
about which financial information is otherwise
publicly available; a foreign private issuer that has
securities listed outside the United States and has
its principal trading market outside the United
States; a foreign sovereign debt security; an assetbacked security, as defined in Regulation AB [17
CFR 229.1100], issued in a registered transaction
with publicly available distribution reports; an
asset-backed security issued or guaranteed by
Fannie Mae, Freddie Mac or the Government
National Mortgage Association (‘‘Ginnie Mae’’); or
indexes in which 80 percent or more of the index’s
weight is comprised of these reference entities or
reference securities.
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subject to liability under Securities Act
Section 12(a)(2).
The Securities Act exemption in the
interim final temporary rule is limited
to offers and sales to eligible contract
participants (as defined in Section
1a(12) of the CEA as in effect on the date
of adoption of the rule, other than a
person that is an eligible contract
participant under Section 1a(12)(C) of
the CEA). Under Securities Act Section
2A, a security-based swap agreement
that is entered into between eligible
contract participants is not permitted to
be registered under the Securities Act,
but the provisions of Securities Act
Section 17(a) continue to apply to such
transactions. The operation of one or
more CCPs pursuant to the actions we
are taking today will allow such
security-based swap agreements to
continue to be entered into between
eligible contract participants and then
be novated to the CCP. The Securities
Act exemption is intended to limit
investor involvement in eligible CDS
that are issued or cleared by a
Registered or Exempt CCP to eligible
contract participants, who are those
persons Congress determined were
qualified to engage in activities in the
generally unregulated (other than with
respect to the antifraud provisions of the
Securities Act and the Exchange Act) 24
OTC CDS market.
The Securities Act interim final
temporary rule also provides that any
offer or sale of an eligible CDS that is
or will be issued or cleared by a
Registered or Exempt CCP by or on
behalf of the issuer of a security, an
affiliate of such issuer, or an
underwriter, if such security is
delivered in settlement or whose value
is used to determine the amount of the
settlement obligation, will constitute a
‘‘contract for sale of,’’ ‘‘sale of,’’ ‘‘offer
for sale,’’ or ‘‘offer to sell’’ such security
under Section 2(a)(3) of the Securities
Act. This provision is intended to
ensure that an eligible CDS that is or
will be issued or cleared by a Registered
or Exempt CCP cannot be used by an
issuer, affiliate of an issuer or
underwriter to circumvent the
24 See Title III of the Commodity Futures
Modernization Act of 2000 (Pub. L. 106–554) and
the definition of eligible contract participant in
Title I of the Commodity Futures Modernization
Act of 2000 [7 U.S.C. 1a(12)]. The term ‘‘eligible
contract participant’’ generally includes various
regulated financial institutions, business enterprises
that meet certain tests relating to total assets or net
worth, certain pension funds, state and local
governments, and certain wealthy individuals.
In addition, the provisions of Section 16 of the
Exchange Act apply to security-based swap
agreements. See 15 U.S.C. 78p(g). The exemptions
are available only with regard to non-excluded CDS
satisfying the exemption’s conditions and not other
types of derivative contracts.
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registration requirements of Section 5
with respect to an issuer’s security for
such eligible CDS.25 As a result, a
transaction by such persons in an
eligible CDS that is or will be issued or
cleared by a Registered or Exempt CCP
having such securities of the issuer also
is a transaction in the issuer’s securities
that must be registered under the
Securities Act, unless an exemption
from registration is available.
Further, we are adopting on an
interim final temporary basis an
amendment to Securities Act Rule 146.
Under the temporary amendment to
Securities Act Rule 146, eligible
contract participants that are sold
eligible CDS in reliance on interim final
temporary Securities Act Rule 239T will
be defined as ‘‘qualified purchasers’’
under Section 18(b)(3) of the Securities
Act and thereby such eligible CDS that
are or will be issued or cleared by a
Registered or Exempt CCP will be
considered ‘‘covered securities’’ under
Section 18 of the Securities Act and
exempt from state blue sky laws.26 We
are adopting this amendment because
we believe that eligible contract
participants are the kinds of
sophisticated investors who do not
require the protections of registration
under state securities laws. In this
regard, as we discuss above, Congress
determined that eligible contract
participants were the types of persons
that were able to engage in activities in
the OTC CDS market unregulated by the
Commission and preempted the
application of certain state laws to
transactions in OTC security-based
swap agreements, including CDS.27 We
believe that defining such eligible
contract participants as ‘‘qualified
purchasers’’ for purposes of engaging in
transactions in eligible CDS in reliance
on temporary Securities Act Rule 239T
would be consistent with such
Congressional intent.
C. Exchange Act Rule 12a–10T and Rule
12h–1(h)T
We also are adopting two interim final
temporary rules relating to Exchange
Act registration of eligible CDS that are
or have been issued or cleared by a
Registered or Exempt CCP. We are
adopting interim final temporary
Exchange Act Rule 12a–10T to exempt
25 This provision is similar to the condition in the
Securities Act exemption in Rule 238 for
standardized options [17 CFR 230.238] and in
Securities Act Section 2(a)(3) [15 U.S.C. 77b(a)(3)]
relating to security futures products.
26 State securities regulation of covered securities
generally is limited under Section 18(b). Under
Section 18(b)(3), covered securities are securities
offered and sold to qualified purchasers, as defined
by the Commission.
27 See 7 U.S.C. 16(e)(2).
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eligible CDS that are or have been
issued or cleared by a Registered or
Exempt CCP from the provisions of
Section 12(a) of the Exchange Act under
certain conditions.28 We also are
adopting an interim final temporary
amendment to Exchange Act Rule 12h–
1 to exempt eligible CDS that are or
have been issued or cleared by a
Registered or Exempt CCP from the
provisions of Section 12(g) of the
Exchange Act under certain
conditions.29 This exemption is the
same as that available to standardized
options issued by a registered options
clearing agency and security futures
products issued by a registered clearing
agency, and this temporary rule should
facilitate the operation of the CCPs.
D. Trust Indenture Act Rule 4d–11T
We are adopting a new interim final
temporary rule under Section 304(d) of
the Trust Indenture Act that would
exempt any eligible CDS, as defined in
Securities Act Rule 239T and offered
and sold in reliance on Securities Act
Rule 239T, from having to comply with
the provisions of the Trust Indenture
Act.30 We believe an exemption from
the Trust Indenture Act is appropriate
in this situation.
The Trust Indenture Act is aimed at
addressing problems that unregulated
debt offerings posed for investors and
the public,31 and provides a mechanism
for debtholders to protect and enforce
their rights with respect to the debt. We
do not believe that the protections
contained in the Trust Indenture Act are
needed at this time to protect eligible
contract participants to whom a sale of
an eligible CDS is made in reliance on
interim final temporary Securities Act
Rule 239T. The identified problems that
the Trust Indenture Act is intended to
address do not occur in the offer and
sale of eligible CDS.32 For example,
eligible CDS are contracts between two
parties and, as a result, do not raise the
same problem regarding the ability of
parties to enforce their rights under the
instruments as would, for example, a
28 15
U.S.C. 78l(a).
U.S.C. 78l(g).
30 The Trust Indenture Act applies to debt
securities sold through the use of the mails or
interstate commerce. Section 304 of the Trust
Indenture Act exempts from the Act a number of
securities and transactions. Section 304(a) of the
Trust Indenture Act exempts securities that are
exempt under Securities Act Section 3(a) but does
not exempt from the Trust Indenture Act securities
that are exempt by Commission rule. Accordingly,
while Securities Act Rule 239T would exempt the
offer and sale of eligible CDS satisfying certain
conditions from all the provisions of the Securities
Act (other than Section 17(a)), the Trust Indenture
Act would continue to apply.
31 See 15 U.S.C.77bbb(a).
32 15 U.S.C. 77bbb(a).
29 15
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debt offering to the public. Moreover,
through novation, the CCP becomes the
counterparty to the buyer and the seller,
and each would look directly to the CCP
to satisfy the obligations under the
eligible CDS. As a consequence,
enforcement of contractual rights and
obligations under the eligible CDS
would occur directly between such
parties, and the Trust Indenture Act
provisions would not provide any
additional meaningful substantive or
procedural protections.
Accordingly, due to the nature of
eligible CDS as bilateral contracts that
will have been issued or cleared by
Registered or Exempt CCPs, we do not
believe the protections contained in the
Trust Indenture Act are currently
needed with respect to these
instruments. Therefore, we believe the
exemption is necessary or appropriate
in the public interest, consistent with
the protection of investors and the
purposes fairly intended by the Trust
Indenture Act.
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E. Request for Comment
We request and encourage any
interested person to submit comments
regarding the interim final temporary
rules. In particular, we solicit comment
on the following questions:
• We are interested in understanding
what type of non-excluded CDS would
not be eligible for these exemptions. Are
there credit swaps that would not be
encompassed within the scope of the
exemptions and that should be covered?
• What are the amounts and types of
CDS that may not satisfy the conditions
for the exemptions?
• Is the definition of eligible CDS
appropriate and does it include the
types of CDS that should be within the
exemptions or should there be another
definition? Does the definition of
eligible CDS include all the appropriate
or relevant material terms of a CDS?
Should we require more specificity as to
the terms, including final settlement
valuations?
• Each of the temporary exemptions
contains particular conditions. Should
the Securities Act exemption in
temporary Securities Act Rule 239T be
conditioned on the eligible CDS being
issued or cleared by a Registered or
Exempt CCP? If not, why not?
• Should there be information
conditions in the Securities Act
exemptions themselves regarding the
reference entities or reference securities
similar to the information requirements
in the CCP exemptive orders? If so, what
type of information conditions should
be included and why? Is additional or
different information from that
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contained in the CCP exemption orders
appropriate?
• Are the Securities Act, Exchange
Act and Trust Indenture Act exemptions
appropriate? If not, why not? Given the
voluntary nature of using a CCP, should
we take a different approach?
• The Securities Act exemption also
provides that eligible CDS that are or
will be issued or cleared by a Registered
or Exempt CCP and are entered into
with an issuer of a security, or an
underwriter or affiliate of such issuer, if
such security is delivered in settlement
or whose value is used to determine the
amount of the settlement obligation,
will be considered an offer and sale of
such security at that time. Are there
circumstances in which the application
of the Securities Act to such security of
the issuer should not apply at the time
of the offer and sale of eligible CDS that
are or will be issued or cleared by a
Registered or Exempt CCP? Are there
securities or obligations used in CDS
transactions that are not debt
obligations? If yes, please explain.
• The Securities Act exemption is
limited to offers and sales to eligible
contract participants. Should the
exemption be limited in this manner? If
not, why not? Are there persons who
invest in CDS now in the OTC market
that would not be able to take advantage
of the exemptions? If yes, please explain
the categories of persons and why the
exemptions should include such
persons.
• The definition of ‘‘qualified
purchaser’’ for purposes of the interim
final temporary amendment to
Securities Act Rule 146 applies only to
eligible contract participants that have
been sold eligible CDS in reliance on the
new interim final temporary exemption
in Securities Act Rule 239T. Is this an
appropriate definition and should
eligible contract participants that are
sold eligible CDS pursuant to Securities
Act Rule 239T be considered ‘‘qualified
purchasers’’ for purposes of Section 18
of the Securities Act?
• Should the Securities Act
exemption be limited to an exemption
from Section 5 and Section 12 of the
Securities Act? Please explain your
reasoning in detail.
• Should we exempt eligible CDS that
have been issued or cleared by a
Registered or Exempt CCP from the
registration requirements of the
Exchange Act? If not, why?
• The conditions of the temporary
Exchange Act and Trust Indenture Act
exemptions are the same as the
conditions to the temporary Securities
Act exemption. Is this appropriate or
should there be different conditions
relating to the Exchange Act and Trust
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3971
Indenture Act exemptions? If yes, please
explain.
• The interim final temporary rules
include an exemption from the
application of the Trust Indenture Act
for eligible CDS that are offered and sold
in reliance on interim final Securities
Act Rule 239T. Is this exemption
appropriate or are there contractual
protections in the Trust Indenture Act
that should be included as mandatory
provisions of an eligible CDS contract
that is or will be issued or cleared by a
Registered or Exempt CCP? If yes, please
explain in detail.
III. Transition and Expiration Date of
Interim Final Temporary Rules
We are adopting the interim final
rules on a temporary basis until
September 25, 2009. We anticipate that
this term of this exemption will provide
us with adequate time to evaluate the
availability of the exemptions
applicable to CDS CCPs and nonexcluded CDS, and whether any
conditions or provisions of such
exemptions should be modified.
Adoption of the interim final
temporary rules, which will be effective
on [effective date] and will continue in
effect until September 25, 2009, will
facilitate the development of one or
more CCPs as well as our review of the
CDS market. We have included several
requests for comment in this release. We
will consider the public comments we
receive in determining whether we
should revise the interim final
temporary rules in any respect, as well
as whether we should consider
extending the exemptions. The rules
will expire and cease to be effective on
September 25, 2009 unless we act to
extend the effective date or revise the
interim final temporary rules.
IV. Other Matters
The Administrative Procedure Act
generally requires an agency to publish
notice of a proposed rulemaking in the
Federal Register.33 This requirement
does not apply, however, if the agency
‘‘for good cause finds * * * that notice
and public procedure are impracticable,
unnecessary, or contrary to the public
interest.’’ 34 Further, the Administrative
Procedure Act also generally requires
that an agency publish an adopted rule
in the Federal Register 30 days before
it becomes effective.35 This requirement
does not apply, however, if the agency
finds good cause for making the rule
effective sooner.36 We, for good cause,
33 See
5 U.S.C. 553(b).
34 Id.
35 See
5 U.S.C. 553(d).
36 Id.
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find that notice and solicitation of
comment before adopting the new rules
is impracticable, unnecessary, or
contrary to the public interest.
For the reasons we discussed
throughout this release, we believe that
we have good cause to act immediately
to adopt these rules on an interim final
temporary basis. The OTC market for
CDS has been a source of concerns to us
and other financial regulators. These
concerns include the systemic risk
posed by CDS, highlighted by the
possible inability of parties to meet their
obligations as counterparties and the
potential resulting adverse effects on
other markets and the financial
system.37 Recent credit market events
have demonstrated the seriousness of
these risks in a CDS market operating
without meaningful regulation,
transparency,38 or CCPs.39 These events
have emphasized the need for CCPs as
mechanisms to help control such
risks.40 A CCP for CDS could be an
important step in reducing the
counterparty risks inherent in the CDS
market, and thereby help mitigate
potential systemic impacts. In
November 2008, the President’s
Working Group on Financial Markets
stated that the implementation of a CCP
for CDS was a top priority 41 and, in
furtherance of this recommendation, the
Commission, the FRB and the CFTC
signed a Memorandum of
Understanding 42 that establishes a
framework for consultation and
information sharing on issues related to
CCPs for CDS. Given the continued
uncertainty in this market, taking action
37 In addition to the potential systemic risks that
CDS pose to financial stability, we are concerned
about other potential risks in this market, including
operational risks, risks relating to manipulation and
fraud, and regulatory arbitrage risks.
38 See Policy Objectives for the OTC Derivatives
Market, The President’s Working Group on
Financial Markets (November 14, 2008), https://
www.ustreas.gov/press/releases/reports/policy
objectives.pdf (‘‘Public reporting of prices, trading
volumes and aggregate open interest should be
required to increase market transparency for
participants and the public.’’)
39 See The Role of Credit Derivatives in the U.S.
Economy Before the H. Agric. Comm., 110th Cong.
(2008) (Statement of Erik Sirri, Director of the
Division of Trading and Markets, Commission).
40 See id.
41 See Policy Objectives for the OTC Derivatives
Market, The President’s Working Group on
Financial Markets (November 14, 2008), https://
www.ustreas.gov/press/releases/reports/policy
objectives.pdf. See also Policy Statement on
Financial Market Developments, The President’s
Working Group on Financial Markets (March 13,
2008), https://www.treas.gov/press/releases/reports/
pwgpolicystatemktturmoil_03122008.pdf; Progress
Update on March Policy Statement on Financial
Market Developments, The President’s Working
Group on Financial Markets (October 2008),
https://www.treas.gov/press/releases/reports/
q4progress%20update.pdf.
42 See MOU, supra note 10.
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to help foster the prompt development
of CCPs, including granting conditional
exemptions from certain provisions of
the federal securities laws, thus is in the
public interest. The interim final
temporary rules we are adopting are
intended to facilitate the ability of one
or more CCPs for CDS to operate by
providing exemptions from certain
regulatory provisions that might
otherwise prevent them from engaging
in such activities. Absent an exemption,
the offer and sale of eligible CDS that
are or will be issued or cleared by a
Registered or Exempt CCP may have to
be registered under the Securities Act,
the eligible CDS that have been so
issued or cleared may have to be
registered as a class under the Exchange
Act and the provisions of the Trust
Indenture Act may need to be complied
with. We believe that the interim final
temporary rules exempting the
registration of eligible CDS that are or
will be issued or cleared by a Registered
or Exempt CCP under certain conditions
will facilitate the use by eligible
contract participants of CDS CCPs.
Without also exempting the offers and
sales of the eligible CDS from the
registration requirements of the
Securities Act and the Exchange Act
and the provisions of the Trust
Indenture Act, we believe that the CCPs
would not be able to operate in the
manner contemplated by the exemptive
orders. We emphasize that we are
requesting comments on the interim
final temporary rules and will carefully
consider any comments that we receive
and respond to them in a subsequent
release. Moreover, these interim final
temporary rules will expire on
September 25, 2009. Setting a
termination date for the interim final
temporary rules will necessitate further
Commission action no later than the end
of that period if we determine to
continue the same, or similar,
requirements contained in the interim
final temporary rules. We find that there
is good cause to have the rules effective
as interim final temporary rules on
January 22, 2009 and that notice and
public procedure in advance of
effectiveness of the interim final
temporary rules is impracticable,
unnecessary and contrary to the public
interest.43
43 This finding also satisfies the requirements of
5 U.S.C. 808(2), allowing the rule amendment to
become effective notwithstanding the requirement
of 5 U.S.C. 801 (if a federal agency finds that notice
and public comment are ‘‘impractical, unnecessary
or contrary to the public interest,’’ a rule ‘‘shall take
effect at such time as the federal agency
promulgating the rule determines’’).
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V. Paperwork Reduction Act
The interim final temporary rules do
not impose any new ‘‘collections of
information’’ within the meaning of the
Paperwork Reduction Act of 1995
(‘‘PRA’’),44 nor do they create any new
filing, reporting, recordkeeping, or
disclosure reporting requirements for a
CCP that is or will be issuing or clearing
eligible CDS. Accordingly, we are not
submitting the interim final temporary
rules to the Office of Management and
Budget for review in accordance with
the PRA.45 We request comment on
whether our conclusion that there are
no collections of information is correct.
VI. Cost-Benefit Analysis
We are adopting interim final
temporary rules under the Securities
Act, the Exchange Act and the Trust
Indenture Act that would exempt
eligible CDS that are or will be issued
or cleared by a Registered or Exempt
CCP and offered and sold only to
eligible contract participants from all
provisions of the Securities Act, other
than the Section 17(a) anti-fraud
provision, as well as from the
registration requirements under Section
12 of the Exchange Act and from the
provisions of the Trust Indenture Act.
These interim final temporary rules are
intended to facilitate the operation of
one or more CCPs to act as a clearing
agency in the CDS market to reduce
some of the risks in the CDS market.
A CDS is a bilateral contract between
two parties, known as counterparties.
The value of this financial contract is
based on underlying obligations of a
single entity or on a particular security
or other debt obligation, or an index of
several such entities, securities, or
obligations. The obligation of a seller to
make payment under a CDS contract is
triggered by a default or other credit
event as to such entity or entities or
such security or securities. Investors
may use CDS for a variety of reasons,
including to offset or insure against risk
in their fixed-income portfolios, to take
synthetic positions in bonds or in
segments of the debt market as
represented by an index, or to capitalize
on the volatility in credit spreads during
times of economic uncertainty. In recent
years, CDS market volumes have rapidly
increased.46 This growth has coincided
with a significant rise in the types and
44 44
U.S.C. 3501 et seq.
U.S.C. 3507(d) and 5 CFR 1320.11.
46 See Semiannual OTC derivatives statistics at
end-December 2007, Bank for International
Settlements (‘‘BIS’’), available at https://www.bis.
org/statistics/otcder/dt1920a.pdf.
45 44
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number of entities participating in the
CDS market.47
In a CCP arrangement, both parties
entering a CDS would novate their
trades to the CCP, and the CCP would
stand in as the counterparty to all
parties of the CDS it clears. Through this
novation process, the counterparty risk
of a CDS would be effectively
concentrated in the CCP.
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A. Benefits
We are providing exemptive orders
that will facilitate the operation of CCPs
for the CDS market. In connection with
these actions, we are adopting
exemptions from certain provisions of
the Securities Act, the Exchange Act
and the Trust Indenture Act, subject to
certain conditions described in the
companion exemptive orders and in the
exemptions themselves. The conditions
and representations in the companion
exemptive orders and exemptions
require that information be available
about the terms of the CDS, the
creditworthiness of the CCP or any
guarantor, and the clearing and
settlement process for the CDS.
Additionally, the conditions require that
financial information about the
reference entity, the issuer of the
reference security, or the reference
security be publicly available. We
believe that these interim final
temporary rules and the exemptions we
are providing under the Exchange Act,
will facilitate the operation of CCPs
while enabling us to provide oversight
to the non-excluded CDS market. We
believe that the operation of one or more
CCPs in accordance with our
exemptions likely would improve the
efficiency and effectiveness of the CDS
market, provide clearing participants
with increased transparency of
exposures to particular reference
entities or reference securities, and
increase available information about
reference entities or reference securities.
Absent an exemption, the offer and
sale of eligible CDS that are or will be
issued or cleared by a Registered or
Exempt CCP would have to be registered
under the Securities Act, the eligible
CDS that are or have been issued or
cleared by a Registered or Exempt CCP
would have to be registered as a class
under the Exchange Act, and the
provisions of the Trust Indenture Act
would apply. We believe that the
interim final temporary rules exempting
47 CDSs were initially created to meet the demand
of banking institutions looking to hedge and
diversify the credit risk attendant with their lending
activities. However, financial institutions such as
insurance companies, pension funds, securities
firms and hedge funds have entered the CDS
market.
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the registration of eligible CDS issued or
cleared by a Registered or Exempt CCP
under certain conditions will facilitate
the use by eligible contract participants
of CDS CCPs. Without also exempting
the offers and sales of eligible CDS
issued or cleared by a Registered or
Exempt CCP from the registration
requirements of the Securities Act and
the Exchange Act and the provisions of
the Trust Indenture Act, we believe that
the CCPs would not be able to operate
in the manner contemplated by the
exemptive orders.
The interim final temporary
exemptions also will treat eligible CDS
issued or cleared by a Registered or
Exempt CCP under the Securities Act
and the Exchange Act in the same
manner as certain other types of
derivative contracts, such as security
futures products and standardized
options.48 A Registered or Exempt CCP
issuing or clearing eligible CDS will
benefit from the temporary exemptions
because it will not have to file
registration statements with us covering
the offer and sale of the eligible CDS.
The registration form most applicable to
a CCP is a Form S–20, which is the form
that is used by options clearing houses
that do not qualify for our exemption in
Securities Act Rule 238 49 from
registering the offer and sale of
standardized options. If a CCP is not
required to register the offer and sale of
eligible CDS (on Form S–20, for
example), it would not have to incur the
costs of such registration, including
legal and accounting costs. Some of
these costs, of course, such as the costs
of obtaining audited financial
statements, may still be incurred as a
result of the operations of the entity as
a CCP and the regulatory oversight of
the central counterparty operations. In
addition, if any of the CCPs are entities
that are subject to the periodic reporting
requirements of the Exchange Act, the
cost of filing a registration statement
covering the eligible CDS would be
lessened further as the information
regarding the CCP already would be
prepared. The availability of exemptions
under the Securities Act, the Exchange
Act, and the Trust Indenture Act also
would mean that CCPs would not incur
the costs of preparing disclosure
documents describing eligible CDS and
from preparing indentures and
arranging for the services of a trustee.
48 See, e.g., Securities Act Section 3(a)(14) [15
U.S.C. 77c(a)(14)], Securities Act Rule 238 [17 CFR
230.238]; Exchange Act Section 12(a) [15 U.S.C.
78l], and Exchange Act Rule 12h–1(d) and (e) [17
CFR 240.12h–1(d) and (e)].
49 17 CFR 230.238.
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B. Costs
The interim final temporary rules
exempting offers and sales of eligible
CDS that are or will be issued or cleared
by a Registered or Exempt CCP should
facilitate the use by eligible contract
participants of CDS CCPs that are the
subject of exemptive orders at minimal
cost to the CCP or investors. Because the
interim final temporary rules are selfexecuting, the costs of being able to rely
on such exemptions, we believe, are
minimal.
Absent an exemption, a CCP may
have to file a registration statement
covering the offer and sale of the eligible
CDS, may have to satisfy the applicable
provisions of the Trust Indenture Act,
and may have to register the class of
eligible CDS that it has issued or cleared
under the Exchange Act, which would
provide investors with civil remedies in
addition to antifraud remedies. While a
CCP registration statement covering
eligible CDS (or the offer and sale of
such eligible CDS) may provide certain
information about the CCP, CDS
contract terms, and the identification of
reference entities or reference securities,
it would not necessarily provide the
type of information necessary to assess
the credit risk of the reference entity or
reference security. Further, while a CCP
registration statement would provide
information to the CDS market
participants, as well as to the market as
a whole, a condition of the clearing
agency exemption in the exemptive
orders is that the CCPs make their
audited financial statements and other
information about themselves publicly
available. We recognize that a
consequence of the exemptions would
be the unavailability of certain remedies
under the Securities Act and the
Exchange Act and certain protections
under the Trust Indenture Act. While an
investor would be able to pursue an
antifraud action in connection with the
purchase and sale of eligible CDS under
Exchange Act Section 10(b),50 it would
not be able to pursue civil remedies
under Sections 11 or 12 of the Securities
Act.51 We could still pursue an
antifraud action in the offer and sale of
eligible CDS issued or cleared by a
CCP.52
50 15
U.S.C. 78j(b).
U.S.C. 77k and 77l.
52 See 15 U.S.C. 77q and 15 U.S.C. 78j(b).
51 15
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VII. Consideration of Impact On the
Economy, Burden On Competition and
Promotion of Efficiency, Competition
and Capital Formation
Section 23(a)(2) of the Exchange
Act 53 requires us, when adopting rules
under the Exchange Act, to consider the
impact that any new rule would have on
competition. Section 23(a)(2) prohibits
us from adopting any rule that would
impose a burden on competition not
necessary or appropriate in furtherance
of the purposes of the Exchange Act. In
addition, Section 2(b) 54 of the Securities
Act and Section 3(f) 55 of the Exchange
Act require us, when engaging in
rulemaking where we are required to
consider or determine whether an action
is necessary or appropriate in the public
interest, to also consider whether the
action will promote efficiency,
competition, and capital formation.
We are adopting interim final
temporary rules that would exempt
eligible CDS issued or cleared by a
Registered or Exempt CCP from all
provisions of the Securities Act, other
than the Section 17(a) antifraud
provision, as well as from the
registration requirements under Section
12 of the Exchange Act and the
provisions of the Trust Indenture Act.
Because our interim final temporary
exemptions will be available to any
Registered or Exempt CCP offering and
selling eligible CDS, we do not believe
that our actions today will impose a
burden on competition. We also believe
that the ability to settle CDS through
CCPs will improve the transparency of
the CDS market and provide greater
assurance to participants as to the
capacity of the eligible CDS
counterparty to perform its obligations
under the eligible CDS. We believe that
increased transparency in the CDS
market could help to decrease further
market turmoil and thereby facilitate the
capital formation process.
VIII. Regulatory Flexibility Act
Certification
The Commission hereby certifies
pursuant to 5 U.S.C. 605(b) that the
interim final temporary rules contained
in this release will not have a significant
economic impact on a substantial
number of small entities. The interim
final temporary rules exempt eligible
CDS that are or will be issued or cleared
by a Registered or Exempt CCP. None of
the entities that are eligible to meet the
requirements of the exemption from
registration under Section 17A is a
small entity. For this reason, the interim
53 15
U.S.C. 78w(a)(2).
U.S.C. 77b(b).
55 15 U.S.C. 78c(f).
14:54 Jan 21, 2009
IX. Statutory Authority and Text of the
Rules and Amendments
The rules and amendments described
in this release are being adopted under
the authority set forth in Sections 18, 19
and 28 of the Securities Act; Sections
12(h), 23(a) and 36 of the Exchange Act;
and Section 304(d) of the Trust
Indenture Act.
List of Subjects
17 CFR Parts 230, 240 and 260.
Reporting and recordkeeping
requirements, Securities.
Text of the Rules and Amendments
For the reasons set out in the
preamble, the Commission amends Title
17, Chapter II, of the Code of Federal
Regulations as follows:
■
PART 230—GENERAL RULES AND
REGULATIONS, SECURITIES ACT OF
1933
1. The authority citation for Part 230
continues to read, in part, as follows:
■
Authority: 15 U.S.C. 77b, 77c, 77d, 77f,
77g, 77h, 77j, 77r, 77s, 77z–3, 77sss, 78c, 78d,
78j, 78l, 78m, 78n, 78o, 78t, 78w, 78ll(d),
78mm, 80a–8, 80a–24, 80a–28, 80a–29, 80a–
30, and 80a–37, unless otherwise noted.
*
*
*
*
*
2. Section 230.146 is amended by
adding paragraph (c)T to read as
follows:
■
§ 230.146
Act.
Rules under section 18 of the
*
*
*
*
*
(c)T Temporary definition of eligible
contract participant as qualified
purchaser. For purposes of Section
18(b)(3) of the Act (15 U.S.C. 77r(b)(3)),
the term ‘‘qualified purchaser’’ shall
mean any eligible contract participant
(as defined in Section 1a(12) of the
Commodity Exchange Act (7 U.S.C.
1a(12)) as in effect on the date of
adoption of this section, other than a
person who is an eligible contract
participant under Section 1(a)(12)(C) of
the Commodity Exchange Act) that has
been sold an eligible credit default swap
(as defined in Rule 239T of this Act) in
reliance on Rule 239T of this Act. This
temporary rule will expire on
September 25, 2009.
■ 3. Section 230.239T is added to read
as follows:
§ 230.239T Temporary exemption for
eligible credit default swaps.
(a) Except as expressly provided in
paragraph (b) and (c) of this section, the
54 15
VerDate Nov<24>2008
final temporary rules should not have a
significant economic impact on a
substantial number of small entities.
Jkt 217001
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Act does not apply to any eligible credit
default swap that is:
(1) Issued or cleared by a clearing
agency registered as a clearing agency
under Section 17A of the Securities
Exchange Act of 1934 (15 U.S.C. 78q–1)
or exempt from registration under
Section 17A of the Securities Exchange
Act of 1934 pursuant to a rule,
regulation, or order of the Commission;
and
(2) Offered and sold only to an
eligible contract participant (as defined
in Section 1a(12) of the Commodity
Exchange Act (7 U.S.C. 1a(12)) as in
effect on the date of adoption of this
section, other than a person who is an
eligible contract participant under
Section 1(a)(12)(C) of the Commodity
Exchange Act).
(b) The exemption provided in
paragraph (a) of this section does not
apply to the provisions of Section 17(a)
of the Act (15 U.S.C. 77q(a)).
(c) Offers and sales. Any offer or sale
of an eligible credit default swap
pursuant to this section by or on behalf
of the issuer of an identified security
that is to be delivered if there is a creditrelated event or whose value is used to
determine the amount of the settlement
obligation, an affiliate of such issuer, or
an underwriter, will constitute a
‘‘contract for sale of,’’ ‘‘sale of,’’ ‘‘offer
for sale,’’ or ‘‘offer to sell’’ such
identified security under Section 2(a)(3)
of the Act (15 U.S.C. 77b(a)(3)).
(d) Definition of Eligible Credit
Default Swap. For purposes of this
section, an eligible credit default swap
is a bilateral executory derivative
contract not subject to individual
negotiation:
(1) in which a buyer makes payments
to the seller and, in return, receives a
payout if there is a default or other
credit event involving identified
obligation(s) or identified entity(ies)
within a certain time; and
(2) The agreement for which includes
the:
(i) Specification of the identified
obligation or obligor; or, in the case of
an identified group or index thereof, all
of the identified obligations or obligors
comprising any such group or index;
(ii) Term of the agreement;
(iii) Notional amount upon which
payment obligations are calculated;
(iv) Credit-related events that trigger a
settlement obligation; and
(v) Obligations to be delivered if there
is a credit-related event or, if it is a cash
settlement, the obligations whose value
is to be used to determine the amount
of settlement obligation under the
eligible credit default swap.
(e) This temporary rule will expire on
September 25, 2009.
E:\FR\FM\22JAR1.SGM
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Federal Register / Vol. 74, No. 13 / Thursday, January 22, 2009 / Rules and Regulations
temporary rule will expire on
September 25, 2009.
PART 240—GENERAL RULES AND
REGULATIONS, SECURITIES
EXCHANGE ACT OF 1934
PART 260—GENERAL RULES AND
REGULATIONS, TRUST INDENTURE
ACT OF 1939
4. The authority citation for Part 240
continues to read, in part, as follows:
■
Authority: 15 U.S.C. 77c, 77d, 77g, 77j,
77s, 77z–2, 77z–3, 77eee, 77ggg, 77nnn,
77sss, 77ttt, 78c, 78d, 78e, 78f, 78g, 78i, 78j,
78j–1, 78k, 78k–1, 78l, 78m, 78n, 78o, 78p,
78q, 78s, 78u–5, 78w, 78x, 78ll, 78mm, 80a–
20, 80a–23, 80a–29, 80a–37, 80b–3, 80b–4,
80b–11, and 7201 et seq., and 18 U.S.C. 1350,
unless otherwise noted.
■
*
*
*
*
*
5. Section 240.12a–10T is added to
read as follows:
§ 260.4d–11T Temporary exemption for
eligible credit default swaps offered and
sold in reliance on Securities Act of 1933
Rule 239T (§ 230.239T).
§ 240.12a–10T Temporary exemption of
eligible credit default swaps from Section
12(a) of the Act.
Any eligible credit default swap (as
defined in Rule 239T of this chapter, 17
CFR 230.239T), whether or not issued
under an indenture, is exempt from the
Act if offered and sold in reliance on
Rule 239T of this chapter. This
temporary rule will expire on
September 25, 2009.
■
(a) The provisions of Section 12(a) of
the Act (15 U.S.C. 78l(a)) do not apply
in respect of any eligible credit default
swap, as defined in Rule 239T of the
Securities Act of 1933 (17 CFR
230.239T) issued or cleared by a
clearing agency registered as a clearing
agency under Section 17A of the Act (15
U.S.C. 78q–1) or exempt from
registration under Section 17A of the
Act pursuant to a rule, regulation, or
order of the Commission, that will be
purchased by or sold to an eligible
contract participant (as defined in
Section 1a(12) of the Commodity
Exchange Act (7 U.S.C. 1a(12)) as in
effect on the date of adoption of this
section, other than a person who is an
eligible contract participant under
Section 1(a)(12)(C) of the Commodity
Exchange Act.
(b) This temporary rule will expire on
September 25, 2009.
■ 6. Section 240.12h–1 is amended by
adding paragraph (h)T to read as
follows:
§ 240.12h–1 Exemptions from registration
under section 12(g) of the Act.
rmajette on PRODPC74 with RULES
*
*
*
*
*
(h)T any eligible credit default swap,
as defined in Rule 239T of the Securities
Act of 1933 (17 CFR 230.239T), issued
or cleared by a clearing agency
registered as a clearing agency under
Section 17A of the Act (15 U.S.C. 78q–
1) or exempt from registration under
Section 17A of the Act pursuant to a
rule, regulation, or order of the
Commission that will be purchased by
or sold to an eligible contract
participant (as defined in Section 1a(12)
of the Commodity Exchange Act (7
U.S.C. 1a(12)) as in effect on the date of
adoption of this section, other than a
person who is an eligible contract
participant under Section 1(a)(12)(C) of
the Commodity Exchange Act. This
VerDate Nov<24>2008
14:54 Jan 21, 2009
Jkt 217001
7. The authority citation for Part 260
continues to read as follows:
Authority: 15 U.S.C. 77eee, 77ggg, 77nnn,
77sss, 78ll(d), 80b–3, 80b–4, and 80b–11.
8. Section 260.4d–11T is added to
read as follows:
■
By the Commission.
Dated: January 14, 2009.
Elizabeth M. Murphy,
Secretary.
[FR Doc. E9–1123 Filed 1–21–09; 8:45 am]
BILLING CODE 8011–01–P
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 52
[EPA–R09–OAR–2008–0705; FRL–8748–7]
Approval and Promulgation of
Implementation Plans; Nevada; Vehicle
Inspection and Maintenance Program
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Final rule.
SUMMARY: Under the Clean Air Act, EPA
is approving certain revisions, and
disapproving certain other revisions, to
the Nevada State Implementation Plan
submitted by the Nevada Division of
Environmental Protection. These
revisions relate to the application of the
State’s vehicle inspection and
maintenance program to vehicles
operated on Federal installations. EPA
is also correcting certain plan revisions
related to this subject that EPA
previously approved in error. The
intended effect is to ensure that vehicles
operated on Federal installations are
subject only to those requirements of the
State’s vehicle inspection and
maintenance program that apply in the
same manner and to the same extent to
nongovernmental entities.
PO 00000
Frm 00013
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3975
DATES: Effective Date: This rule is
effective on February 23, 2009.
ADDRESSES: EPA has established docket
number EPA–R09–OAR–2008–0705 for
this action. The index to the docket is
available electronically at https://
www.regulations.gov and in hard copy
at EPA Region IX, 75 Hawthorne Street,
San Francisco, California. While all
documents in the docket are listed in
the index, some information may be
publicly available only at the hard copy
location (e.g., copyrighted material), and
some may not be publicly available in
either location (e.g., CBI). To inspect the
hard copy materials, please schedule an
appointment during normal business
hours with the contact listed in the FOR
FURTHER INFORMATION CONTACT section.
FOR FURTHER INFORMATION CONTACT:
Eleanor Kaplan, Air Planning Office
(AIR–2), U.S. Environmental Protection
Agency, Region IX, (415) 947–4147,
kaplan.eleanor@epa.gov.
SUPPLEMENTARY INFORMATION:
Throughout this document, ‘‘we’’, ‘‘us’’
and ‘‘our’’ refer to EPA.
Table of Contents
I. Proposed Action
II. Public Comments
III. EPA Action
IV. Statutory and Executive Order Reviews
I. Proposed Action
On September 25, 2008 (73 FR 55466),
under the Clean Air Act (CAA or ‘‘Act’’),
EPA proposed to approve certain
revisions, and to disapprove certain
other revisions, to the Nevada State
Implementation Plan (SIP) submitted by
the Nevada Division of Environmental
Protection (NDEP). These revisions
relate to the application of the State’s
vehicle inspection and maintenance
(I/M) program to vehicles operated on
Federal installations. EPA also proposed
to correct certain SIP revisions related to
this subject that EPA previously
approved in error.
Specifically, EPA proposed to
approve paragraphs (a), (b) and (c) of
subsection (2) of Nevada Administrative
Code (NAC) section 445B.595
(‘‘Inspections of vehicles owned by
State or political subdivisions or
operated on federal installations’’).
NDEP submitted NAC 445B.595 to EPA
on May 11, 2007. We proposed to
approve these paragraphs of NAC
445B.595(2) because they extend the
same vehicle I/M testing, standards, and
certification requirements to motor
vehicles operated on Federal
installations as apply to
nongovernmental entities, consistent
with CAA section 118(a). See our
September 25, 2008 proposed rule at 73
FR 55467. By the same token, we
E:\FR\FM\22JAR1.SGM
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Agencies
[Federal Register Volume 74, Number 13 (Thursday, January 22, 2009)]
[Rules and Regulations]
[Pages 3967-3975]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-1123]
=======================================================================
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
17 CFR PARTS 230, 240 and 260
[Release Nos. 33-8999; 34-59246; 39-2549; File No. S7-02-09]
RIN 3235-AK26
Temporary Exemptions for Eligible Credit Default Swaps To
Facilitate Operation of Central Counterparties To Clear and Settle
Credit Default Swaps
AGENCY: Securities and Exchange Commission.
ACTION: Interim final temporary rules; request for comments.
-----------------------------------------------------------------------
SUMMARY: We are adopting interim final temporary rules providing
exemptions under the Securities Act of 1933, the Securities Exchange
Act of 1934, and the Trust Indenture Act of 1939 for certain credit
default swaps to facilitate the operation of one or more central
counterparties for those credit default swaps. The interim final
temporary rules define such credit default swaps as ``eligible credit
default swaps'' and exempt them from all provisions of the Securities
Act, other than the Section 17(a) anti-fraud provisions, as well as
from Exchange Act registration requirements and from the provisions of
the Trust Indenture Act, provided certain conditions are met. Our
interim final temporary rules also define as a ``qualified purchaser,''
for purposes of the ``covered securities'' provisions of Section 18 of
the Securities Act, any ``eligible contract participant,'' as defined
in Section 1a(12) of the Commodity Exchange Act (``CEA''), other than a
person who is an eligible contract participant under Section 1a(12)(C)
of the CEA, to whom a sale of a eligible credit default swap is made in
reliance on the interim final temporary Securities Act exemption.
DATES: Effective Date: The interim final temporary rules are effective
January 22, 2009 until September 25, 2009.
Comment Date: Comments on the interim final temporary rules should
be received on or before March 23, 2009.
ADDRESSES: Comments may be submitted by any of the following methods:
Electronic Comments
Use the Commission's Internet comment form (https://
www.sec.gov/rules/interim-final-temp.shtml);
Send an e-mail to rule-comments@sec.gov. Please include
File Number S7-02-09 on the subject line; or
Use the Federal Rulemaking Portal (https://
www.regulations.gov). Follow the instructions for submitting comments.
Paper Comments
Send paper comments in triplicate to Elizabeth M. Murphy,
Secretary, Securities and Exchange Commission, 100 F Street, NE.,
Washington, DC 20549-1090.
All submissions should refer to File Number S7-02-09. This file number
should be included on the subject line if e-mail is used. To help us
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/interim-final-temp.shtml).
Comments are also available for public inspection and copying in the
Commission's Public Reference Room, 100 F Street, NE., Washington, DC
20549, on official business days between the hours of 10 a.m. and 3
p.m. All comments received will be posted without change; we do not
edit personal identifying information from submissions. You should
submit only information that you wish to make available publicly.
FOR FURTHER INFORMATION CONTACT: Amy M. Starr, Senior Special Counsel,
or Kim McManus, Special Counsel, Office of Chief Counsel, Division of
Corporation Finance, at (202) 551-3500, U.S. Securities and Exchange
Commission, 100 F Street, NE., Washington, DC 20549-3628.
SUPPLEMENTARY INFORMATION: We are adopting interim final temporary Rule
239T and a temporary amendment to Rule 146 under the Securities Act of
1933 (``Securities Act'').\1\ We are also adopting interim final
temporary Rule 12a-10T and Rule 12h-1(h)T under the Securities Exchange
Act of 1934 (``Exchange Act'') \2\ and interim final temporary Rule 4d-
11T under the Trust Indenture Act of 1939 (``Trust Indenture Act'').\3\
---------------------------------------------------------------------------
\1\ 15 U.S.C. 77a et seq.
\2\ 15 U.S.C. 78a et seq.
\3\ 15 U.S.C. 77aaa et seq.
---------------------------------------------------------------------------
I. Background
In response to the recent turmoil in the financial markets, we have
taken multiple actions to protect investors and ensure the integrity of
the nation's securities markets.\4\ Today we are taking further action
designed to address concerns related to the market in credit default
swaps (``CDS''). The over-the-counter (``OTC'') market for CDS has been
a source of concerns to us and other financial regulators. These
concerns include the systemic risk posed by CDS, highlighted by the
possible inability of parties to meet their obligations as
counterparties and the potential resulting adverse effects on other
markets and the financial system.\5\ Recent credit market events have
demonstrated the seriousness of these risks in a CDS market operating
without meaningful regulation, transparency,\6\ or
[[Page 3968]]
central counterparties (``CCPs'').\7\ These events have emphasized the
need for CCPs as mechanisms to help control such risks.\8\ A CCP for
CDS could be an important step in reducing the counterparty risks
inherent in the CDS market, and thereby help mitigate potential
systemic impacts. In November 2008, the President's Working Group on
Financial Markets stated that the implementation of a CCP for CDS was a
top priority \9\ and, in furtherance of this recommendation, the
Commission, the FRB and the Commodity Futures Trading Commission
(``CFTC'') signed a Memorandum of Understanding \10\ that establishes a
framework for consultation and information sharing on issues related to
CCPs for CDS. Given the continued uncertainty in this market, taking
action to help foster the prompt development of CCPs, including
granting conditional exemptions from certain provisions of the federal
securities laws, is in the public interest. The interim final temporary
rules we are adopting are intended to facilitate the ability of one or
more CCPs for CDS to operate by providing exemptions from certain
regulatory provisions that might otherwise prevent them from engaging
in such activities.
---------------------------------------------------------------------------
\4\ A nonexclusive list of the Commission's actions to stabilize
financial markets during this credit crisis include: adopting a
package of measures to strengthen investor protections against naked
short selling, including rules requiring a hard T+3 close-out,
eliminating the options market maker exception of Regulation SHO,
and expressly targeting fraud in short selling transactions (See
Securities Exchange Act Release No. 58572 (September 17, 2008), 73
FR 54875 (September 23, 2008)); issuing an emergency order to
enhance protections against naked short selling in the securities of
primary dealers, Federal National Mortgage Association (``Fannie
Mae''), and Federal Home Loan Mortgage Corporation (``Freddie Mac'')
(See Securities Exchange Act Release No. 58166 (July 15, 2008), 73
FR 42379 (July 21, 2008)); taking temporary emergency action to ban
short selling in financial securities (See Securities Exchange Act
Release No. 58592 (September 18, 2008), 73 FR 55169 (September 24,
2008)); approving emergency rulemaking to ensure disclosure of short
positions by hedge funds and other institutional money managers (See
Securities Exchange Act Release No. 58591A (September 21, 2008), 73
FR 55557 (September 25, 2008)); proposing rules to strengthen the
regulation of credit rating agencies and making the limits and
purposes of credit ratings clearer to investors (See Securities
Exchange Act Release No. 57967 (June 16, 2008), 73 FR 36212 (June
25, 2008); entering into a Memorandum of Understanding with the
Board of Governors of the Federal Reserve System (``FRB'') to make
sure key federal financial regulators share information and
coordinate regulatory activities in important areas of common
interest (See Memorandum of Understanding Between the U.S.
Securities and Exchange Commission and the Board of Governors of the
Federal Reserve System Regarding Coordination and Information
Sharing in Areas of Common Regulatory and Supervisory Interest (July
7, 2008), https://www.sec.gov/news/press/2008/2008-134_mou.pdf).
\5\ In addition to the potential systemic risks that CDS pose to
financial stability, we are concerned about other potential risks in
this market, including operational risks, risks relating to
manipulation and fraud, and regulatory arbitrage risks.
\6\ See Policy Objectives for the OTC Derivatives Market, The
President's Working Group on Financial Markets (November 14, 2008),
https://www.ustreas.gov/press/releases/reports/policyobjectives.pdf
(``Public reporting of prices, trading volumes and aggregate open
interest should be required to increase market transparency for
participants and the public.'').
\7\ See The Role of Credit Derivatives in the U.S. Economy
Before the H. Agric. Comm., 110th Cong. (2008) (Statement of Erik
Sirri, Director of the Division of Trading and Markets, Commission).
\8\ See id.
\9\ See Policy Objectives for the OTC Derivatives Market, The
President's Working Group on Financial Markets (November 14, 2008),
https://www.ustreas.gov/press/releases/reports/policyobjectives.pdf.
See also Policy Statement on Financial Market Developments, The
President's Working Group on Financial Markets (March 13, 2008),
https://www.treas.gov/press/releases/reports/
pwgpolicystatemktturmoil_03122008.pdf; Progress Update on March
Policy Statement on Financial Market Developments, The President's
Working Group on Financial Markets (October 2008), https://
www.treas.gov/press/releases/reports/q4progress%20update.pdf.1
\10\ See Memorandum of Understanding Between the Board of
Governors of the Federal Reserve System, the U.S. Commodity Futures
Trading Commission and the U.S. Securities and Exchange Commission
Regarding Central Counterparties for Credit Default Swaps (November
14, 2008), https://www.treas.gov/press/releases/reports/finalmou.pdf
(``MOU'').
---------------------------------------------------------------------------
A CDS is a bilateral contract between two parties, known as
counterparties. The value of this financial contract is based on
underlying obligations (``reference obligations'') of a single entity
(a ``reference entity'') or on a particular security or other debt
obligation (``reference security''), or an index of several such
entities, securities, or obligations. The obligation of a seller to
make payments under a CDS contract is triggered by a default or other
credit event as to such entity or entities or such security or
securities. Investors may use CDS for a variety of reasons, including
to offset or insure against risk in their fixed-income portfolios, to
take synthetic positions in bonds or in segments of the debt market as
represented by an index, or to capitalize on the volatility in credit
spreads during times of economic uncertainty. In recent years, CDS
market volumes have rapidly increased.\11\ This growth has coincided
with a significant rise in the types and number of entities
participating in the CDS market.\12\
---------------------------------------------------------------------------
\11\ See Semiannual OTC derivatives statistics at end-December
2007, Bank for International Settlements (``BIS''), available at
https://www.bis.org/statistics/otcder/dt1920a.pdf.
\12\ CDS were initially created to meet the demand of banking
institutions looking to hedge and diversify the credit risk
attendant with their lending activities. However, financial
institutions such as insurance companies, pension funds, securities
firms and hedge funds have entered the CDS market.
---------------------------------------------------------------------------
The operation of a well-regulated CCP can significantly reduce
counterparty risks by preventing the failure of a single market
participant from having a disproportionate effect on the overall
market. A CCP would novate bilateral trades, which would result in the
CCP entering into separate contractual arrangements with both
counterparties--becoming buyer to one and seller to the other.\13\
Today, CDS agreements generally are negotiated and entered into
bilaterally, but both parties may agree that one party may novate the
agreement and substitute another party to take responsibility for
performance, by acting as the counterparty, under the agreement. In a
CCP arrangement, both parties entering a CDS would novate their trades
to the CCP, and the CCP would stand in as the counterparty to all
parties of the CDS it clears. Through this novation process, the
counterparty risk of a CDS would be effectively concentrated in the
CCP.
---------------------------------------------------------------------------
\13\ ``Novation'' is a ``process through which the original
obligation between a buyer and seller is discharged through the
substitution of the CCP as seller to buyer and buyer to seller,
creating two new contracts.'' Committee on Payment and Settlement
Systems, Technical Committee of the International Organization of
Securities Commissioners, Recommendations for Central Counterparties
(November 2004) at 66.
---------------------------------------------------------------------------
In companion actions to these interim final temporary rules, we are
temporarily exempting, subject to conditions, a clearing agency acting
as a CCP from the requirement to register as a clearing agency under
Section 17A of the Exchange Act \14\ solely to perform the functions of
a clearing agency for certain CDS transactions, and also certain
eligible contract participants \15\ and others from certain Exchange
Act requirements with respect to certain CDS.\16\ We also are
temporarily exempting any exchange that effects transactions in certain
CDS from the requirements under Sections 5 and 6 of the Exchange Act
\17\ to register as a national securities exchange, and any broker or
dealer that effects transactions on an exchange in certain CDS from the
requirements of Section 5 of the Exchange Act.
---------------------------------------------------------------------------
\14\ 15 U.S.C. 78q-1.
\15\ See 7 U.S.C. 1a(12).
\16\ See Securities Exchange Act Release Nos. 59164 and 59165
(December 24, 2008).
\17\ 15 U.S.C. 78e and 78f.
---------------------------------------------------------------------------
In connection with these actions to facilitate the operation of
these CCPs for the CDS market, we believe that it is appropriate and
necessary to provide temporary exemptions from certain provisions of
the Securities Act, the Exchange Act and the Trust Indenture Act,
subject to certain conditions described in the companion exemptive
orders and in the exemptions themselves. We believe that these interim
final temporary rules, and the exemptive orders we are providing under
the Exchange Act, will facilitate the operation of one or more CCPs
that will clear and settle CDS transactions while enabling us to
provide oversight to the CDS market.
We believe that the operation of one or more CCPs in accordance
with our exemptions likely would improve the efficiency and
effectiveness of the CDS market, provide for increased transparency of
exposures to particular reference entities or reference securities, and
increase available information about reference entities or reference
securities. The conditions in the companion exemptive orders will
enable us to oversee the development of CDS CCPs and exchanges as they
evolve, and to take such additional action as we may deem necessary to
promote the public interest and the protection of investors. Moreover,
the limited duration of the exemptions and the interim final temporary
rules provided today will enable one or more CCPs and CDS exchanges to
become operational while we gain useful experience with the CDS market
and evaluate the public input, including comments, we receive on the
temporary rules and exemptions.
II. Discussion of the Interim Final Temporary Rules and Amendments
We are adopting interim final temporary rules and amendments to
[[Page 3969]]
existing rules (collectively, ``interim final temporary rules'') to
provide certain conditional exemptions under the Securities Act, the
Exchange Act and the Trust Indenture Act.
A. Scope of the Interim Final Temporary Rules
Our authority over the OTC market for CDS is limited. Specifically,
Section 2A of the Securities Act and Section 3A of the Exchange Act
limit our authority over ``swap agreements'' as defined in Section 206A
of the Gramm-Leach-Bliley Act.\18\ For those CDS that are swap
agreements, the exclusion from the definition of security in Section 2A
of the Securities Act and Section 3A of the Exchange Act and related
provisions will continue to apply. Our action today does not affect
these CDS, and these interim final temporary rules do not apply to
them. For those CDS that are not swap agreements (``non-excluded
CDS''), our action today provides certain conditional exemptions from
the provisions of the Securities Act, the Exchange Act, and the Trust
Indenture Act and is designed to encourage the development and
operation of one or more CDS CCPs and CDS exchanges.\19\
---------------------------------------------------------------------------
\18\ 15 U.S.C. 77b(b)-1 and 15 U.S.C. 78c-1. Section 2A of the
Securities Act and Section 3A of the Exchange Act excludes both a
non-security-based and a security-based ``swap agreement'' from the
definition of ``security'' under Section 2(a)(1) of the Securities
Act, 15 U.S.C. 77b(a)(1) and Section 3(a)(10) of the Exchange Act,
15 U.S.C. 78c(a)(10). Section 206A of the Gramm-Leach-Bliley Act
defines a ``swap agreement'' as ``any agreement, contract, or
transaction between eligible contract participants (as defined in
section 1a(12) of the Commodity Exchange Act * * *) * * * the
material terms of which (other than price and quantity) are subject
to individual negotiation. * * *'' 15 U.S.C. 78c note.
\19\ Section 28 of the Securities Act authorizes us to exempt
any person, security or transaction from any provision of the
Securities Act by rule or regulation to the extent that the
exemption is necessary or appropriate in the public interest and
consistent with the protection of investors. 15 U.S.C. 77z-3.
Similarly, Section 36 of the Exchange Act gives us the authority to
exempt any person, security or transaction from any Exchange Act
provision by rule, regulation or order, to the extent that the
exemption is necessary or appropriate in the public interest and
consistent with the protection of investors. 15 U.S.C. 78mm.
Finally, Section 304(d) of the Trust Indenture Act authorizes us to
exempt conditionally or unconditionally any person, security or
transaction from any Trust Indenture Act provision by rules or
regulation to the extent that the exemption is necessary or
appropriate in the public interest and consistent with the
protection of investors and the purposes fairly intended by the
Trust Indenture Act. 15 U.S.C. 77ddd(d).
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B. Securities Act Rule 239T
We are adopting interim final temporary Securities Act Rule 239T to
exempt certain CDS (``eligible CDS'') \20\ that are being or will be
issued or cleared by a CCP satisfying the conditions set forth in the
companion exemptions, or registered as a clearing agency under Section
17A of the Exchange Act (``Registered or Exempt CCP''), to eligible
contract participants from all provisions of the Securities Act, except
the anti-fraud provisions of Section 17(a) of the Securities Act.\21\
Securities Act Rule 239T will permit the offer and sale of such
eligible CDS that are or will be issued or cleared by a Registered or
Exempt CCP without requiring compliance with Section 5 of the
Securities Act, and communications used in connection with such offers
and sales will not be subject to Section 12(a)(2) liability under the
Securities Act.
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\20\ As we discuss below, we have included a definition of
``eligible credit default swap'' in interim final temporary
Securities Act Rule 239T.
\21\ 15 U.S.C. Sec. 77q. This exemption is consistent with the
Securities Act exemptions for standardized options and security
futures products. See Section 3(a)(14) [15 U.S.C. Sec. 77c(a)(14)]
and Securities Act Rule 238 [17 CFR 230.238].
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Absent this exemption, the Securities Act may require registration
of the offer and sale of eligible CDS that are or will be issued or
cleared by a Registered or Exempt CCP. We believe that the interim
final temporary rules exempting offers and sales of such eligible CDS
by a Registered or Exempt CCP will facilitate the use by eligible
contract participants of CCPs for eligible CDS. Indeed, without also
exempting the offers and sales of the eligible CDS by a Registered or
Exempt CCP from the registration requirements of the Securities Act and
the Exchange Act and the provisions of the Trust Indenture Act, we
believe that the CCPs would not be able to operate in the manner
contemplated by the Exchange Act exemptive orders. In addition, the
Securities Act, Exchange Act and Trust Indenture Act exemptions should
encourage market participants to clear their CDS through the CCPs.
Under Securities Act Rule 239T, an eligible CDS would be exempt
from the registration requirements of the Securities Act if it is or
will be issued or cleared by a Registered or Exempt CCP, and if the
eligible CDS is offered and sold only to an ``eligible contract
participant'' (as defined in Section 1a(12) of the CEA as in effect on
the date of adoption of this rule, other than a person who is an
eligible contract participant under Section 1a(12)(C) of the CEA).\22\
We have included a definition of eligible CDS solely for purposes of
the interim final temporary rules. Under this definition, an eligible
CDS is a bilateral executory derivative contract not subject to
individual negotiation (1) in which a buyer makes payments to the
seller and, in return, receives a payout if there is a default or other
credit event involving the reference obligation(s) or reference
entity(ies) within a certain time, and (2) the agreement for which
includes the:
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\22\ See 7 U.S.C. 1(a)(12). The exemption would be limited to
those persons defined as eligible contract participants in the
statute and would not extend to those persons that are included in
the definition through regulatory action by the CFTC. See 7 U.S.C.
1(a)(12)(C).
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Specification of the reference obligation or obligor; or,
in the case of a reference group or index thereof, all of the reference
obligations or obligors comprising any such group or index);
Term of the agreement;
Notional amount upon which payment obligations are
calculated;
Credit-related events that trigger a settlement
obligation; and
Obligations to be delivered if there is a credit-related
event or, if it is a cash settlement, the obligations whose value is to
be used to determine the amount of settlement obligation under the
eligible credit default swap.
Securities Act Rule 239T will permit the offer and sale of eligible
CDS that are or will be issued or cleared by a Registered or Exempt CCP
without requiring compliance with Section 5 of the Securities Act,
while assuring the availability of information to buyers and sellers of
CDS, due to certain information conditions in the companion exemptive
orders,\23\ and preserving anti-fraud liability under Section 17(a) of
the Securities Act, which currently applies to security-based swap
agreements. Securities Act Rule 239T also provides an exemption from
the liability provisions of Securities Act Section 12. Thus, oral or
written communications used in connection with the offer and sale of
eligible CDS that are or will be issued or cleared by a Registered or
Exempt CCP in reliance on the rule will not be
[[Page 3970]]
subject to liability under Securities Act Section 12(a)(2).
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\23\ We note that among the conditions of the exemptions, or
representations in the exemptive requests on which we are relying,
from clearing registration are that: (1) Information is available
about the terms of the CDS, the creditworthiness of the CCP or any
guarantor, and the clearing and settlement process for the CDS; and
(2) the reference entity, the issuer of the reference security, or
the reference security is one of the following: an entity reporting
under the Exchange Act, providing Securities Act Rule 144A(d)(4)
information, or about which financial information is otherwise
publicly available; a foreign private issuer that has securities
listed outside the United States and has its principal trading
market outside the United States; a foreign sovereign debt security;
an asset-backed security, as defined in Regulation AB [17 CFR
229.1100], issued in a registered transaction with publicly
available distribution reports; an asset-backed security issued or
guaranteed by Fannie Mae, Freddie Mac or the Government National
Mortgage Association (``Ginnie Mae''); or indexes in which 80
percent or more of the index's weight is comprised of these
reference entities or reference securities.
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The Securities Act exemption in the interim final temporary rule is
limited to offers and sales to eligible contract participants (as
defined in Section 1a(12) of the CEA as in effect on the date of
adoption of the rule, other than a person that is an eligible contract
participant under Section 1a(12)(C) of the CEA). Under Securities Act
Section 2A, a security-based swap agreement that is entered into
between eligible contract participants is not permitted to be
registered under the Securities Act, but the provisions of Securities
Act Section 17(a) continue to apply to such transactions. The operation
of one or more CCPs pursuant to the actions we are taking today will
allow such security-based swap agreements to continue to be entered
into between eligible contract participants and then be novated to the
CCP. The Securities Act exemption is intended to limit investor
involvement in eligible CDS that are issued or cleared by a Registered
or Exempt CCP to eligible contract participants, who are those persons
Congress determined were qualified to engage in activities in the
generally unregulated (other than with respect to the antifraud
provisions of the Securities Act and the Exchange Act) \24\ OTC CDS
market.
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\24\ See Title III of the Commodity Futures Modernization Act of
2000 (Pub. L. 106-554) and the definition of eligible contract
participant in Title I of the Commodity Futures Modernization Act of
2000 [7 U.S.C. 1a(12)]. The term ``eligible contract participant''
generally includes various regulated financial institutions,
business enterprises that meet certain tests relating to total
assets or net worth, certain pension funds, state and local
governments, and certain wealthy individuals.
In addition, the provisions of Section 16 of the Exchange Act
apply to security-based swap agreements. See 15 U.S.C. 78p(g). The
exemptions are available only with regard to non-excluded CDS
satisfying the exemption's conditions and not other types of
derivative contracts.
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The Securities Act interim final temporary rule also provides that
any offer or sale of an eligible CDS that is or will be issued or
cleared by a Registered or Exempt CCP by or on behalf of the issuer of
a security, an affiliate of such issuer, or an underwriter, if such
security is delivered in settlement or whose value is used to determine
the amount of the settlement obligation, will constitute a ``contract
for sale of,'' ``sale of,'' ``offer for sale,'' or ``offer to sell''
such security under Section 2(a)(3) of the Securities Act. This
provision is intended to ensure that an eligible CDS that is or will be
issued or cleared by a Registered or Exempt CCP cannot be used by an
issuer, affiliate of an issuer or underwriter to circumvent the
registration requirements of Section 5 with respect to an issuer's
security for such eligible CDS.\25\ As a result, a transaction by such
persons in an eligible CDS that is or will be issued or cleared by a
Registered or Exempt CCP having such securities of the issuer also is a
transaction in the issuer's securities that must be registered under
the Securities Act, unless an exemption from registration is available.
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\25\ This provision is similar to the condition in the
Securities Act exemption in Rule 238 for standardized options [17
CFR 230.238] and in Securities Act Section 2(a)(3) [15 U.S.C.
77b(a)(3)] relating to security futures products.
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Further, we are adopting on an interim final temporary basis an
amendment to Securities Act Rule 146. Under the temporary amendment to
Securities Act Rule 146, eligible contract participants that are sold
eligible CDS in reliance on interim final temporary Securities Act Rule
239T will be defined as ``qualified purchasers'' under Section 18(b)(3)
of the Securities Act and thereby such eligible CDS that are or will be
issued or cleared by a Registered or Exempt CCP will be considered
``covered securities'' under Section 18 of the Securities Act and
exempt from state blue sky laws.\26\ We are adopting this amendment
because we believe that eligible contract participants are the kinds of
sophisticated investors who do not require the protections of
registration under state securities laws. In this regard, as we discuss
above, Congress determined that eligible contract participants were the
types of persons that were able to engage in activities in the OTC CDS
market unregulated by the Commission and preempted the application of
certain state laws to transactions in OTC security-based swap
agreements, including CDS.\27\ We believe that defining such eligible
contract participants as ``qualified purchasers'' for purposes of
engaging in transactions in eligible CDS in reliance on temporary
Securities Act Rule 239T would be consistent with such Congressional
intent.
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\26\ State securities regulation of covered securities generally
is limited under Section 18(b). Under Section 18(b)(3), covered
securities are securities offered and sold to qualified purchasers,
as defined by the Commission.
\27\ See 7 U.S.C. 16(e)(2).
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C. Exchange Act Rule 12a-10T and Rule 12h-1(h)T
We also are adopting two interim final temporary rules relating to
Exchange Act registration of eligible CDS that are or have been issued
or cleared by a Registered or Exempt CCP. We are adopting interim final
temporary Exchange Act Rule 12a-10T to exempt eligible CDS that are or
have been issued or cleared by a Registered or Exempt CCP from the
provisions of Section 12(a) of the Exchange Act under certain
conditions.\28\ We also are adopting an interim final temporary
amendment to Exchange Act Rule 12h-1 to exempt eligible CDS that are or
have been issued or cleared by a Registered or Exempt CCP from the
provisions of Section 12(g) of the Exchange Act under certain
conditions.\29\ This exemption is the same as that available to
standardized options issued by a registered options clearing agency and
security futures products issued by a registered clearing agency, and
this temporary rule should facilitate the operation of the CCPs.
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\28\ 15 U.S.C. 78l(a).
\29\ 15 U.S.C. 78l(g).
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D. Trust Indenture Act Rule 4d-11T
We are adopting a new interim final temporary rule under Section
304(d) of the Trust Indenture Act that would exempt any eligible CDS,
as defined in Securities Act Rule 239T and offered and sold in reliance
on Securities Act Rule 239T, from having to comply with the provisions
of the Trust Indenture Act.\30\ We believe an exemption from the Trust
Indenture Act is appropriate in this situation.
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\30\ The Trust Indenture Act applies to debt securities sold
through the use of the mails or interstate commerce. Section 304 of
the Trust Indenture Act exempts from the Act a number of securities
and transactions. Section 304(a) of the Trust Indenture Act exempts
securities that are exempt under Securities Act Section 3(a) but
does not exempt from the Trust Indenture Act securities that are
exempt by Commission rule. Accordingly, while Securities Act Rule
239T would exempt the offer and sale of eligible CDS satisfying
certain conditions from all the provisions of the Securities Act
(other than Section 17(a)), the Trust Indenture Act would continue
to apply.
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The Trust Indenture Act is aimed at addressing problems that
unregulated debt offerings posed for investors and the public,\31\ and
provides a mechanism for debtholders to protect and enforce their
rights with respect to the debt. We do not believe that the protections
contained in the Trust Indenture Act are needed at this time to protect
eligible contract participants to whom a sale of an eligible CDS is
made in reliance on interim final temporary Securities Act Rule 239T.
The identified problems that the Trust Indenture Act is intended to
address do not occur in the offer and sale of eligible CDS.\32\ For
example, eligible CDS are contracts between two parties and, as a
result, do not raise the same problem regarding the ability of parties
to enforce their rights under the instruments as would, for example, a
[[Page 3971]]
debt offering to the public. Moreover, through novation, the CCP
becomes the counterparty to the buyer and the seller, and each would
look directly to the CCP to satisfy the obligations under the eligible
CDS. As a consequence, enforcement of contractual rights and
obligations under the eligible CDS would occur directly between such
parties, and the Trust Indenture Act provisions would not provide any
additional meaningful substantive or procedural protections.
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\31\ See 15 U.S.C.77bbb(a).
\32\ 15 U.S.C. 77bbb(a).
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Accordingly, due to the nature of eligible CDS as bilateral
contracts that will have been issued or cleared by Registered or Exempt
CCPs, we do not believe the protections contained in the Trust
Indenture Act are currently needed with respect to these instruments.
Therefore, we believe the exemption is necessary or appropriate in the
public interest, consistent with the protection of investors and the
purposes fairly intended by the Trust Indenture Act.
E. Request for Comment
We request and encourage any interested person to submit comments
regarding the interim final temporary rules. In particular, we solicit
comment on the following questions:
We are interested in understanding what type of non-
excluded CDS would not be eligible for these exemptions. Are there
credit swaps that would not be encompassed within the scope of the
exemptions and that should be covered?
What are the amounts and types of CDS that may not satisfy
the conditions for the exemptions?
Is the definition of eligible CDS appropriate and does it
include the types of CDS that should be within the exemptions or should
there be another definition? Does the definition of eligible CDS
include all the appropriate or relevant material terms of a CDS? Should
we require more specificity as to the terms, including final settlement
valuations?
Each of the temporary exemptions contains particular
conditions. Should the Securities Act exemption in temporary Securities
Act Rule 239T be conditioned on the eligible CDS being issued or
cleared by a Registered or Exempt CCP? If not, why not?
Should there be information conditions in the Securities
Act exemptions themselves regarding the reference entities or reference
securities similar to the information requirements in the CCP exemptive
orders? If so, what type of information conditions should be included
and why? Is additional or different information from that contained in
the CCP exemption orders appropriate?
Are the Securities Act, Exchange Act and Trust Indenture
Act exemptions appropriate? If not, why not? Given the voluntary nature
of using a CCP, should we take a different approach?
The Securities Act exemption also provides that eligible
CDS that are or will be issued or cleared by a Registered or Exempt CCP
and are entered into with an issuer of a security, or an underwriter or
affiliate of such issuer, if such security is delivered in settlement
or whose value is used to determine the amount of the settlement
obligation, will be considered an offer and sale of such security at
that time. Are there circumstances in which the application of the
Securities Act to such security of the issuer should not apply at the
time of the offer and sale of eligible CDS that are or will be issued
or cleared by a Registered or Exempt CCP? Are there securities or
obligations used in CDS transactions that are not debt obligations? If
yes, please explain.
The Securities Act exemption is limited to offers and
sales to eligible contract participants. Should the exemption be
limited in this manner? If not, why not? Are there persons who invest
in CDS now in the OTC market that would not be able to take advantage
of the exemptions? If yes, please explain the categories of persons and
why the exemptions should include such persons.
The definition of ``qualified purchaser'' for purposes of
the interim final temporary amendment to Securities Act Rule 146
applies only to eligible contract participants that have been sold
eligible CDS in reliance on the new interim final temporary exemption
in Securities Act Rule 239T. Is this an appropriate definition and
should eligible contract participants that are sold eligible CDS
pursuant to Securities Act Rule 239T be considered ``qualified
purchasers'' for purposes of Section 18 of the Securities Act?
Should the Securities Act exemption be limited to an
exemption from Section 5 and Section 12 of the Securities Act? Please
explain your reasoning in detail.
Should we exempt eligible CDS that have been issued or
cleared by a Registered or Exempt CCP from the registration
requirements of the Exchange Act? If not, why?
The conditions of the temporary Exchange Act and Trust
Indenture Act exemptions are the same as the conditions to the
temporary Securities Act exemption. Is this appropriate or should there
be different conditions relating to the Exchange Act and Trust
Indenture Act exemptions? If yes, please explain.
The interim final temporary rules include an exemption
from the application of the Trust Indenture Act for eligible CDS that
are offered and sold in reliance on interim final Securities Act Rule
239T. Is this exemption appropriate or are there contractual
protections in the Trust Indenture Act that should be included as
mandatory provisions of an eligible CDS contract that is or will be
issued or cleared by a Registered or Exempt CCP? If yes, please explain
in detail.
III. Transition and Expiration Date of Interim Final Temporary Rules
We are adopting the interim final rules on a temporary basis until
September 25, 2009. We anticipate that this term of this exemption will
provide us with adequate time to evaluate the availability of the
exemptions applicable to CDS CCPs and non-excluded CDS, and whether any
conditions or provisions of such exemptions should be modified.
Adoption of the interim final temporary rules, which will be
effective on [effective date] and will continue in effect until
September 25, 2009, will facilitate the development of one or more CCPs
as well as our review of the CDS market. We have included several
requests for comment in this release. We will consider the public
comments we receive in determining whether we should revise the interim
final temporary rules in any respect, as well as whether we should
consider extending the exemptions. The rules will expire and cease to
be effective on September 25, 2009 unless we act to extend the
effective date or revise the interim final temporary rules.
IV. Other Matters
The Administrative Procedure Act generally requires an agency to
publish notice of a proposed rulemaking in the Federal Register.\33\
This requirement does not apply, however, if the agency ``for good
cause finds * * * that notice and public procedure are impracticable,
unnecessary, or contrary to the public interest.'' \34\ Further, the
Administrative Procedure Act also generally requires that an agency
publish an adopted rule in the Federal Register 30 days before it
becomes effective.\35\ This requirement does not apply, however, if the
agency finds good cause for making the rule effective sooner.\36\ We,
for good cause,
[[Page 3972]]
find that notice and solicitation of comment before adopting the new
rules is impracticable, unnecessary, or contrary to the public
interest.
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\33\ See 5 U.S.C. 553(b).
\34\ Id.
\35\ See 5 U.S.C. 553(d).
\36\ Id.
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For the reasons we discussed throughout this release, we believe
that we have good cause to act immediately to adopt these rules on an
interim final temporary basis. The OTC market for CDS has been a source
of concerns to us and other financial regulators. These concerns
include the systemic risk posed by CDS, highlighted by the possible
inability of parties to meet their obligations as counterparties and
the potential resulting adverse effects on other markets and the
financial system.\37\ Recent credit market events have demonstrated the
seriousness of these risks in a CDS market operating without meaningful
regulation, transparency,\38\ or CCPs.\39\ These events have emphasized
the need for CCPs as mechanisms to help control such risks.\40\ A CCP
for CDS could be an important step in reducing the counterparty risks
inherent in the CDS market, and thereby help mitigate potential
systemic impacts. In November 2008, the President's Working Group on
Financial Markets stated that the implementation of a CCP for CDS was a
top priority \41\ and, in furtherance of this recommendation, the
Commission, the FRB and the CFTC signed a Memorandum of Understanding
\42\ that establishes a framework for consultation and information
sharing on issues related to CCPs for CDS. Given the continued
uncertainty in this market, taking action to help foster the prompt
development of CCPs, including granting conditional exemptions from
certain provisions of the federal securities laws, thus is in the
public interest. The interim final temporary rules we are adopting are
intended to facilitate the ability of one or more CCPs for CDS to
operate by providing exemptions from certain regulatory provisions that
might otherwise prevent them from engaging in such activities. Absent
an exemption, the offer and sale of eligible CDS that are or will be
issued or cleared by a Registered or Exempt CCP may have to be
registered under the Securities Act, the eligible CDS that have been so
issued or cleared may have to be registered as a class under the
Exchange Act and the provisions of the Trust Indenture Act may need to
be complied with. We believe that the interim final temporary rules
exempting the registration of eligible CDS that are or will be issued
or cleared by a Registered or Exempt CCP under certain conditions will
facilitate the use by eligible contract participants of CDS CCPs.
Without also exempting the offers and sales of the eligible CDS from
the registration requirements of the Securities Act and the Exchange
Act and the provisions of the Trust Indenture Act, we believe that the
CCPs would not be able to operate in the manner contemplated by the
exemptive orders. We emphasize that we are requesting comments on the
interim final temporary rules and will carefully consider any comments
that we receive and respond to them in a subsequent release. Moreover,
these interim final temporary rules will expire on September 25, 2009.
Setting a termination date for the interim final temporary rules will
necessitate further Commission action no later than the end of that
period if we determine to continue the same, or similar, requirements
contained in the interim final temporary rules. We find that there is
good cause to have the rules effective as interim final temporary rules
on January 22, 2009 and that notice and public procedure in advance of
effectiveness of the interim final temporary rules is impracticable,
unnecessary and contrary to the public interest.\43\
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\37\ In addition to the potential systemic risks that CDS pose
to financial stability, we are concerned about other potential risks
in this market, including operational risks, risks relating to
manipulation and fraud, and regulatory arbitrage risks.
\38\ See Policy Objectives for the OTC Derivatives Market, The
President's Working Group on Financial Markets (November 14, 2008),
https://www.ustreas.gov/press/releases/reports/policyobjectives.pdf
(``Public reporting of prices, trading volumes and aggregate open
interest should be required to increase market transparency for
participants and the public.'')
\39\ See The Role of Credit Derivatives in the U.S. Economy
Before the H. Agric. Comm., 110th Cong. (2008) (Statement of Erik
Sirri, Director of the Division of Trading and Markets, Commission).
\40\ See id.
\41\ See Policy Objectives for the OTC Derivatives Market, The
President's Working Group on Financial Markets (November 14, 2008),
https://www.ustreas.gov/press/releases/reports/policyobjectives.pdf.
See also Policy Statement on Financial Market Developments, The
President's Working Group on Financial Markets (March 13, 2008),
https://www.treas.gov/press/releases/reports/
pwgpolicystatemktturmoil_03122008.pdf; Progress Update on March
Policy Statement on Financial Market Developments, The President's
Working Group on Financial Markets (October 2008), https://
www.treas.gov/press/releases/reports/q4progress%20update.pdf.
\42\ See MOU, supra note 10.
\43\ This finding also satisfies the requirements of 5 U.S.C.
808(2), allowing the rule amendment to become effective
notwithstanding the requirement of 5 U.S.C. 801 (if a federal agency
finds that notice and public comment are ``impractical, unnecessary
or contrary to the public interest,'' a rule ``shall take effect at
such time as the federal agency promulgating the rule determines'').
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V. Paperwork Reduction Act
The interim final temporary rules do not impose any new
``collections of information'' within the meaning of the Paperwork
Reduction Act of 1995 (``PRA''),\44\ nor do they create any new filing,
reporting, recordkeeping, or disclosure reporting requirements for a
CCP that is or will be issuing or clearing eligible CDS. Accordingly,
we are not submitting the interim final temporary rules to the Office
of Management and Budget for review in accordance with the PRA.\45\ We
request comment on whether our conclusion that there are no collections
of information is correct.
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\44\ 44 U.S.C. 3501 et seq.
\45\ 44 U.S.C. 3507(d) and 5 CFR 1320.11.
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VI. Cost-Benefit Analysis
We are adopting interim final temporary rules under the Securities
Act, the Exchange Act and the Trust Indenture Act that would exempt
eligible CDS that are or will be issued or cleared by a Registered or
Exempt CCP and offered and sold only to eligible contract participants
from all provisions of the Securities Act, other than the Section 17(a)
anti-fraud provision, as well as from the registration requirements
under Section 12 of the Exchange Act and from the provisions of the
Trust Indenture Act. These interim final temporary rules are intended
to facilitate the operation of one or more CCPs to act as a clearing
agency in the CDS market to reduce some of the risks in the CDS market.
A CDS is a bilateral contract between two parties, known as
counterparties. The value of this financial contract is based on
underlying obligations of a single entity or on a particular security
or other debt obligation, or an index of several such entities,
securities, or obligations. The obligation of a seller to make payment
under a CDS contract is triggered by a default or other credit event as
to such entity or entities or such security or securities. Investors
may use CDS for a variety of reasons, including to offset or insure
against risk in their fixed-income portfolios, to take synthetic
positions in bonds or in segments of the debt market as represented by
an index, or to capitalize on the volatility in credit spreads during
times of economic uncertainty. In recent years, CDS market volumes have
rapidly increased.\46\ This growth has coincided with a significant
rise in the types and
[[Page 3973]]
number of entities participating in the CDS market.\47\
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\46\ See Semiannual OTC derivatives statistics at end-December
2007, Bank for International Settlements (``BIS''), available at
https://www.bis.org/statistics/otcder/dt1920a.pdf.
\47\ CDSs were initially created to meet the demand of banking
institutions looking to hedge and diversify the credit risk
attendant with their lending activities. However, financial
institutions such as insurance companies, pension funds, securities
firms and hedge funds have entered the CDS market.
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In a CCP arrangement, both parties entering a CDS would novate
their trades to the CCP, and the CCP would stand in as the counterparty
to all parties of the CDS it clears. Through this novation process, the
counterparty risk of a CDS would be effectively concentrated in the
CCP.
A. Benefits
We are providing exemptive orders that will facilitate the
operation of CCPs for the CDS market. In connection with these actions,
we are adopting exemptions from certain provisions of the Securities
Act, the Exchange Act and the Trust Indenture Act, subject to certain
conditions described in the companion exemptive orders and in the
exemptions themselves. The conditions and representations in the
companion exemptive orders and exemptions require that information be
available about the terms of the CDS, the creditworthiness of the CCP
or any guarantor, and the clearing and settlement process for the CDS.
Additionally, the conditions require that financial information about
the reference entity, the issuer of the reference security, or the
reference security be publicly available. We believe that these interim
final temporary rules and the exemptions we are providing under the
Exchange Act, will facilitate the operation of CCPs while enabling us
to provide oversight to the non-excluded CDS market. We believe that
the operation of one or more CCPs in accordance with our exemptions
likely would improve the efficiency and effectiveness of the CDS
market, provide clearing participants with increased transparency of
exposures to particular reference entities or reference securities, and
increase available information about reference entities or reference
securities.
Absent an exemption, the offer and sale of eligible CDS that are or
will be issued or cleared by a Registered or Exempt CCP would have to
be registered under the Securities Act, the eligible CDS that are or
have been issued or cleared by a Registered or Exempt CCP would have to
be registered as a class under the Exchange Act, and the provisions of
the Trust Indenture Act would apply. We believe that the interim final
temporary rules exempting the registration of eligible CDS issued or
cleared by a Registered or Exempt CCP under certain conditions will
facilitate the use by eligible contract participants of CDS CCPs.
Without also exempting the offers and sales of eligible CDS issued or
cleared by a Registered or Exempt CCP from the registration
requirements of the Securities Act and the Exchange Act and the
provisions of the Trust Indenture Act, we believe that the CCPs would
not be able to operate in the manner contemplated by the exemptive
orders.
The interim final temporary exemptions also will treat eligible CDS
issued or cleared by a Registered or Exempt CCP under the Securities
Act and the Exchange Act in the same manner as certain other types of
derivative contracts, such as security futures products and
standardized options.\48\ A Registered or Exempt CCP issuing or
clearing eligible CDS will benefit from the temporary exemptions
because it will not have to file registration statements with us
covering the offer and sale of the eligible CDS. The registration form
most applicable to a CCP is a Form S-20, which is the form that is used
by options clearing houses that do not qualify for our exemption in
Securities Act Rule 238 \49\ from registering the offer and sale of
standardized options. If a CCP is not required to register the offer
and sale of eligible CDS (on Form S-20, for example), it would not have
to incur the costs of such registration, including legal and accounting
costs. Some of these costs, of course, such as the costs of obtaining
audited financial statements, may still be incurred as a result of the
operations of the entity as a CCP and the regulatory oversight of the
central counterparty operations. In addition, if any of the CCPs are
entities that are subject to the periodic reporting requirements of the
Exchange Act, the cost of filing a registration statement covering the
eligible CDS would be lessened further as the information regarding the
CCP already would be prepared. The availability of exemptions under the
Securities Act, the Exchange Act, and the Trust Indenture Act also
would mean that CCPs would not incur the costs of preparing disclosure
documents describing eligible CDS and from preparing indentures and
arranging for the services of a trustee.
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\48\ See, e.g., Securities Act Section 3(a)(14) [15 U.S.C.
77c(a)(14)], Securities Act Rule 238 [17 CFR 230.238]; Exchange Act
Section 12(a) [15 U.S.C. 78l], and Exchange Act Rule 12h-1(d) and
(e) [17 CFR 240.12h-1(d) and (e)].
\49\ 17 CFR 230.238.
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B. Costs
The interim final temporary rules exempting offers and sales of
eligible CDS that are or will be issued or cleared by a Registered or
Exempt CCP should facilitate the use by eligible contract participants
of CDS CCPs that are the subject of exemptive orders at minimal cost to
the CCP or investors. Because the interim final temporary rules are
self-executing, the costs of being able to rely on such exemptions, we
believe, are minimal.
Absent an exemption, a CCP may have to file a registration
statement covering the offer and sale of the eligible CDS, may have to
satisfy the applicable provisions of the Trust Indenture Act, and may
have to register the class of eligible CDS that it has issued or
cleared under the Exchange Act, which would provide investors with
civil remedies in addition to antifraud remedies. While a CCP
registration statement covering eligible CDS (or the offer and sale of
such eligible CDS) may provide certain information about the CCP, CDS
contract terms, and the identification of reference entities or
reference securities, it would not necessarily provide the type of
information necessary to assess the credit risk of the reference entity
or reference security. Further, while a CCP registration statement
would provide information to the CDS market participants, as well as to
the market as a whole, a condition of the clearing agency exemption in
the exemptive orders is that the CCPs make their audited financial
statements and other information about themselves publicly available.
We recognize that a consequence of the exemptions would be the
unavailability of certain remedies under the Securities Act and the
Exchange Act and certain protections under the Trust Indenture Act.
While an investor would be able to pursue an antifraud action in
connection with the purchase and sale of eligible CDS under Exchange
Act Section 10(b),\50\ it would not be able to pursue civil remedies
under Sections 11 or 12 of the Securities Act.\51\ We could still
pursue an antifraud action in the offer and sale of eligible CDS issued
or cleared by a CCP.\52\
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\50\ 15 U.S.C. 78j(b).
\51\ 15 U.S.C. 77k and 77l.
\52\ See 15 U.S.C. 77q and 15 U.S.C. 78j(b).
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[[Page 3974]]
VII. Consideration of Impact On the Economy, Burden On Competition and
Promotion of Efficiency, Competition and Capital Formation
Section 23(a)(2) of the Exchange Act \53\ requires us, when
adopting rules under the Exchange Act, to consider the impact that any
new rule would have on competition. Section 23(a)(2) prohibits us from
adopting any rule that would impose a burden on competition not
necessary or appropriate in furtherance of the purposes of the Exchange
Act. In addition, Section 2(b) \54\ of the Securities Act and Section
3(f) \55\ of the Exchange Act require us, when engaging in rulemaking
where we are required to consider or determine whether an action is
necessary or appropriate in the public interest, to also consider
whether the action will promote efficiency, competition, and capital
formation.
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\53\ 15 U.S.C. 78w(a)(2).
\54\ 15 U.S.C. 77b(b).
\55\ 15 U.S.C. 78c(f).
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We are adopting interim final temporary rules that would exempt
eligible CDS issued or cleared by a Registered or Exempt CCP from all
provisions of the Securities Act, other than the Section 17(a)
antifraud provision, as well as from the registration requirements
under Section 12 of the Exchange Act and the provisions of the Trust
Indenture Act. Because our interim final temporary exemptions will be
available to any Registered or Exempt CCP offering and selling eligible
CDS, we do not believe that our actions today will impose a burden on
competition. We also believe that the ability to settle CDS through
CCPs will improve the transparency of the CDS market and provide
greater assurance to participants as to the capacity of the eligible
CDS counterparty to perform its obligations under the eligible CDS. We
believe that increased transparency in the CDS market could help to
decrease further market turmoil and thereby facilitate the capital
formation process.
VIII. Regulatory Flexibility Act Certification
The Commission hereby certifies pursuant to 5 U.S.C. 605(b) that
the interim final temporary rules contained in this release will not
have a significant economic impact on a substantial number of small
entities. The interim final temporary rules exempt eligible CDS that
are or will be issued or cleared by a Registered or Exempt CCP. None of
the entities that are eligible to meet the requirements of the
exemption from registration under Section 17A is a small entity. For
this reason, the interim final temporary rules should not have a
significant economic impact on a substantial number of small entities.
IX. Statutory Authority and Text of the Rules and Amendments
The rules and amendments described in this release are being
adopted under the authority set forth in Sections 18, 19 and 28 of the
Securities Act; Sections 12(h), 23(a) and 36 of the Exchange Act; and
Section 304(d) of the Trust Indenture Act.
List of Subjects
17 CFR Parts 230, 240 and 260.
Reporting and recordkeeping requirements, Securities.
Text of the Rules and Amendments
0
For the reasons set out in the preamble, the Commission amends Title
17, Chapter II, of the Code of Federal Regulations as follows:
PART 230--GENERAL RULES AND REGULATIONS, SECURITIES ACT OF 1933
0
1. The authority citation for Part 230 continues to read, in part, as
follows:
Authority: 15 U.S.C. 77b, 77c, 77d, 77f, 77g, 77h, 77j, 77r,
77s, 77z-3, 77sss, 78c, 78d, 78j, 78l, 78m, 78n, 78o, 78t, 78w,
78ll(d), 78mm, 80a-8, 80a-24, 80a-28, 80a-29, 80a-30, and 80a-37,
unless otherwise noted.
* * * * *
0
2. Section 230.146 is amended by adding paragraph (c)T to read as
follows:
Sec. 230.146 Rules under section 18 of the Act.
* * * * *
(c)T Temporary definition of eligible contract participant as
qualified purchaser. For purposes of Section 18(b)(3) of the Act (15
U.S.C. 77r(b)(3)), the term ``qualified purchaser'' shall mean any
eligible contract participant (as defined in Section 1a(12) of the
Commodity Exchange Act (7 U.S.C. 1a(12)) as in effect on the date of
adoption of this section, other than a person who is an eligible
contract participant under Section 1(a)(12)(C) of the Commodity
Exchange Act) that has been sold an eligible credit default swap (as
defined in Rule 239T of this Act) in reliance on Rule 239T of this Act.
This temporary rule will expire on September 25, 2009.
0
3