Self-Regulatory Organizations; NASDAQ OMX PHLX, Inc.; Notice of Filing and Immediate Effectiveness of Proposed Rule Change To Allow Tied Hedge Transactions, 63162-63167 [E9-28740]
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63162
Federal Register / Vol. 74, No. 230 / Wednesday, December 2, 2009 / Notices
Regulatory Commission’s Web site,
https://www.prc.gov.
Neva R. Watson,
Attorney, Legislative.
[FR Doc. E9–28767 Filed 12–1–09; 8:45 am]
BILLING CODE 7710–12–P
SMALL BUSINESS ADMINISTRATION
[Disaster Declaration #11939 and #11940]
Virginia Disaster #VA–00026
AGENCY: U.S. Small Business
Administration.
ACTION: Notice.
SUMMARY: This is a notice of an
Administrative declaration of a disaster
for the Commonwealth of Virginia,
dated 11/25/2009.
Incident: Severe Nor’easter coupled
with the remnants of Hurricane Ida.
Incident Period: 11/12/2009 through
11/15/2009.
Effective Date: 11/25/2009.
Physical Loan Application Deadline
Date: 01/25/2010.
Economic Injury (EIDL) Loan
Application Deadline Date: 08/25/2010
ADDRESSES: Submit completed loan
applications to: U.S. Small Business
Administration, Processing and
Disbursement Center, 14925 Kingsport
Road, Fort Worth, TX 76155.
FOR FURTHER INFORMATION CONTACT: A.
Escobar, Office of Disaster Assistance,
U.S. Small Business Administration,
409 3rd Street, SW., Suite 6050,
Washington, DC 20416.
SUPPLEMENTARY INFORMATION: Notice is
hereby given that as a result of the
Administrator’s disaster declaration,
applications for disaster loans may be
filed at the address listed above or other
locally announced locations.
The following areas have been
determined to be adversely affected by
the disaster:
Primary Cities: Hampton City, Newport
News City, Norfolk City, Virginia
Beach City.
Contiguous Cities and Counties:
Virginia: Chesapeake City, James City,
Poquoson City, Portsmouth City,
York.
North Carolina: Currituck.
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The Interest Rates are:
Percent
For Physical Damage:
Homeowners With Credit
Available Elsewhere ..........
Homeowners Without Credit
Available Elsewhere ..........
Businesses With Credit Available Elsewhere ..................
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18:28 Dec 01, 2009
(Crossing, Facilitation and Solicited
Orders) to allow hedging stock, security
Businesses Without Credit
future or futures contract positions to be
Available Elsewhere ..........
4.000 represented concurrently with option
Non-Profit Organizations With
facilitations or solicitations in the
Credit Available Elsewhere
3.625 trading crowd (‘‘tied hedge’’ orders).
Non-Profit
Organizations
The Exchange proposes to adopt a
Without Credit Available
Elsewhere ..........................
3.000 similarly worded Commentary .02 to
Options Floor Procedure Advice
For Economic Injury:
(‘‘OFPA’’ or ‘‘Advice’’) B–11 (Crossing,
Businesses and Small Agricultural Cooperatives WithFacilitation and Solicited Orders) to
out Credit Available Elseharmonize it with Rule 1064. The
where .................................
4.000 Exchange also proposes to amend Rule
Non-Profit
Organizations
1066 (Certain Types of Orders Defined)
Without Credit Available
and Commentary .08 to Rule 1080 (Phlx
Elsewhere ..........................
3.000
XL and XL II) to clarify definitional
language in respect of tied hedge orders.
The number assigned to this disaster
The text of the proposed rule change
for physical damage is 119396 and for
is available on the Exchange’s Web site
economic injury is 119400.
at https://
The States which received an EIDL
nasdaqomxphlx.cchwallstreet.com/
Declaration # are Virginia, North
NASDAQOMXPHLX/Filings/, at the
Carolina.
principal office of the Exchange, and at
(Catalog of Federal Domestic Assistance
the Commission’s Public Reference
Numbers 59002 and 59008)
Room.
Percent
5.125
Dated: November 25, 2009.
Karen G. Mills,
Administrator.
[FR Doc. E9–28768 Filed 12–1–09; 8:45 am]
BILLING CODE 8025–01–P
SECURITIES AND EXCHANGE
COMMISSION
Release No. 34–61066; File No. SR–Phlx–
2009–98]
Self-Regulatory Organizations;
NASDAQ OMX PHLX, Inc.; Notice of
Filing and Immediate Effectiveness of
Proposed Rule Change To Allow Tied
Hedge Transactions
November 25, 2009.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (the
‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that, on
November 20, 2009, NASDAQ OMX
PHLX, Inc. (‘‘Phlx’’ or the ‘‘Exchange’’)
filed with the Securities and Exchange
Commission (the ‘‘Commission’’) the
proposed rule change as described in
Items I, II and III below, which Items
have been prepared by the Exchange.
The Commission is publishing this
notice to solicit comments on the
proposed rule change from interested
persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange is filing with the
Commission a proposal to adopt
Commentary .04 to Phlx Rule 1064
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II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
self-regulatory organization included
statements concerning the purpose of,
and basis for, the proposed rule change
and discussed any comments it received
on the proposed rule change. The text
of those statements may be examined at
the places specified in Item IV below.
The Exchange has prepared summaries,
set forth in sections A, B, and C below,
of the most significant parts of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The purpose of the proposal is to
adopt new Commentary .04 to Phlx Rule
1064 and new Commentary .02 to OFPA
B–11 to allow hedging stock, security
future or futures contract positions to be
represented currently with option
facilitations or solicitations in the
trading crowd (tied hedge orders); and
to clarify definitional language in
respect of tied hedge orders in Rules
1066 and 1080.
This rule change is based on a similar
recently approved rule change proposal
by another option exchange regarding
tied hedge orders.3
3 See Securities Exchange Act Release No. 60499
(August 13, 2009), 74 FR 42350 (August 21, 2009)
(SR–CBOE–2009–007) (notice of filing and order
granting accelerated approval regarding ‘‘tied
hedge’’ transactions). SR–CBOE–2009–007 was, in
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Background
By way of background, Rule 1064 and
OFPA B–11 4 generally deal with,
among other things: (a) When an
Options Floor Broker (‘‘Floor Broker’’)
who holds orders to buy and sell the
same options series may cross such
orders; 5 (b) when a Floor Broker
holding an options order for a public
customer and a contra-side order may
cross such orders; 6 and (c) when a
solicitation occurs where an order, other
than a cross, is presented by a Floor
Broker for execution in the trading
crowd.7 Rule 1064 also deals with firm
participation guarantees entitling a
Floor Broker to cross certain percentages
of the original order with other orders
that the Floor Broker is holding, or in
the case of a public customer order,
with facilitation orders of the original
firm (i.e. the firm from which the
original customer order originated).8
Additionally, Rule 1064 and OFPA B–
11 indicate that a non member
organization or person associated with a
member or member organization who
has knowledge of all the material terms
of an order being facilitated, or an order
being crossed, the execution of which is
imminent, shall not enter (based on
such knowledge) an order to: (a) Buy or
sell an option for the same underlying
security, (b) buy or sell a security
underlying such class, or (c) buy or sell
a related instrument (known as the
‘‘anticipatory hedge rule’’).9
The Exchange notes that Rule 1064
and OFPA B–11 were designed to
preserve the right to solicit orders in
advance of submitting a proposal to the
turn, based on a previous Phlx rule change
proposal, SR–PHLX–2003–75, that was ultimately
not pursued to approval. See Securities Exchange
Act Release No. 48875 (December 4, 2003), 68 FR
70072 (December 16, 2003) (SR–Phlx-2003–75)
(notice of filing).
4 OFPA B–11 is similar in structure and content
to Rule 1064 (with the exception that Commentaries
.02 and .03 to Rule 1064 are not in OFPA B–11).
A sentence regarding priority is added to subsection
(c)(iii) of Rule 1064 for conformity with OFPA B–
11.
5 Rule 1064(a).
6 Rule 1064(b).
7 Rule 1064(c).
8 Commentary .02 to Rule 1064. For purposes of
this commentary, an ‘‘original order’’ is when a
Floor Broker holds an equity, index or U.S. dollarsettled foreign currency option order of the eligible
order size or greater. Commentary .02 provides
further that spread, straddle, combination or hedge
orders, as defined in Exchange Rule 1066, on
opposite sides of the market may be crossed,
provided that the Floor Broker holding such orders
proceeds in the manner described in Rule 1064.
9 Rule 1064(d). For purposes of this subsection
(d), an order to buy or sell a ‘‘related instrument’’
means, ‘‘in reference to an index option, an order
to buy or sell securities comprising 10% or more
of the component securities in the index or an order
to buy or sell a futures contract on an economically
equivalent index.’’
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trading crowd, while at the same time
assuring that orders that are the subject
of solicitation are exposed to the auction
market (trading crowd) in a meaningful
way by prohibiting behavior such as
anticipatory hedging.
Rule 1064 and OFPA B–11 provide
that a violation of the rule or Advice,
respectively, may be considered
inconsistent with just and equitable
principles of trade.10
When Phlx originally adopted the
anticipatory hedge rule in 2001, the
Exchange believed that the prohibition
on anticipatory hedging was necessary
to prevent members and associated
persons from using undisclosed nonpublic information about imminent
solicited option transactions to trade the
relevant option or any closely-related
instrument in advance of persons
represented in the relevant options
crowd.11 While the Exchange has
continued to believe that this basic
principle remains true, changes in the
marketplace have caused the Exchange
to re-evaluate the effectiveness and
efficiency of the Exchange’s anticipatory
hedge rule requirements.
The Exchange believes that increased
volatility in the markets, as well as the
advent of penny trading in underlying
stocks and resultant decreased liquidity
at the top of each underlying market’s
displayed NBBO, it has become
increasingly difficult for members and
member organizations to assess ultimate
execution prices and the extent of
available stock to hedge related options
facilitation/solicitation activities, and to
manage that market risk. This risk
extends to simple and complex orders,12
and to all market participants involved
in the transaction (whether upstairs or
on-floor) because of the uncertainty of
the extent to which the market
participant will participate in the
transaction, the amount of time
associated with the auction process, and
the likelihood that the underlying stock
prices in today’s environment may be
difficult to assess and may change
before they are able to hedge. These
circumstances can make it difficult to
obtain a hedge, difficult to quote orders,
10 Commentary .01 to Rule 1064 and OFPA B–11.
The language of Commentary .01 to OFPA B–11 is
clarified to indicate that a violation of the Advice
may be considered conduct inconsistent with just
and equitable principles of trade.
11 See Securities Exchange Act Release No. 44740
(August 23, 2001), 66 FR 45721 (August 29, 2001)
(SR–Phlx–2001–61) (notice of filing and immediate
effectiveness regarding, among other things,
anticipatory hedge rule in Rule 1064 and OFPA B–
11).
12 Subsection (a)(i)(F) to Commentary .08 is
clarified to indicate that Complex Orders include
‘‘tied hedge’’ orders. Rule 1066 is similarly clarified
to indicate that hedge orders include ‘‘tied hedge’’
orders.
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and difficult to achieve executions; and
can translate into less liquidity in the
form of smaller size and wider quote
spreads, fewer opportunities for price
improvement, and the inefficient
handling of orders.
Additionally, more and more trading
activity appears to be taking place away
from the exchange-listed environment
and in the over-the-counter (‘‘OTC’’)
market, which by its nature is not
subject to the same trade-through type
risks present in the exchange
environment. Therefore, the Exchange is
seeking to make its trading rules more
efficient not only to address the market
risk and execution concerns, but also to
effectively compete with and attract
volume from the OTC market. What is
more, trading strategies of marketmakers, which include Registered
Options Traders (‘‘ROTs’’) and
specialists on the Exchange, have
evolved.13 Whereas market-makers
previously tended to trade based on
delta risk,14 now market-making
strategy tends to be based more on
volatility.15 The tied hedge transaction
procedures (described below) are
designed in a way that is consistent
with this shift toward a volatility
trading strategy, and makes it more
desirable for market-makers to compete
for orders that are exposed through the
solicitation process.
Proposed Exception to Anticipatory
Hedge Rule
In order to address the concerns
associated with increased volatility and
decreased liquidity and more effectively
compete with the OTC market, the
13 For obligations and restrictions generally
applicable to ROTs and specialists, see Rule 1014.
14 The price of an option is not completely
dependent on supply and demand, nor on the price
of the underlying security. Market-makers price
options based on fundamental measures of risk as
well. One of these measures, delta, is the rate of
change in the price of an option as it relates to
changes in the price of the underlying security,
security future or futures contract. The delta of an
option is measured incrementally based on
movement in the price of the underlying security,
security future or futures contract. For example, if
the price of an option increases or decreases by
$1.00 for each $1.00 increase or decrease in the
price of the underlying security, the option would
have a delta of 100. If the price of an option
increases or decreases by $0.50 for each $1.00
increase or decrease in the price of the underlying
security, the option would have a delta of 50.
15 Volatility is a measure of the fluctuation in the
underlying security’s market price. Market-makers
that trade based on volatility generally have options
positions that they hedge with the underlying. Once
hedged, the risk exposure to the market-maker is
realized volatility and implied volatility. Realized
volatility (also known as historical volatility) is the
actual volatility in the underlying. Implied
volatility is determined by using option prices
existing in the market at the time rather than using
historical data on the market price changes of the
underlying.
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Exchange is proposing to adopt in
Commentary .04 to Rule 1064 and
Commentary .02 to OFPA B–11 a
limited exception to the anticipatory
hedging restrictions that would permit
the representation of hedging stock
positions in conjunction with option
orders in the options trading crowd (a
‘‘tied hedge’’ transaction). The Exchange
believes this limited exception remains
in keeping with the original design of
Rule 1064(d), but sets forth a more
practicable approach considering
today’s trading environment that will
provide the ability to hedge in a way
that will still encourage meaningful
competition among upstairs and floor
traders. Besides stock positions, the
proposal would also permit security
futures positions to be used as a hedge.
In addition, in the case where the order
is for options on indices, options on
exchange-traded funds (‘‘ETFs’’) or
options on Holding Company
Depository Receipts (‘‘HOLDRS’’), a
related instrument may be used as a
hedge. A ‘‘related instrument’’ would
mean, in reference to an index option,
securities comprising ten percent or
more of the component securities in the
index or a futures contract on any
economically equivalent index
applicable to the option order. A
‘‘related instrument’’ would mean, in
reference to an ETF or HOLDR option,
a futures contract on any economically
equivalent index applicable to the ETF
or HOLDR underlying the option
order.16
With a tied hedge transaction,
Exchange members would be permitted
to hedge an option order with the
underlying security, a security future or
futures contract, as applicable, and then
forward the option order and the
hedging position to an Exchange Floor
Broker with instructions to represent the
option order together with the hedging
position to the options trading crowd.
The in-crowd market participants that
chose to participate in the option
transaction must also participate in the
hedging position.
First, under the proposal, the original
option order must be in a class
designated as eligible for a tied hedge
transaction as determined by the
Exchange, including FLEX options
classes.17 The original option order
16 For example, a tied hedge order involving
options on the iShares Russell 2000 Index ETF
(IWM) might involve a hedge position in the
underlying ETF, security futures overlying the ETF,
or futures contracts overlying the Russell 2000
Index.
17 FLEX options provide investors with the ability
to customize basic option features including size,
expiration date, exercise style, and certain exercise
prices. See Rule 1079.
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must also be within designated tied
hedge eligibility size parameters, which
would be determined by the Exchange
and would not be smaller than 500
contracts.18 The Exchange notes that the
minimum order size would apply to an
individual original order.19 Multiple
original orders could not be aggregated
to satisfy the requirement (though
multiple contra-side solicited orders
could be aggregated to execute against
the original order). The Exchange states
that the primary purpose of this
provision is to limit use of the tied
hedge procedures to larger orders that
might benefit from a member’s or
member organization’s ability to execute
a facilitating hedge.20 Assuming an
option order meets these eligibility
parameters, the proposal also includes a
number of other conditions that must be
satisfied.
Second, the proposal would also
require that, prior to entering tied hedge
orders on behalf of customers, the
member or member organization must
deliver to the customer a onetime
written notification informing the
customer that his order may be executed
using the Exchange’s tied hedge
procedures. Under the proposal, the
written notification must disclose the
terms and conditions contained in the
proposed rule and be in a form
approved by the Exchange. Given the
minimum size requirement of 500
contracts per order, the Exchange
believes that use of the tied hedges
procedures will generally consist of
orders for the accounts of institutional
or sophisticated, high net worth
investors. The Exchange therefore
believes that a one-time notification
delivered by the member or member
organization to the customer would be
sufficient, and that an order-by-order
18 The designated classes and minimum order
size applicable to each class would be
communicated to the membership via an Options
Regulatory Alert (‘‘ORA’’). For example, the
Exchange could determine to make the tied hedge
transaction procedures available in options class
XYZ for orders of 1000 contracts or more. Such a
determination would be announced via ORA,
which would include a cumulative list of all classes
and corresponding sizes for which the tied hedge
procedures are available.
19 In determining whether an individual original
order satisfies the eligible order size requirement,
any complex order must contain one leg alone
which is for the eligible order size or greater. For
complex order procedures generally, see
Commentary .08 to Rule 1080 and Rule 1089(b)(2).
For complex order procedures in respect of locked
and crossed markets, see Rule 1083(d).
20 The Exchange believes that, given the
decreased amount of liquidity available at the
NBBO, the frequency with which quotes may
flicker, and differing costs associated with accessing
liquidity on various markets, as well as for ease of
administration, the proposed 500 contract
minimum should be sufficient to address these
considerations.
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notification would be unnecessary and
overly burdensome.
Third, a member or member
organization would be required to create
an electronic record that it is engaging
in a tied hedge order in a form and
manner prescribed by the Exchange.
The Exchange states that the purpose of
this provision is to create a record to
ensure that hedging trades would be
appropriately associated with the
related options order and appropriately
evaluated in the Exchange’s surveillance
program. The Exchange believes that
this requirement should enable the
Exchange to monitor for compliance
with the requirements of the proposed
rule, as discussed below, by identifying
the specific purchase or sell orders
relating to the hedging position.
Fourth, the proposed rule would
require that members and member
organizations that have decided to
engage in tied hedge orders for
representation in the trading crowd
would have to ensure that the hedging
position associated with the tied hedge
order is comprised of a position that is
designated as eligible for a tied hedge
transaction. Eligible hedging positions
would be determined by the Exchange
for each eligible class and may include
(a) The same underlying stock
applicable to the option order, (b) a
security future overlying the same stock
applicable to the option order, or (c) in
reference to an option on an index, ETF
or HOLDR, a ‘‘related instrument’’ (as
described above). For example, for
options overlying XYZ stock, the
Exchange may determine to designate
the underlying XYZ stock or XYZ
security futures or both as eligible
hedging positions.21 The Exchange
states that the purpose of this provision
is to ensure that the hedging position
would be for the same stock, equivalent
security future or related instrument, as
applicable, thus allowing crowd
participants who may be considering
participation in a tied hedge order to
adequately evaluate the risk associated
with the option as it relates to the
hedge. With stock positions in
particular, the Exchange notes that
occasionally crowd participants hedge
option positions with stock that is
related to the option, such as the stock
of an issuer in the same industry, but
not the actual stock associated with the
option. Except as otherwise discussed
above for index options, the proposed
21 As with designated classes and minimum order
size, the eligible hedging positions applicable to
each class would be communicated to the
membership via ORA, which would include a
cumulative list of all classes and corresponding
sizes for which the tied hedge procedures are
available. See note 19, supra.
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rule change would not allow such a
‘‘related’’ hedging stock position, but
would require the hedging stock
position to be the actual security
underlying the option.
Fifth, the proposal would require that
the entire hedging position be brought
without undue delay to the trading
crowd. In considering whether the
hedging position is presented without
‘‘undue delay,’’ the Exchange believes
that members and member organizations
should continue to have the same ability
to shop an order in advance of
presenting it to the crowd and should be
able to enhance that process through
obtaining a hedge. The Exchange also
believes that, once a hedge is obtained,
the order should be brought to the
crowd promptly in order to satisfy the
‘‘undue delay’’ requirement. In addition,
the proposal would require that the
hedging position be announced to the
trading crowd concurrently with the
option order, offered to the crowd in its
entirety, and offered at the execution
price received by the member or
member organization introducing the
order to any in-crowd market
participant who has established parity
or priority for the related options. Incrowd market participants that
participate in the option transaction
must also participate in the hedging
position on a proportionate basis 22 and
would not be permitted to prevent the
option transaction from occurring by
giving a competing bid or offer for one
component of the tied hedge order. The
Exchange states that the purpose of
these requirements is to ensure that the
hedging position represented to the
crowd would be a good faith effort to
provide in-crowd market participants
with the same opportunity as the
member or member organization
introducing the tied hedge order to
compete most effectively for the option
order.
For example, if a member or member
organization introducing a tied stock
hedge order were to offer 1,000 XYZ
option contracts to the crowd (overlying
100,000 shares of XYZ stock) and
concurrently offer only 30,000 of
100,000 shares of the underlying stock
that the member obtained as a hedge,
crowd participants might only be
willing or able to participate in 300 of
the option contracts offered if the
hedging stock position cannot be
obtained at a price as favorable as the
stock hedging position offering price, if
22 For example, if an in-crowd market
participant’s allocation is 100 contracts out of a 500
contract option order (1⁄5), the same in-crowd
market participant would trade 10,000 shares of a
50,000 stock hedge position tied to that option
order (1⁄5).
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at all. The Exchange states that the effect
of this would be to place the crowd at
a disadvantage relative to the
introducing member or member
organization for the remaining 700
option contracts in the tied stock hedge
order, and thus create a disincentive for
the crowd to bid or offer competitively
for the remaining 700 option contracts.
The Exchange believes the requirement
that the hedging position be presented
concurrently with the option order in
the crowd and offered to the crowd in
its entirety at the execution price
received by the member or member
organization introducing the order
should ensure that the crowd would be
competing on a level playing field with
the introducing member or member
organization to provide the best price to
the customer.
Sixth, the proposal would require that
the hedging position not exceed the
options order on a delta basis. For
example, in the situation where a tied
stock hedge order involves the
simultaneous purchase of 50,000 shares
of XYZ stock and the sale of 500 XYZ
call contract (known as a ‘‘buy-write’’),
and the delta of the option is 100, it
would be considered ‘‘hedged’’ by
50,000 shares of stock. Accordingly, the
proposed rule would not allow the
introducing member firm to purchase
more than 50,000 shares of stock in the
hedging stock position. The Exchange
believes that it is reasonable to require
that the hedging position be in amounts
that do not exceed the equivalent size of
the related options order on a delta
basis, and not for a greater number of
shares. The Exchange believes that the
proposed rule change would support its
view that the member or member
organization introducing the tied hedge
order be guided by the notion that any
excess hedging activity could be
detrimental to the eventual execution
price of the option order. Consequently,
while delta estimates may vary slightly,
the introducing member or member
organization would be required to
assume hedging positions not to exceed
the equivalent size of the options order
on a delta basis.23
23 The Exchange notes that there may be scenarios
where the introducing member purchases (sells)
less than the delta, e.g., when there is not enough
stock available to buy (sell) at the desired price. In
such scenarios, the introducing member would
present the stock that was purchased (sold) and
share it with the in-crowd market participants on
equal terms. This risk of obtaining less than a delta
hedge is a risk that exists under the current rules
because of the uncertainty that exists when market
participants price an option and have to anticipate
the price at which they will be able to obtain a
hedge. The proposed tied hedge procedures are
designed to help reduce this risk, but the initiating
member may still be unable to execute enough stock
at the desired price. To the extent the initiating
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63165
The Exchange believes that the delta
basis requirement, together with the
additional conditions that an
introducing member or member
organization bring the hedging position
without undue delay to the trading
crowd and announce it concurrently
with the option order, offer it to the
crowd in its entirety, and offer it at the
execution price received by the member
or member organization to any in-crowd
market participant who has established
parity or priority, will help assure that
the hedging activity is bona fide and not
for speculative or manipulative
purposes. Additionally, the Exchange
believes these conditions will help
assure that there is no adverse affect on
the auction market because, as
discussed above, in-crowd market
participants will have the same
opportunity as the member or member
organization introducing the tied hedge
order to compete for the option order
and will share the same benefits of
limiting the market risk associated with
hedging. The Exchange believes that
customers will also benefit if the market
risks are limited in the manner
proposed. Once an original order is
hedged, there is no delta risk. With the
delta risk minimized, quotes will likely
narrow as market participants (whether
upstairs or on-floor) are better able to
hedge and compete for orders. For
example, market-makers could more
easily quote markets to trade against a
customer’s original order based on
volatility with the delta risk minimized,
which should ultimately present more
price improvement opportunities to the
original order.24
At this time, the Exchange is not
proposing any special priority
provisions applicable to tied hedge
transactions, though it intends to
evaluate whether such changes are
desired and may submit a separate rule
filing on this subject in the future.
Under the instant proposal, all tied
hedge transactions will be treated as
member is able to execute any portion of the hedge,
the risk exposure to the initiating member and incrowd market participants would be diminished
because those shares would be ‘‘tied up’’ and
available for everyone that participates on the
resulting tied hedge transaction. The Exchange does
not believe that the initiating member would have
an unfair advantage by having the ability to prefacilitate less than a delta hedge because the
proposed procedures would require the in-crowd
market participants to get a proportional share of
the hedge. To the extent more stock is needed to
complete a hedge, the initiating member and the incrowd market participants would have the same
risk exposure that they do today.
24 The Exchange also believes that the proposed
exception to the anticipatory hedging procedures
will assist in the Exchange’s competitive efforts to
attract order flow from the OTC market, which may
result in increased volume on the exchange
markets.
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mstockstill on DSKH9S0YB1PROD with NOTICES
complex orders. Priority will be
afforded in accordance with the
Exchange’s existing open outcry
allocation and reporting procedures for
complex orders.25 Any resulting tied
hedge transactions will also be subject
to the existing NBBO trade-through
requirements for options and stock, as
applicable. In this regard, the Exchange
believes that the resulting option and
stock components of the tied hedge
transactions may qualify for various
NBBO trade through exceptions
including, for example, the complex
trade exception.26 However, when the
option order is a simple order the
execution of the option leg of a tied
hedge transaction does not qualify it for
any NBBO trade-through exception for a
Complex Trade. Recognizing that tied
hedge transactions involve complex
orders and trades, the Exchange is
amending the definition of Complex
Order to clarify that these include ‘‘tied
hedge’’ transactions.27
The Exchange recognizes that, at the
time a tied hedge transaction is
executed in a trading crowd, market
conditions in any of the non-Phlx
market(s) may prevent the execution of
the non-options leg(s) at the price(s)
agreed upon. For example, the
execution price may be outside the nonPhlx market’s best bid or offer (‘‘BBO’’),
such as where the stock leg is to be
executed at a price of $25.03 and the
particular stock market’s BBO is $24.93–
$25.02; such an execution would
normally not be permitted unless an
25 For reporting procedures, see, Rules 1053
(Filing of Trade Information), 1003 (Reporting of
Options Positions), 1022 (Securities Accounts and
Orders of Specialists and Registered Options
Traders), and 1028 (Confirmations). For allocation
procedures, see, Rules 1014 (Obligations and
Restrictions Applicable to Specialists and
Registered Options Traders) and 1080 (Phlx XL and
XL II). Options trading rules are generally located
in the 1000 series of rules known as the Options
Rules (Rule 1000 et. seq.) and include Rules 1001
(Position Limits), 1002 (Exercise Limits), 1033 (Bid
and Offers—Premium), 1034 (Minimum
Increments), and 1035 (Acceptance of Bid or Offer).
26 See Rule 1085(b)(6) (Order Protection). Rules
1083 (Intermarket Linkage) through 1087
(Limitation on Principal Order Access) implement
the recently-approved joint Options Order
Protection and Locked/Crossed Market Plan (the
‘‘Protection and Locked/Crossed Plan’’). See
Securities Exchange Act Release No. 60405 (July 30,
2009), 74 FR 39362 (August 6, 2009)(File No. 4–
546)(approval order for the Protection and Locked/
Crossed Plan). See also Securities Exchange Act
Release No. 60550 (August 20, 2009), 74 FR 44430
(August 28, 2009)(SR–Phlx-2009–61)(approval
order for Phlx rules implementing the Protection
and Locked/Crossed Plan).
27 See Commentary .08(a)(i)(F) to Rule 1080. The
Exchange notes that a complex order for ‘‘tied
hedge’’purposes in Rule 1080 is distinct from a
complex trade for linkage purposes in Rule 1083;
and that intramarket priority on the Exchange for
tied hedge purposes is distinct from intermarket
priority for linkage purposes.
VerDate Nov<24>2008
18:28 Dec 01, 2009
Jkt 220001
exception applies that permits the trade
to be reported outside the BBO.28 The
Exchange clarified in proposed
Commentary .04 to Rule 1064 and
Commentary.02 to OFPA B–11 that in
the event the conditions in the non-Phlx
market continue to prevent the
execution of the non-option leg(s) at the
agreed price(s), the trade representing
the options leg(s) of the tied hedge
transaction may be cancelled at the
request of any member that is a party to
the tied hedge transaction.
The following examples illustrate
these principles:
• Simple Original Order: Introducing
member receives an original customer
order to buy 500 XYZ call options,
which has a delta of 100. The
introducing member purchases 50,000
shares of XYZ stock on the NYSE for an
average price of $25.03 per share. Once
the stock is executed on the NYSE, the
introducing member, without undue
delay, announces the 500 contract
option order and 50,000 share tied stock
hedge at $25.03 per share to the
appropriate Phlx trading crowd.
• Complex Original Order:
Introducing member receives an original
customer stock-option order to buy 500
XYZ call options and sell 50,000 shares
of XYZ stock. The introducing member
purchases 50,000 shares of XYZ stock
on the NYSE for an average price of
$25.03 per share. Once the stock is
executed on the NYSE, the introducing
member, without undue delay,
announces the 500 contract option order
and 50,000 share tied stock hedge at
$25.03 per share to the appropriate
trading crowd.
In either the scenario regarding
simple orders or the scenario regarding
complex orders (which includes ‘‘tied
hedge’’ orders), the next steps are the
same and generally are no different from
the procedures currently used to
execute a complex order on Phlx in
open outcry.
The Exchange notes regarding the
examples above that:
• The in-crowd market participants
would have an opportunity to provide
competing quotes for the tied hedge
package (and not for the individual
component legs of the package). For
example, assume the best net price is
$24.53 (equal to $0.50 for each option
contract and $25.03 for each
corresponding share of hedging stock).
• The option order and hedging stock
would be allocated among the in-crowd
market participants that established
28 The Exchange notes that the possibility of this
scenario occurring exists with complex order
executions today and tied hedge transactions would
present nothing unique or novel in this regard.
PO 00000
Frm 00051
Fmt 4703
Sfmt 4703
priority or parity at that price, including
the initiating member, in accordance
with the allocation algorithm applicable
to the options class, with the options leg
being executed and reported on Phlx
and the stock leg being executed and
reported on the stock market specified
by the initiating member. For example,
the introducing member might trade
40% pursuant to an open outcry
crossing entitlement (200 options
contracts and 20,000 shares of stock)
and the remaining balance might be
with three different market-makers that
each participated on 20% of the order
(100 options contracts and 10,000 shares
of stock per market-maker).
• The resultant tied hedge
transaction: (a) would qualify as a
‘‘complex trade’’ under the Options
Intermarket Linkage and the execution
of the 500 option contracts with the
market participants would not be
subject to the NBBO for the particular
option series in the scenario where the
original order is a complex order (not a
simple order); and (b) would qualify as
a ‘‘qualified contingent trade’’ under
Regulation NMS and the execution of
the 30,000 shares of stock (the original
50,000 shares less the initiating
member’s 20,000 portion) with the
market participants would not be
subject to the NBBO for the underlying
XYZ stock.
• The execution of the options leg
would have to satisfy Phlx’s intramarket priority rules for complex orders
(including that the execution price may
not be outside the Phlx BBO (‘‘PBBO’’)).
Thus, if the PBBO for the series was
$0.40 $0.55, the execution could take
place at or inside that price range (e.g.,
at the quoted price of $0.50) and could
not take place outside that price range
(e.g., not at $0.56).
• Similarly, the execution of the stock
at $25.03 per share would have to
satisfy the intra-market priority rules of
the non-Phlx market(s) where the stock
is to be executed (including that the
execution price may not be outside that
market’s BBO) or, alternatively, qualify
for an exception that permits the trade
to be reported outside the non-Phlx
market(s) BBO.
• If market conditions in the nonPhlx market(s) prevent the execution of
the stock leg(s) at the price(s) agreed
upon from occurring (e.g., the BBO
remains at $24.93–$25.02), then the
options leg(s) could be cancelled at the
request of any member that is a party to
that trade.
While the particular circumstances
surrounding each transaction on the
Exchange’s trading floor are different,
the Exchange does not believe, as a
general proposition, that the tied hedge
E:\FR\FM\02DEN1.SGM
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Federal Register / Vol. 74, No. 230 / Wednesday, December 2, 2009 / Notices
procedures would be inherently harmful
or detrimental to customers or have an
adverse affect on the auction market.
Rather, the Exchange believes the
procedures will improve the
opportunities for an order to be exposed
to a competitive auction and represent
an improvement over the current rules.
The fact that the parties to such a trade
end up fully hedged may contribute to
the best execution of the orders,29 and,
in any event, participants continue to be
governed by, among other things, their
best execution responsibilities. The
Exchange also believes that the
proposed tied hedge procedures are
fully consistent with the original design
of Rule 1064(d) which, as discussed
above, was to eliminate the unfairness
that can be associated with a solicited
transaction and encourage meaningful
competition. The tied hedge procedures
should enable in-crowd market
participants to be on equal footing with
solicited parties in a manner that
minimizes all parties’ market risk while
continuing to assure that orders are
exposed in a meaningful way.
2. Statutory Basis
The Exchange believes that its
proposal is consistent with Section 6(b)
of the Act 30 in general, and furthers the
objectives of Section 6(b)(5) of the Act 31
in particular, in that it is designed to
promote just and equitable principles of
trade, to remove impediments to and
perfect the mechanism of a free and
open market and a national market
system, and, in general to protect
investors and the public interest, by
establishing rules governing tied hedge
orders, which include specific
requirements and procedures to be
followed. Specifically, the Exchange
believes the procedures will improve
the opportunities for orders to be
exposed to price improvement in a
manner that will encourage a fair,
competitive auction process and
minimize all parties’ market risk.
mstockstill on DSKH9S0YB1PROD with NOTICES
B. Self-Regulatory Organization’s
Statement on Burden on Competition
The Exchange does not believe that
the proposed rule change will impose
any burden on competition not
necessary or appropriate in furtherance
of the purposes of the Act.
29 As market participants are better able to hedge
risk associated with completing these transactions,
the Exchange believes that quotes may narrow and
result in increased price improvement
opportunities.
30 15 U.S.C. 78f(b).
31 15 U.S.C. 78f(b)(5).
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18:28 Dec 01, 2009
Jkt 220001
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
No written comments were either
solicited or received.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
Because the foregoing rule does not (i)
Significantly affect the protection of
investors or the public interest; (ii)
impose any significant burden on
competition; and (iii) become operative
for 30 days from the date on which it
was filed, or such shorter time as the
Commission may designate if consistent
with the protection of investors and the
public interest, provided that the selfregulatory organization has given the
Commission written notice of its intent
to file the proposed rule change at least
five business days prior to the date of
filing of the proposed rule change or
such shorter time as designated by the
Commission,32 the proposed rule
change has become effective pursuant to
Section 19(b)(3)(A) of the Act 33 and
Rule 19b–4(f)(6) thereunder.34
At any time within 60 days of the
filing of such proposed rule change, the
Commission may summarily abrogate
such rule change if it appears to the
Commission that such action is
necessary or appropriate in the public
interest, for the protection of investors,
or otherwise in furtherance of the
purposes of the Act.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an e-mail to rulecomments@sec.gov. Please include File
Number SR–Phlx–2009–98 on the
subject line.
Paper Comments
• Send paper comments in triplicate
to Elizabeth M. Murphy, Secretary,
Securities and Exchange Commission,
100 F Street, NE., Washington, DC
20549–1090.
32 The
Exchange has satisfied this requirement.
U.S.C. 78s(b)(3)(A).
34 17 CFR 240.19b–4(f)(6).
All submissions should refer to File
Number SR–Phlx–2009–98. This file
number should be included on the
subject line if e-mail is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for inspection and copying in
the Commission’s Public Reference
Room, 100 F Street, NE., Washington,
DC 20549, on official business days
between the hours of 10 a.m. and 3 p.m.
Copies of such filing also will be
available for inspection and copying at
the principal office of the Exchange. All
comments received will be posted
without change; the Commission does
not edit personal identifying
information from submissions. You
should submit only information that
you wish to make available publicly. All
submissions should refer to File
Number SR–Phlx–2009–98 and should
be submitted on or before December 23,
2009.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.35
Elizabeth M. Murphy,
Secretary.
[FR Doc. E9–28740 Filed 12–1–09; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–61060 File No. SR–FINRA–
2009–072]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Notice of Filing of
Proposed Rule Change To Amend the
Deficient Claims Rules of the Codes of
Arbitration Procedure for Customer
and Industry Disputes
November 24, 2009.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
33 15
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35 17
E:\FR\FM\02DEN1.SGM
CFR 200.30–3(a)(12).
02DEN1
Agencies
[Federal Register Volume 74, Number 230 (Wednesday, December 2, 2009)]
[Notices]
[Pages 63162-63167]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-28740]
=======================================================================
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SECURITIES AND EXCHANGE COMMISSION
Release No. 34-61066; File No. SR-Phlx-2009-98]
Self-Regulatory Organizations; NASDAQ OMX PHLX, Inc.; Notice of
Filing and Immediate Effectiveness of Proposed Rule Change To Allow
Tied Hedge Transactions
November 25, 2009.
Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
(the ``Act'') \1\ and Rule 19b-4 thereunder,\2\ notice is hereby given
that, on November 20, 2009, NASDAQ OMX PHLX, Inc. (``Phlx'' or the
``Exchange'') filed with the Securities and Exchange Commission (the
``Commission'') the proposed rule change as described in Items I, II
and III below, which Items have been prepared by the Exchange. The
Commission is publishing this notice to solicit comments on the
proposed rule change from interested persons.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
---------------------------------------------------------------------------
I. Self-Regulatory Organization's Statement of the Terms of Substance
of the Proposed Rule Change
The Exchange is filing with the Commission a proposal to adopt
Commentary .04 to Phlx Rule 1064 (Crossing, Facilitation and Solicited
Orders) to allow hedging stock, security future or futures contract
positions to be represented concurrently with option facilitations or
solicitations in the trading crowd (``tied hedge'' orders). The
Exchange proposes to adopt a similarly worded Commentary .02 to Options
Floor Procedure Advice (``OFPA'' or ``Advice'') B-11 (Crossing,
Facilitation and Solicited Orders) to harmonize it with Rule 1064. The
Exchange also proposes to amend Rule 1066 (Certain Types of Orders
Defined) and Commentary .08 to Rule 1080 (Phlx XL and XL II) to clarify
definitional language in respect of tied hedge orders.
The text of the proposed rule change is available on the Exchange's
Web site at https://nasdaqomxphlx.cchwallstreet.com/NASDAQOMXPHLX/Filings/, at the principal office of the Exchange, and at the
Commission's Public Reference Room.
II. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
In its filing with the Commission, the self-regulatory organization
included statements concerning the purpose of, and basis for, the
proposed rule change and discussed any comments it received on the
proposed rule change. The text of those statements may be examined at
the places specified in Item IV below. The Exchange has prepared
summaries, set forth in sections A, B, and C below, of the most
significant parts of such statements.
A. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
1. Purpose
The purpose of the proposal is to adopt new Commentary .04 to Phlx
Rule 1064 and new Commentary .02 to OFPA B-11 to allow hedging stock,
security future or futures contract positions to be represented
currently with option facilitations or solicitations in the trading
crowd (tied hedge orders); and to clarify definitional language in
respect of tied hedge orders in Rules 1066 and 1080.
This rule change is based on a similar recently approved rule
change proposal by another option exchange regarding tied hedge
orders.\3\
---------------------------------------------------------------------------
\3\ See Securities Exchange Act Release No. 60499 (August 13,
2009), 74 FR 42350 (August 21, 2009) (SR-CBOE-2009-007) (notice of
filing and order granting accelerated approval regarding ``tied
hedge'' transactions). SR-CBOE-2009-007 was, in turn, based on a
previous Phlx rule change proposal, SR-PHLX-2003-75, that was
ultimately not pursued to approval. See Securities Exchange Act
Release No. 48875 (December 4, 2003), 68 FR 70072 (December 16,
2003) (SR-Phlx-2003-75) (notice of filing).
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[[Page 63163]]
Background
By way of background, Rule 1064 and OFPA B-11 \4\ generally deal
with, among other things: (a) When an Options Floor Broker (``Floor
Broker'') who holds orders to buy and sell the same options series may
cross such orders; \5\ (b) when a Floor Broker holding an options order
for a public customer and a contra-side order may cross such orders;
\6\ and (c) when a solicitation occurs where an order, other than a
cross, is presented by a Floor Broker for execution in the trading
crowd.\7\ Rule 1064 also deals with firm participation guarantees
entitling a Floor Broker to cross certain percentages of the original
order with other orders that the Floor Broker is holding, or in the
case of a public customer order, with facilitation orders of the
original firm (i.e. the firm from which the original customer order
originated).\8\
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\4\ OFPA B-11 is similar in structure and content to Rule 1064
(with the exception that Commentaries .02 and .03 to Rule 1064 are
not in OFPA B-11). A sentence regarding priority is added to
subsection (c)(iii) of Rule 1064 for conformity with OFPA B-11.
\5\ Rule 1064(a).
\6\ Rule 1064(b).
\7\ Rule 1064(c).
\8\ Commentary .02 to Rule 1064. For purposes of this
commentary, an ``original order'' is when a Floor Broker holds an
equity, index or U.S. dollar-settled foreign currency option order
of the eligible order size or greater. Commentary .02 provides
further that spread, straddle, combination or hedge orders, as
defined in Exchange Rule 1066, on opposite sides of the market may
be crossed, provided that the Floor Broker holding such orders
proceeds in the manner described in Rule 1064.
---------------------------------------------------------------------------
Additionally, Rule 1064 and OFPA B-11 indicate that a non member
organization or person associated with a member or member organization
who has knowledge of all the material terms of an order being
facilitated, or an order being crossed, the execution of which is
imminent, shall not enter (based on such knowledge) an order to: (a)
Buy or sell an option for the same underlying security, (b) buy or sell
a security underlying such class, or (c) buy or sell a related
instrument (known as the ``anticipatory hedge rule'').\9\
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\9\ Rule 1064(d). For purposes of this subsection (d), an order
to buy or sell a ``related instrument'' means, ``in reference to an
index option, an order to buy or sell securities comprising 10% or
more of the component securities in the index or an order to buy or
sell a futures contract on an economically equivalent index.''
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The Exchange notes that Rule 1064 and OFPA B-11 were designed to
preserve the right to solicit orders in advance of submitting a
proposal to the trading crowd, while at the same time assuring that
orders that are the subject of solicitation are exposed to the auction
market (trading crowd) in a meaningful way by prohibiting behavior such
as anticipatory hedging.
Rule 1064 and OFPA B-11 provide that a violation of the rule or
Advice, respectively, may be considered inconsistent with just and
equitable principles of trade.\10\
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\10\ Commentary .01 to Rule 1064 and OFPA B-11. The language of
Commentary .01 to OFPA B-11 is clarified to indicate that a
violation of the Advice may be considered conduct inconsistent with
just and equitable principles of trade.
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When Phlx originally adopted the anticipatory hedge rule in 2001,
the Exchange believed that the prohibition on anticipatory hedging was
necessary to prevent members and associated persons from using
undisclosed non-public information about imminent solicited option
transactions to trade the relevant option or any closely-related
instrument in advance of persons represented in the relevant options
crowd.\11\ While the Exchange has continued to believe that this basic
principle remains true, changes in the marketplace have caused the
Exchange to re-evaluate the effectiveness and efficiency of the
Exchange's anticipatory hedge rule requirements.
---------------------------------------------------------------------------
\11\ See Securities Exchange Act Release No. 44740 (August 23,
2001), 66 FR 45721 (August 29, 2001) (SR-Phlx-2001-61) (notice of
filing and immediate effectiveness regarding, among other things,
anticipatory hedge rule in Rule 1064 and OFPA B-11).
---------------------------------------------------------------------------
The Exchange believes that increased volatility in the markets, as
well as the advent of penny trading in underlying stocks and resultant
decreased liquidity at the top of each underlying market's displayed
NBBO, it has become increasingly difficult for members and member
organizations to assess ultimate execution prices and the extent of
available stock to hedge related options facilitation/solicitation
activities, and to manage that market risk. This risk extends to simple
and complex orders,\12\ and to all market participants involved in the
transaction (whether upstairs or on-floor) because of the uncertainty
of the extent to which the market participant will participate in the
transaction, the amount of time associated with the auction process,
and the likelihood that the underlying stock prices in today's
environment may be difficult to assess and may change before they are
able to hedge. These circumstances can make it difficult to obtain a
hedge, difficult to quote orders, and difficult to achieve executions;
and can translate into less liquidity in the form of smaller size and
wider quote spreads, fewer opportunities for price improvement, and the
inefficient handling of orders.
---------------------------------------------------------------------------
\12\ Subsection (a)(i)(F) to Commentary .08 is clarified to
indicate that Complex Orders include ``tied hedge'' orders. Rule
1066 is similarly clarified to indicate that hedge orders include
``tied hedge'' orders.
---------------------------------------------------------------------------
Additionally, more and more trading activity appears to be taking
place away from the exchange-listed environment and in the over-the-
counter (``OTC'') market, which by its nature is not subject to the
same trade-through type risks present in the exchange environment.
Therefore, the Exchange is seeking to make its trading rules more
efficient not only to address the market risk and execution concerns,
but also to effectively compete with and attract volume from the OTC
market. What is more, trading strategies of market-makers, which
include Registered Options Traders (``ROTs'') and specialists on the
Exchange, have evolved.\13\ Whereas market-makers previously tended to
trade based on delta risk,\14\ now market-making strategy tends to be
based more on volatility.\15\ The tied hedge transaction procedures
(described below) are designed in a way that is consistent with this
shift toward a volatility trading strategy, and makes it more desirable
for market-makers to compete for orders that are exposed through the
solicitation process.
---------------------------------------------------------------------------
\13\ For obligations and restrictions generally applicable to
ROTs and specialists, see Rule 1014.
\14\ The price of an option is not completely dependent on
supply and demand, nor on the price of the underlying security.
Market-makers price options based on fundamental measures of risk as
well. One of these measures, delta, is the rate of change in the
price of an option as it relates to changes in the price of the
underlying security, security future or futures contract. The delta
of an option is measured incrementally based on movement in the
price of the underlying security, security future or futures
contract. For example, if the price of an option increases or
decreases by $1.00 for each $1.00 increase or decrease in the price
of the underlying security, the option would have a delta of 100. If
the price of an option increases or decreases by $0.50 for each
$1.00 increase or decrease in the price of the underlying security,
the option would have a delta of 50.
\15\ Volatility is a measure of the fluctuation in the
underlying security's market price. Market-makers that trade based
on volatility generally have options positions that they hedge with
the underlying. Once hedged, the risk exposure to the market-maker
is realized volatility and implied volatility. Realized volatility
(also known as historical volatility) is the actual volatility in
the underlying. Implied volatility is determined by using option
prices existing in the market at the time rather than using
historical data on the market price changes of the underlying.
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Proposed Exception to Anticipatory Hedge Rule
In order to address the concerns associated with increased
volatility and decreased liquidity and more effectively compete with
the OTC market, the
[[Page 63164]]
Exchange is proposing to adopt in Commentary .04 to Rule 1064 and
Commentary .02 to OFPA B-11 a limited exception to the anticipatory
hedging restrictions that would permit the representation of hedging
stock positions in conjunction with option orders in the options
trading crowd (a ``tied hedge'' transaction). The Exchange believes
this limited exception remains in keeping with the original design of
Rule 1064(d), but sets forth a more practicable approach considering
today's trading environment that will provide the ability to hedge in a
way that will still encourage meaningful competition among upstairs and
floor traders. Besides stock positions, the proposal would also permit
security futures positions to be used as a hedge. In addition, in the
case where the order is for options on indices, options on exchange-
traded funds (``ETFs'') or options on Holding Company Depository
Receipts (``HOLDRS''), a related instrument may be used as a hedge. A
``related instrument'' would mean, in reference to an index option,
securities comprising ten percent or more of the component securities
in the index or a futures contract on any economically equivalent index
applicable to the option order. A ``related instrument'' would mean, in
reference to an ETF or HOLDR option, a futures contract on any
economically equivalent index applicable to the ETF or HOLDR underlying
the option order.\16\
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\16\ For example, a tied hedge order involving options on the
iShares Russell 2000 Index ETF (IWM) might involve a hedge position
in the underlying ETF, security futures overlying the ETF, or
futures contracts overlying the Russell 2000 Index.
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With a tied hedge transaction, Exchange members would be permitted
to hedge an option order with the underlying security, a security
future or futures contract, as applicable, and then forward the option
order and the hedging position to an Exchange Floor Broker with
instructions to represent the option order together with the hedging
position to the options trading crowd. The in-crowd market participants
that chose to participate in the option transaction must also
participate in the hedging position.
First, under the proposal, the original option order must be in a
class designated as eligible for a tied hedge transaction as determined
by the Exchange, including FLEX options classes.\17\ The original
option order must also be within designated tied hedge eligibility size
parameters, which would be determined by the Exchange and would not be
smaller than 500 contracts.\18\ The Exchange notes that the minimum
order size would apply to an individual original order.\19\ Multiple
original orders could not be aggregated to satisfy the requirement
(though multiple contra-side solicited orders could be aggregated to
execute against the original order). The Exchange states that the
primary purpose of this provision is to limit use of the tied hedge
procedures to larger orders that might benefit from a member's or
member organization's ability to execute a facilitating hedge.\20\
Assuming an option order meets these eligibility parameters, the
proposal also includes a number of other conditions that must be
satisfied.
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\17\ FLEX options provide investors with the ability to
customize basic option features including size, expiration date,
exercise style, and certain exercise prices. See Rule 1079.
\18\ The designated classes and minimum order size applicable to
each class would be communicated to the membership via an Options
Regulatory Alert (``ORA''). For example, the Exchange could
determine to make the tied hedge transaction procedures available in
options class XYZ for orders of 1000 contracts or more. Such a
determination would be announced via ORA, which would include a
cumulative list of all classes and corresponding sizes for which the
tied hedge procedures are available.
\19\ In determining whether an individual original order
satisfies the eligible order size requirement, any complex order
must contain one leg alone which is for the eligible order size or
greater. For complex order procedures generally, see Commentary .08
to Rule 1080 and Rule 1089(b)(2). For complex order procedures in
respect of locked and crossed markets, see Rule 1083(d).
\20\ The Exchange believes that, given the decreased amount of
liquidity available at the NBBO, the frequency with which quotes may
flicker, and differing costs associated with accessing liquidity on
various markets, as well as for ease of administration, the proposed
500 contract minimum should be sufficient to address these
considerations.
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Second, the proposal would also require that, prior to entering
tied hedge orders on behalf of customers, the member or member
organization must deliver to the customer a onetime written
notification informing the customer that his order may be executed
using the Exchange's tied hedge procedures. Under the proposal, the
written notification must disclose the terms and conditions contained
in the proposed rule and be in a form approved by the Exchange. Given
the minimum size requirement of 500 contracts per order, the Exchange
believes that use of the tied hedges procedures will generally consist
of orders for the accounts of institutional or sophisticated, high net
worth investors. The Exchange therefore believes that a one-time
notification delivered by the member or member organization to the
customer would be sufficient, and that an order-by-order notification
would be unnecessary and overly burdensome.
Third, a member or member organization would be required to create
an electronic record that it is engaging in a tied hedge order in a
form and manner prescribed by the Exchange. The Exchange states that
the purpose of this provision is to create a record to ensure that
hedging trades would be appropriately associated with the related
options order and appropriately evaluated in the Exchange's
surveillance program. The Exchange believes that this requirement
should enable the Exchange to monitor for compliance with the
requirements of the proposed rule, as discussed below, by identifying
the specific purchase or sell orders relating to the hedging position.
Fourth, the proposed rule would require that members and member
organizations that have decided to engage in tied hedge orders for
representation in the trading crowd would have to ensure that the
hedging position associated with the tied hedge order is comprised of a
position that is designated as eligible for a tied hedge transaction.
Eligible hedging positions would be determined by the Exchange for each
eligible class and may include (a) The same underlying stock applicable
to the option order, (b) a security future overlying the same stock
applicable to the option order, or (c) in reference to an option on an
index, ETF or HOLDR, a ``related instrument'' (as described above). For
example, for options overlying XYZ stock, the Exchange may determine to
designate the underlying XYZ stock or XYZ security futures or both as
eligible hedging positions.\21\ The Exchange states that the purpose of
this provision is to ensure that the hedging position would be for the
same stock, equivalent security future or related instrument, as
applicable, thus allowing crowd participants who may be considering
participation in a tied hedge order to adequately evaluate the risk
associated with the option as it relates to the hedge. With stock
positions in particular, the Exchange notes that occasionally crowd
participants hedge option positions with stock that is related to the
option, such as the stock of an issuer in the same industry, but not
the actual stock associated with the option. Except as otherwise
discussed above for index options, the proposed
[[Page 63165]]
rule change would not allow such a ``related'' hedging stock position,
but would require the hedging stock position to be the actual security
underlying the option.
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\21\ As with designated classes and minimum order size, the
eligible hedging positions applicable to each class would be
communicated to the membership via ORA, which would include a
cumulative list of all classes and corresponding sizes for which the
tied hedge procedures are available. See note 19, supra.
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Fifth, the proposal would require that the entire hedging position
be brought without undue delay to the trading crowd. In considering
whether the hedging position is presented without ``undue delay,'' the
Exchange believes that members and member organizations should continue
to have the same ability to shop an order in advance of presenting it
to the crowd and should be able to enhance that process through
obtaining a hedge. The Exchange also believes that, once a hedge is
obtained, the order should be brought to the crowd promptly in order to
satisfy the ``undue delay'' requirement. In addition, the proposal
would require that the hedging position be announced to the trading
crowd concurrently with the option order, offered to the crowd in its
entirety, and offered at the execution price received by the member or
member organization introducing the order to any in-crowd market
participant who has established parity or priority for the related
options. In-crowd market participants that participate in the option
transaction must also participate in the hedging position on a
proportionate basis \22\ and would not be permitted to prevent the
option transaction from occurring by giving a competing bid or offer
for one component of the tied hedge order. The Exchange states that the
purpose of these requirements is to ensure that the hedging position
represented to the crowd would be a good faith effort to provide in-
crowd market participants with the same opportunity as the member or
member organization introducing the tied hedge order to compete most
effectively for the option order.
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\22\ For example, if an in-crowd market participant's allocation
is 100 contracts out of a 500 contract option order (\1/5\), the
same in-crowd market participant would trade 10,000 shares of a
50,000 stock hedge position tied to that option order (\1/5\).
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For example, if a member or member organization introducing a tied
stock hedge order were to offer 1,000 XYZ option contracts to the crowd
(overlying 100,000 shares of XYZ stock) and concurrently offer only
30,000 of 100,000 shares of the underlying stock that the member
obtained as a hedge, crowd participants might only be willing or able
to participate in 300 of the option contracts offered if the hedging
stock position cannot be obtained at a price as favorable as the stock
hedging position offering price, if at all. The Exchange states that
the effect of this would be to place the crowd at a disadvantage
relative to the introducing member or member organization for the
remaining 700 option contracts in the tied stock hedge order, and thus
create a disincentive for the crowd to bid or offer competitively for
the remaining 700 option contracts. The Exchange believes the
requirement that the hedging position be presented concurrently with
the option order in the crowd and offered to the crowd in its entirety
at the execution price received by the member or member organization
introducing the order should ensure that the crowd would be competing
on a level playing field with the introducing member or member
organization to provide the best price to the customer.
Sixth, the proposal would require that the hedging position not
exceed the options order on a delta basis. For example, in the
situation where a tied stock hedge order involves the simultaneous
purchase of 50,000 shares of XYZ stock and the sale of 500 XYZ call
contract (known as a ``buy-write''), and the delta of the option is
100, it would be considered ``hedged'' by 50,000 shares of stock.
Accordingly, the proposed rule would not allow the introducing member
firm to purchase more than 50,000 shares of stock in the hedging stock
position. The Exchange believes that it is reasonable to require that
the hedging position be in amounts that do not exceed the equivalent
size of the related options order on a delta basis, and not for a
greater number of shares. The Exchange believes that the proposed rule
change would support its view that the member or member organization
introducing the tied hedge order be guided by the notion that any
excess hedging activity could be detrimental to the eventual execution
price of the option order. Consequently, while delta estimates may vary
slightly, the introducing member or member organization would be
required to assume hedging positions not to exceed the equivalent size
of the options order on a delta basis.\23\
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\23\ The Exchange notes that there may be scenarios where the
introducing member purchases (sells) less than the delta, e.g., when
there is not enough stock available to buy (sell) at the desired
price. In such scenarios, the introducing member would present the
stock that was purchased (sold) and share it with the in-crowd
market participants on equal terms. This risk of obtaining less than
a delta hedge is a risk that exists under the current rules because
of the uncertainty that exists when market participants price an
option and have to anticipate the price at which they will be able
to obtain a hedge. The proposed tied hedge procedures are designed
to help reduce this risk, but the initiating member may still be
unable to execute enough stock at the desired price. To the extent
the initiating member is able to execute any portion of the hedge,
the risk exposure to the initiating member and in-crowd market
participants would be diminished because those shares would be
``tied up'' and available for everyone that participates on the
resulting tied hedge transaction. The Exchange does not believe that
the initiating member would have an unfair advantage by having the
ability to pre-facilitate less than a delta hedge because the
proposed procedures would require the in-crowd market participants
to get a proportional share of the hedge. To the extent more stock
is needed to complete a hedge, the initiating member and the in-
crowd market participants would have the same risk exposure that
they do today.
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The Exchange believes that the delta basis requirement, together
with the additional conditions that an introducing member or member
organization bring the hedging position without undue delay to the
trading crowd and announce it concurrently with the option order, offer
it to the crowd in its entirety, and offer it at the execution price
received by the member or member organization to any in-crowd market
participant who has established parity or priority, will help assure
that the hedging activity is bona fide and not for speculative or
manipulative purposes. Additionally, the Exchange believes these
conditions will help assure that there is no adverse affect on the
auction market because, as discussed above, in-crowd market
participants will have the same opportunity as the member or member
organization introducing the tied hedge order to compete for the option
order and will share the same benefits of limiting the market risk
associated with hedging. The Exchange believes that customers will also
benefit if the market risks are limited in the manner proposed. Once an
original order is hedged, there is no delta risk. With the delta risk
minimized, quotes will likely narrow as market participants (whether
upstairs or on-floor) are better able to hedge and compete for orders.
For example, market-makers could more easily quote markets to trade
against a customer's original order based on volatility with the delta
risk minimized, which should ultimately present more price improvement
opportunities to the original order.\24\
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\24\ The Exchange also believes that the proposed exception to
the anticipatory hedging procedures will assist in the Exchange's
competitive efforts to attract order flow from the OTC market, which
may result in increased volume on the exchange markets.
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At this time, the Exchange is not proposing any special priority
provisions applicable to tied hedge transactions, though it intends to
evaluate whether such changes are desired and may submit a separate
rule filing on this subject in the future. Under the instant proposal,
all tied hedge transactions will be treated as
[[Page 63166]]
complex orders. Priority will be afforded in accordance with the
Exchange's existing open outcry allocation and reporting procedures for
complex orders.\25\ Any resulting tied hedge transactions will also be
subject to the existing NBBO trade-through requirements for options and
stock, as applicable. In this regard, the Exchange believes that the
resulting option and stock components of the tied hedge transactions
may qualify for various NBBO trade through exceptions including, for
example, the complex trade exception.\26\ However, when the option
order is a simple order the execution of the option leg of a tied hedge
transaction does not qualify it for any NBBO trade-through exception
for a Complex Trade. Recognizing that tied hedge transactions involve
complex orders and trades, the Exchange is amending the definition of
Complex Order to clarify that these include ``tied hedge''
transactions.\27\
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\25\ For reporting procedures, see, Rules 1053 (Filing of Trade
Information), 1003 (Reporting of Options Positions), 1022
(Securities Accounts and Orders of Specialists and Registered
Options Traders), and 1028 (Confirmations). For allocation
procedures, see, Rules 1014 (Obligations and Restrictions Applicable
to Specialists and Registered Options Traders) and 1080 (Phlx XL and
XL II). Options trading rules are generally located in the 1000
series of rules known as the Options Rules (Rule 1000 et. seq.) and
include Rules 1001 (Position Limits), 1002 (Exercise Limits), 1033
(Bid and Offers--Premium), 1034 (Minimum Increments), and 1035
(Acceptance of Bid or Offer).
\26\ See Rule 1085(b)(6) (Order Protection). Rules 1083
(Intermarket Linkage) through 1087 (Limitation on Principal Order
Access) implement the recently-approved joint Options Order
Protection and Locked/Crossed Market Plan (the ``Protection and
Locked/Crossed Plan''). See Securities Exchange Act Release No.
60405 (July 30, 2009), 74 FR 39362 (August 6, 2009)(File No. 4-
546)(approval order for the Protection and Locked/Crossed Plan). See
also Securities Exchange Act Release No. 60550 (August 20, 2009), 74
FR 44430 (August 28, 2009)(SR-Phlx-2009-61)(approval order for Phlx
rules implementing the Protection and Locked/Crossed Plan).
\27\ See Commentary .08(a)(i)(F) to Rule 1080. The Exchange
notes that a complex order for ``tied hedge''purposes in Rule 1080
is distinct from a complex trade for linkage purposes in Rule 1083;
and that intramarket priority on the Exchange for tied hedge
purposes is distinct from intermarket priority for linkage purposes.
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The Exchange recognizes that, at the time a tied hedge transaction
is executed in a trading crowd, market conditions in any of the non-
Phlx market(s) may prevent the execution of the non-options leg(s) at
the price(s) agreed upon. For example, the execution price may be
outside the non-Phlx market's best bid or offer (``BBO''), such as
where the stock leg is to be executed at a price of $25.03 and the
particular stock market's BBO is $24.93-$25.02; such an execution would
normally not be permitted unless an exception applies that permits the
trade to be reported outside the BBO.\28\ The Exchange clarified in
proposed Commentary .04 to Rule 1064 and Commentary.02 to OFPA B-11
that in the event the conditions in the non-Phlx market continue to
prevent the execution of the non-option leg(s) at the agreed price(s),
the trade representing the options leg(s) of the tied hedge transaction
may be cancelled at the request of any member that is a party to the
tied hedge transaction.
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\28\ The Exchange notes that the possibility of this scenario
occurring exists with complex order executions today and tied hedge
transactions would present nothing unique or novel in this regard.
---------------------------------------------------------------------------
The following examples illustrate these principles:
Simple Original Order: Introducing member receives an
original customer order to buy 500 XYZ call options, which has a delta
of 100. The introducing member purchases 50,000 shares of XYZ stock on
the NYSE for an average price of $25.03 per share. Once the stock is
executed on the NYSE, the introducing member, without undue delay,
announces the 500 contract option order and 50,000 share tied stock
hedge at $25.03 per share to the appropriate Phlx trading crowd.
Complex Original Order: Introducing member receives an
original customer stock-option order to buy 500 XYZ call options and
sell 50,000 shares of XYZ stock. The introducing member purchases
50,000 shares of XYZ stock on the NYSE for an average price of $25.03
per share. Once the stock is executed on the NYSE, the introducing
member, without undue delay, announces the 500 contract option order
and 50,000 share tied stock hedge at $25.03 per share to the
appropriate trading crowd.
In either the scenario regarding simple orders or the scenario
regarding complex orders (which includes ``tied hedge'' orders), the
next steps are the same and generally are no different from the
procedures currently used to execute a complex order on Phlx in open
outcry.
The Exchange notes regarding the examples above that:
The in-crowd market participants would have an opportunity
to provide competing quotes for the tied hedge package (and not for the
individual component legs of the package). For example, assume the best
net price is $24.53 (equal to $0.50 for each option contract and $25.03
for each corresponding share of hedging stock).
The option order and hedging stock would be allocated
among the in-crowd market participants that established priority or
parity at that price, including the initiating member, in accordance
with the allocation algorithm applicable to the options class, with the
options leg being executed and reported on Phlx and the stock leg being
executed and reported on the stock market specified by the initiating
member. For example, the introducing member might trade 40% pursuant to
an open outcry crossing entitlement (200 options contracts and 20,000
shares of stock) and the remaining balance might be with three
different market-makers that each participated on 20% of the order (100
options contracts and 10,000 shares of stock per market-maker).
The resultant tied hedge transaction: (a) would qualify as
a ``complex trade'' under the Options Intermarket Linkage and the
execution of the 500 option contracts with the market participants
would not be subject to the NBBO for the particular option series in
the scenario where the original order is a complex order (not a simple
order); and (b) would qualify as a ``qualified contingent trade'' under
Regulation NMS and the execution of the 30,000 shares of stock (the
original 50,000 shares less the initiating member's 20,000 portion)
with the market participants would not be subject to the NBBO for the
underlying XYZ stock.
The execution of the options leg would have to satisfy
Phlx's intra-market priority rules for complex orders (including that
the execution price may not be outside the Phlx BBO (``PBBO'')). Thus,
if the PBBO for the series was $0.40 $0.55, the execution could take
place at or inside that price range (e.g., at the quoted price of
$0.50) and could not take place outside that price range (e.g., not at
$0.56).
Similarly, the execution of the stock at $25.03 per share
would have to satisfy the intra-market priority rules of the non-Phlx
market(s) where the stock is to be executed (including that the
execution price may not be outside that market's BBO) or,
alternatively, qualify for an exception that permits the trade to be
reported outside the non-Phlx market(s) BBO.
If market conditions in the non-Phlx market(s) prevent the
execution of the stock leg(s) at the price(s) agreed upon from
occurring (e.g., the BBO remains at $24.93-$25.02), then the options
leg(s) could be cancelled at the request of any member that is a party
to that trade.
While the particular circumstances surrounding each transaction on
the Exchange's trading floor are different, the Exchange does not
believe, as a general proposition, that the tied hedge
[[Page 63167]]
procedures would be inherently harmful or detrimental to customers or
have an adverse affect on the auction market. Rather, the Exchange
believes the procedures will improve the opportunities for an order to
be exposed to a competitive auction and represent an improvement over
the current rules. The fact that the parties to such a trade end up
fully hedged may contribute to the best execution of the orders,\29\
and, in any event, participants continue to be governed by, among other
things, their best execution responsibilities. The Exchange also
believes that the proposed tied hedge procedures are fully consistent
with the original design of Rule 1064(d) which, as discussed above, was
to eliminate the unfairness that can be associated with a solicited
transaction and encourage meaningful competition. The tied hedge
procedures should enable in-crowd market participants to be on equal
footing with solicited parties in a manner that minimizes all parties'
market risk while continuing to assure that orders are exposed in a
meaningful way.
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\29\ As market participants are better able to hedge risk
associated with completing these transactions, the Exchange believes
that quotes may narrow and result in increased price improvement
opportunities.
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2. Statutory Basis
The Exchange believes that its proposal is consistent with Section
6(b) of the Act \30\ in general, and furthers the objectives of Section
6(b)(5) of the Act \31\ in particular, in that it is designed to
promote just and equitable principles of trade, to remove impediments
to and perfect the mechanism of a free and open market and a national
market system, and, in general to protect investors and the public
interest, by establishing rules governing tied hedge orders, which
include specific requirements and procedures to be followed.
Specifically, the Exchange believes the procedures will improve the
opportunities for orders to be exposed to price improvement in a manner
that will encourage a fair, competitive auction process and minimize
all parties' market risk.
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\30\ 15 U.S.C. 78f(b).
\31\ 15 U.S.C. 78f(b)(5).
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B. Self-Regulatory Organization's Statement on Burden on Competition
The Exchange does not believe that the proposed rule change will
impose any burden on competition not necessary or appropriate in
furtherance of the purposes of the Act.
C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants, or Others
No written comments were either solicited or received.
III. Date of Effectiveness of the Proposed Rule Change and Timing for
Commission Action
Because the foregoing rule does not (i) Significantly affect the
protection of investors or the public interest; (ii) impose any
significant burden on competition; and (iii) become operative for 30
days from the date on which it was filed, or such shorter time as the
Commission may designate if consistent with the protection of investors
and the public interest, provided that the self-regulatory organization
has given the Commission written notice of its intent to file the
proposed rule change at least five business days prior to the date of
filing of the proposed rule change or such shorter time as designated
by the Commission,\32\ the proposed rule change has become effective
pursuant to Section 19(b)(3)(A) of the Act \33\ and Rule 19b-4(f)(6)
thereunder.\34\
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\32\ The Exchange has satisfied this requirement.
\33\ 15 U.S.C. 78s(b)(3)(A).
\34\ 17 CFR 240.19b-4(f)(6).
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At any time within 60 days of the filing of such proposed rule
change, the Commission may summarily abrogate such rule change if it
appears to the Commission that such action is necessary or appropriate
in the public interest, for the protection of investors, or otherwise
in furtherance of the purposes of the Act.
IV. Solicitation of Comments
Interested persons are invited to submit written data, views, and
arguments concerning the foregoing, including whether the proposed rule
change is consistent with the Act. Comments may be submitted by any of
the following methods:
Electronic Comments
Use the Commission's Internet comment form (https://www.sec.gov/rules/sro.shtml); or
Send an e-mail to rule-comments@sec.gov. Please include
File Number SR-Phlx-2009-98 on the subject line.
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 SR-Phlx-2009-98. This file
number should be included on the subject line if e-mail is used. To
help the Commission process and review your comments more efficiently,
please use only one method. The Commission will post all comments on
the Commission's Internet Web site (https://www.sec.gov/rules/sro.shtml). Copies of the submission, all subsequent amendments, all
written statements with respect to the proposed rule change that are
filed with the Commission, and all written communications relating to
the proposed rule change between the Commission and any person, other
than those that may be withheld from the public in accordance with the
provisions of 5 U.S.C. 552, will be available for inspection and
copying in the Commission's Public Reference Room, 100 F Street, NE.,
Washington, DC 20549, on official business days between the hours of 10
a.m. and 3 p.m. Copies of such filing also will be available for
inspection and copying at the principal office of the Exchange. All
comments received will be posted without change; the Commission does
not edit personal identifying information from submissions. You should
submit only information that you wish to make available publicly. All
submissions should refer to File Number SR-Phlx-2009-98 and should be
submitted on or before December 23, 2009.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\35\
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\35\ 17 CFR 200.30-3(a)(12).
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Elizabeth M. Murphy,
Secretary.
[FR Doc. E9-28740 Filed 12-1-09; 8:45 am]
BILLING CODE 8011-01-P