Self-Regulatory Organizations; National Securities Clearing Corporation; Notice of No Objection to Advance Notice Filing to Eliminate the Offset of Its Obligations With Institutional Delivery Transactions That Settle at The Depository Trust Company for the Purpose of Calculating Its Clearing Fund Under Procedure XV of Its Rules & Procedures, 21433-21435 [2013-08306]
Download as PDF
Federal Register / Vol. 78, No. 69 / Wednesday, April 10, 2013 / Notices
Dated: April 5, 2013.
Elizabeth M. Murphy,
Committee Management Officer.
[FR Doc. 2013–08372 Filed 4–9–13; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
Sunshine Act Meeting
Notice is hereby given, pursuant to
the provisions of the Government in the
Sunshine Act, Public Law 94–409, that
the Securities and Exchange
Commission Advisory Committee on
Small and Emerging Companies will
hold a public meeting on Wednesday,
May 1, 2013, in Multi-Purpose Room
LL–006 at the Commission’s
headquarters, 100 F Street NE.,
Washington, DC. The meeting will begin
at 9:30 a.m. (EDT) and will be open to
the public. Seating will be on a firstcome, first-served basis. Doors will open
at 9:00 a.m. Visitors will be subject to
security checks. The meeting will be
Webcast on the Commission’s Web site
at www.sec.gov.
On April 5, 2013 the Commission
published notice of the Committee
meeting (Release No. 33–9399),
indicating that the meeting is open to
the public and inviting the public to
submit written comments to the
Committee. This Sunshine Act notice is
being issued because a majority of the
Commission may attend the meeting.
The agenda for the meeting includes
consideration of recommendations and
other matters relating to rules and
regulations affecting small and emerging
companies under the federal securities
laws. For further information, please
contact the Office of the Secretary at
(202) 551–5400.
Dated: April 5, 2013.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2013–08430 Filed 4–8–13; 11:15 am]
BILLING CODE 8011–01–P
meeting will begin at 10:00 a.m. (EDT)
and will be open to the public, except
for subcommittee meetings. Seating will
be on a first-come, first-served basis.
Doors will open at 9:30 a.m. Visitors
will be subject to security checks. The
meeting will be Webcast on the
Commission’s Web site at www.sec.gov.
Commissioner Aguilar, as duty
officer, determined that no earlier notice
thereof was possible.
On March 29, 2013, the Commission
issued notice of the Committee meeting
(Release No. 33–9397), indicating that
the meeting is open to the public and
inviting the public to submit written
comments to the Committee. This
Sunshine Act notice is being issued
because a quorum of the Commission
may attend the meeting.
The agenda for the meeting includes:
(i) approval of minutes; (ii)
consideration of a recommendation of
the Investor as Purchaser subcommittee
regarding target date funds; (iii)
subcommittee meetings; and (iv)
subcommittee updates. For further
information, please contact the Office of
the Secretary at (202) 551–5400.
entitled the Payment, Clearing, and
Settlement Supervision Act of 2010
(‘‘Clearing Supervision Act’’ or ‘‘Title
VIII’’) and Rule 19b–4(n) of the
Securities Exchange Act of 1934
(‘‘Exchange Act’’). The Advance Notice
was published in the Federal Register
on January 17, 2013.2 The Commission
received two comment letters to the
Advance Notice from one commenter.3
NSCC responded to both comment
letters.4 This publication serves as
notice of no objection to the Advance
Notice.
Dated: April 5, 2013.
Elizabeth M. Murphy,
Secretary.
A. ID Offset
[FR Doc. 2013–08427 Filed 4–8–13; 11:15 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–69301; File No. SR–NSCC–
2012–810]
Self-Regulatory Organizations;
National Securities Clearing
Corporation; Notice of No Objection to
Advance Notice Filing to Eliminate the
Offset of Its Obligations With
Institutional Delivery Transactions
That Settle at The Depository Trust
Company for the Purpose of
Calculating Its Clearing Fund Under
Procedure XV of Its Rules &
Procedures
April 4, 2013.
SECURITIES AND EXCHANGE
COMMISSION
TKELLEY on DSK3SPTVN1PROD with NOTICES
Sunshine Act Meeting
Notice is hereby given, pursuant to
the provisions of the Government in the
Sunshine Act, Public Law 94–409, that
the Securities and Exchange
Commission Investor Advisory
Committee will hold a meeting on
Thursday, April 11, 2013, in MultiPurpose Room LL–006 at the
Commission’s headquarters, 100 F
Street NE., Washington, DC. The
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17:59 Apr 09, 2013
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21433
I. Introduction
On December 18, 2012, National
Securities Clearing Corporation
(‘‘NSCC’’) filed with the Securities and
Exchange Commission (‘‘Commission’’)
advance notice SR–NSCC–2012–810
(‘‘Advance Notice’’) pursuant to Section
806(e) of Title VIII of the Dodd-Frank
Wall Street Reform and Consumer
Protection Act (‘‘Dodd-Frank Act’’),1
1 Dodd-Frank Wall Street Reform and Consumer
Protection Act, Public Law 111–203, 124 Stat. 1376
(2010).
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II. Analysis
NSCC filed the Advance Notice to
permit it to make rule changes to its
Rules & Procedures (‘‘Rules’’) designed
to eliminate the offset of NSCC
obligations with institutional delivery
(‘‘ID’’) transactions that settle at The
Depository Trust Company (‘‘DTC’’) for
the purpose of calculating the NSCC
clearing fund (‘‘Clearing Fund’’) under
Procedure XV of its Rules, as discussed
below.
NSCC maintains a Clearing Fund to
have on deposit assets sufficient to
satisfy losses that may otherwise be
incurred by NSCC as the result of the
default of an NSCC member (‘‘Member’’)
and the resulting closeout of that
Member’s unsettled positions under
NSCC’s trade guaranty. Each Member is
required to contribute to the Clearing
Fund pursuant to a formula calculated
daily. The Clearing Fund formula
accounts for a variety of risk factors
through the application of a number of
components, including Value-at-Risk
2 Release No. 34–68621 (Jan. 10, 2013), 78 FR
3960 (Jan. 17, 2013). NSCC also filed a proposed
rule change pursuant to Section 19(b)(1) of the
Exchange Act on December 17, 2012 seeking
Commission approval to permit NSCC to change its
rules to reflect the proposed change described
herein. The Commission published notice of the
proposed rule change on December 28, 2012.
Release No. 34–68549 (Dec. 28, 2012), 78 FR 792
(Jan. 4, 2013). The Commission extended the period
of review of the proposed rule change on February
5, 2013. Release No. 34–68829 (Feb. 5, 2013), 78 FR
9751 (Feb. 11, 2013).
3 Comment Letter from Lek Securities Corporation
dated January 25, 2013 (https://sec.gov/comments/srnscc-2012–810/nscc2012810–1.pdf), and Comment
Letter from Lek Securities Corporation dated March
18, 2013 (https://sec.gov/comments/sr-nscc-2012–
810/nscc2012810–3.pdf) (collectively, the ‘‘Lek
Letters’’).
4 Response Letter from NSCC dated February 22,
2013 (https://sec.gov/comments/sr-nscc-2012–810/
nscc2012810–2.pdf), and Response Letter from
NSCC dated March 21, 2013 (https://sec.gov/
comments/sr-nscc-2012–810/nscc2012810–4.pdf).
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Federal Register / Vol. 78, No. 69 / Wednesday, April 10, 2013 / Notices
(‘‘VaR’’) 5 and Market Maker Domination
(‘‘MMDOM’’).6
NSCC currently calculates the VaR
and MMDOM components of a
Member’s Clearing Fund required
deposit after allowing for a Member’s
net unsettled NSCC positions in a
particular CUSIP to be offset by any
pending ID transactions settling at DTC
in the same CUSIP, which have been
confirmed and/or affirmed through an
institutional delivery system acceptable
to NSCC (‘‘ID Offset’’).7 ID Offset is
based on the assumption that in the
event of a Member’s insolvency NSCC
will be able to close out any trade for
which there is a corresponding ID
transaction settling at DTC by
completing that ID transaction.8
TKELLEY on DSK3SPTVN1PROD with NOTICES
B. Potential Inability To Complete ID
Transactions
Generally, when NSCC ceases to act
for a Member, it is obligated, for those
transactions that it has guaranteed, to
pay for deliveries made by nondefaulting Members that are due to the
failed Member on the day they are due.
If NSCC is unable to complete the ID
transactions as contemplated by the
current Clearing Fund calculation, then
NSCC may need to liquidate a portfolio
that could be substantially different
than the portfolio for which NSCC
collected its Clearing Fund, leaving
NSCC potentially under-collateralized
and exposed to market risk.
A defaulting Member’s pending ID
transactions may not be completed for a
number of reasons. Completion of an ID
transaction by its institutional
counterparty is voluntary because that
5 The VaR component of the Clearing Fund
calculation is a core component of the formula and
is designed to calculate the amount of money that
may be lost on a portfolio over a given period of
time that is assumed necessary to liquidate the
portfolio, within a given level of confidence. See
Release No. 34–68621 (Jan. 10, 2013), 78 FR 3960
(Jan. 17, 2013).
6 The MMDOM component of the Clearing Fund
calculation is charged to market makers or firms
that clear for them. In calculating the MMDOM, if
the sum of the absolute values of net unsettled
positions in a security for which the firm in
question makes a market is greater than that firm’s
excess net capital, NSCC may then charge the firm
an amount equal to such excess or the sum of each
of the absolute values of the affected net unsettled
positions, or a combination of both. MMDOM
operates to identify concentration within a given
CUSIP. See Release No. 34–68621 (Jan. 10, 2013),
78 FR 3960 (Jan. 17, 2013).
7 For purposes of the ID Offset, NSCC includes ID
transactions that are confirmed and/or affirmed on
trade date, as well as ID transactions affirmed one
day after trade date and remain affirmed through
settlement date. See Release No. 34–68621 (Jan. 10,
2013), 78 FR 3960 (Jan. 17, 2013).
8 ID transactions are included in the ID Offset
only if they are on the opposite side of the market
from the Member’s net NSCC position (i.e., only if
they reduce the net position). See Release No. 34–
68621 (Jan. 10, 2013), 78 FR 3960 (Jan. 17, 2013).
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17:59 Apr 09, 2013
Jkt 229001
counterparty is not a Member, which
means it is not bound by NSCC’s Rules
and is not party to any legally binding
contract with NSCC that requires it or
its custodian to complete the
transaction. Moreover, based on news
that a Member may be in distress or
insolvent, the institutional counterparty
or its investment adviser may take
immediate market action with respect to
the ID transaction, in order to reduce its
market risk, which effectively
eliminates the option for NSCC to
complete the transactions. Finally, ID
transactions settle trade-by-trade
between the executing broker and the
custodian; the netted ID positions used
to offset the NSCC position could be
comprised of thousands of individual
trades with hundreds of different
counterparties. In the event of a Member
default, it could be time consuming for
NSCC to contact the counterparties
individually to get their agreement to
complete the ID transactions. Even if
NSCC were to get all of the
counterparties to agree to complete the
ID transactions, this could delay the
prompt closeout of the defaulter’s open
positions and possibly expose NSCC to
additional market risk in excess of the
Clearing Fund.
Due to the risk that, in the event it
ceases to act for a Member with pending
ID transactions, NSCC may be unable to
complete the pending ID transactions in
the timeframe contemplated by its
current Clearing Fund calculations and,
as a result, may have insufficient margin
in its Clearing Fund, as described above,
NSCC will eliminate the ID Offset
calculation from the VaR and MMDOM
components of a Member’s Clearing
Fund requirement deposit.
C. Implementation Schedule
In order to mitigate the impact of this
rule change on its Members, NSCC will
implement the changes set forth in the
Advance Notice over an 18-month
period. On a date no earlier than 10
days following notice to Members by
Important Notice (‘‘Initial
Implementation Date’’), NSCC will
eliminate ID Offset from ID transactions
that have only been confirmed, but have
not yet been affirmed. Beginning on a
date approximately 12 months from the
Initial Implementation Date, and no
earlier than 10 days following notice to
Members by Important Notice, NSCC
will eliminate from ID Offset all
affirmed ID transactions that have
reached settlement date at the time the
Clearing Fund calculations are run.
Three months later, or approximately 15
months following the Initial
Implementation Date, and on a date no
earlier than 10 days following notice to
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Fmt 4703
Sfmt 4703
Members by Important Notice, NSCC
will eliminate from ID Offset all
affirmed ID transactions that have
reached either settlement date or the
day prior to settlement date. Finally, on
a date approximately 18 months
following the Initial Implementation
Date, and no earlier than 10 days
following notice to Members by
Important Notice, NSCC will eliminate
ID Offset entirely for all ID transactions.
Members will be advised of each
proposed implementation date through
issuance of NSCC Important Notices,
which are publicly available at
www.dtcc.com.
III. Discussion
Although Title VIII does not specify a
standard of review for an Advance
Notice, the stated purpose of Title VIII
is instructive.9 The stated purpose of
Title VIII is to mitigate systemic risk in
the financial system and promote
financial stability by, among other
things, promoting uniform risk
management standards for systemicallyimportant financial market utilities
(‘‘FMUs’’) and providing an enhanced
role for the Federal Reserve Board in the
supervision of risk management
standards for systemically-important
FMUs.10
Section 805(a)(2) of the Clearing
Supervision Act 11 authorizes the
Commission to prescribe risk
management standards for the payment,
clearing, and settlement activities of
designated clearing entities and
financial institutions engaged in
designated activities for which it is the
supervisory agency or the appropriate
financial regulator. Section 805(b) of the
Clearing Supervision Act 12 states that
the objectives and principles for the risk
management standards prescribed under
Section 805(a) shall be to:
• Promote robust risk management;
• promote safety and soundness;
• reduce systemic risks; and
• support the stability of the broader
financial system.
The Commission adopted risk
management standards under Section
805(a)(2) of the Clearing Supervision
Act on October 22, 2012 (‘‘Clearing
Agency Standards’’).13 The Clearing
Agency Standards became effective on
January 2, 2013 and require clearing
agencies that perform central
counterparty (‘‘CCP’’) services to
establish, implement, maintain, and
9 12
U.S.C. 5461(b).
10 Id.
11 12
U.S.C. 5464(a)(2).
U.S.C. 5464(b).
13 Release No. 34–68080 (Oct. 22, 2012), 77 FR
66219 (Nov. 2, 2012).
12 12
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Federal Register / Vol. 78, No. 69 / Wednesday, April 10, 2013 / Notices
TKELLEY on DSK3SPTVN1PROD with NOTICES
enforce written policies and procedures
that are reasonably designed to meet
certain minimum requirements for their
operations and risk management
practices on an ongoing basis.14 As
such, it is appropriate for the
Commission to review Advance Notices
against these risk management
standards that the Commission
promulgated under Section 805(a) and
the objectives and principles of these
risk management standards as described
in Section 805(b).
As a CCP, NSCC occupies an
important role in the securities
settlement system by interposing itself
between counterparties to financial
transactions, thereby reducing certain
risks faced by Members and
contributing to global financial stability.
In this role, however, NSCC is
necessarily subject to certain risks in the
event of the default of a Member.
NSCC’s proposal to eliminate ID
Offsets, as described above, is designed
to help mitigate the risk that NSCC will
be under-collateralized if it ceases to act
for a defaulting Member and is unable
to complete the offsetting ID
transactions in the time currently
contemplated by its Clearing Fund
calculation. Consistent with Section
805(a), the Commission believes this
proposal promotes robust risk
management, as well as the safety and
soundness of NSCC’s operations, while
reducing systemic risks and supporting
the stability of the broader financial
system, by improving NSCC’s risk
management systems in preparation for
a possible Member default via a more
accurate representation of risk in its
Clearing Fund calculation. As discussed
above, NSCC’s calculation of its
Clearing Fund margin will be more
accurate in that it will not include an
assumption of trade closeouts following
a Member insolvency with respect to
trades for which there is a
corresponding ID transaction.
Additionally, Commission Rule
17Ad–22(b)(1) regarding measurement
and management of credit exposure,15
adopted as part of the Clearing Agency
Standards,16 requires a CCP to establish,
implement, maintain and enforce
14 The Clearing Agency Standards are
substantially similar to the risk management
standards established by the Board of Governors of
the Federal Reserve System (‘‘Board of Governors’’)
governing the operations of designated FMUs that
are not clearing entities and financial institutions
engaged in designated activities for which the
Commission or the Commodity Futures Trading
Commission is the Supervisory Agency. See
Financial Market Utilities, 77 FR 45907 (Aug. 2,
2012).
15 17 CFR 240.17Ad–22(b)(1).
16 Release No. 34–68080 (Oct. 22, 2012), 77 FR
66219 (Nov. 2, 2012).
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17:59 Apr 09, 2013
Jkt 229001
written policies and procedures
reasonably designed to measure its
credit exposures to its participants at
least once a day and limit its exposures
to potential losses from defaults by its
participants under normal market
conditions so that the operations of the
CCP would not be disrupted and nondefaulting participants would not be
exposed to losses that they cannot
anticipate or control.17 Here, as
described in detail above, NSCC’s
proposal to eliminate ID Offsets should
help to limit its exposure and nondefaulting members’ exposure to
potential losses from a defaulting
Member, while minimizing disruption
to its CCP operations, by more
accurately reflecting its risks in the
calculation of its Clearing Fund margin.
Furthermore, Commission Rules
17Ad–22(d)(4) regarding identification
and mitigation of operational risk,18 and
17Ad-22(d)(11) regarding default
procedures,19 also both adopted as part
of the Clearing Agency Standards,20
require that registered clearing agencies
‘‘establish, implement, maintain and
enforce written policies and procedures
reasonably designed to, as applicable:
* * * Identify sources of operational
risk and minimize them through the
development of appropriate systems,
controls, and procedures * * * ’’,21 and
‘‘ * * * establish default procedures
that ensure that the clearing agency can
take timely action to contain losses and
liquidity pressures and to continue
meeting its obligations in the event of a
participant default,22 respectively. Here,
as described in detail above, the
elimination of ID Offsets should help
NSCC better minimize settlement risks
and better ensure that it can contain
losses and liquidity pressures, and meet
its obligations in a timely fashion, by
more accurately accounting for those
risks in a Clearing Fund calculation that
is designed to satisfy potential losses in
a timely manner.
In its assessment of the Advance
Notice, the Commission assessed
whether the issues raised by the Lek
Letters relate to the level or nature of
risks presented by NSCC’s proposal,
which is designed to mitigate risks to
NSCC, as discussed above. After
evaluating NSCC’s responses to the Lek
Letters, the Commission believes that
the issues raised in the Lek Letters relate
to the potential competitive effects of
CFR 240.17Ad–22(b)(1).
CFR 240.17Ad–22(d)(4).
19 17 CFR 240.17Ad–22(d)(11).
20 Release No. 34–68080 (Oct. 22, 2012), 77 FR
66219 (Nov. 2, 2012).
21 17 CFR 240.17Ad–22(d)(4).
22 17 CFR 240.17Ad–22(d)(11).
21435
NSCC’s proposal, not the level or nature
of risks presented by it.23 As such, the
issues raised by the Lek Letters are not
considered within the context of this
Notice of No Objection to the Advance
Notice under Title VIII; rather, they are
considered within an analysis of the
proposal’s consistency with Section 17A
of the Exchange Act and the applicable
rules and regulations thereunder, which
the Commission did in its ‘‘Order
Approving Proposed Rule Change to
Eliminate the Offset of [NSCC’s]
Obligations with Institutional Delivery
Transactions that Settle at The
Depository Trust Company for the
Purpose of Calculating Its Clearing Fund
Under Procedure XV of Its Rules &
Procedures’’ (File No. SR–NSCC–2012–
10).24
IV. Conclusion
It is therefore noticed, pursuant to
Section 806(e)(1)(I) of the Clearing
Supervision Act,25 that the Commission
does not object to the proposed rule
change described in the Advance Notice
(File No. SR–NSCC–2012–810) and that
NSCC be and hereby is authorized to
implement the proposed rule change as
of the date of this notice or the date of
the ‘‘Order Approving Proposed Rule
Change to Eliminate the Offset of
[NSCC’s] Obligations with Institutional
Delivery Transactions that Settle at The
Depository Trust Company for the
Purpose of Calculating Its Clearing Fund
Under Procedure XV of Its Rules &
Procedures’’ (File No. SR–NSCC–2012–
10),26 whichever is later.
By the Commission.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2013–08306 Filed 4–9–13; 8:45 am]
BILLING CODE 8011–01–P
17 17
18 17
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Sfmt 9990
23 See
Lek Letters, supra note 3.
Release No. 34–69302 (Apr. 4, 2013).
25 12 U.S.C. 5465(e)(1)(I).
26 Release No. 34–69302 (Apr. 4, 2013).
24 See
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Agencies
[Federal Register Volume 78, Number 69 (Wednesday, April 10, 2013)]
[Notices]
[Pages 21433-21435]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2013-08306]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-69301; File No. SR-NSCC-2012-810]
Self-Regulatory Organizations; National Securities Clearing
Corporation; Notice of No Objection to Advance Notice Filing to
Eliminate the Offset of Its Obligations With Institutional Delivery
Transactions That Settle at The Depository Trust Company for the
Purpose of Calculating Its Clearing Fund Under Procedure XV of Its
Rules & Procedures
April 4, 2013.
I. Introduction
On December 18, 2012, National Securities Clearing Corporation
(``NSCC'') filed with the Securities and Exchange Commission
(``Commission'') advance notice SR-NSCC-2012-810 (``Advance Notice'')
pursuant to Section 806(e) of Title VIII of the Dodd-Frank Wall Street
Reform and Consumer Protection Act (``Dodd-Frank Act''),\1\ entitled
the Payment, Clearing, and Settlement Supervision Act of 2010
(``Clearing Supervision Act'' or ``Title VIII'') and Rule 19b-4(n) of
the Securities Exchange Act of 1934 (``Exchange Act''). The Advance
Notice was published in the Federal Register on January 17, 2013.\2\
The Commission received two comment letters to the Advance Notice from
one commenter.\3\ NSCC responded to both comment letters.\4\ This
publication serves as notice of no objection to the Advance Notice.
---------------------------------------------------------------------------
\1\ Dodd-Frank Wall Street Reform and Consumer Protection Act,
Public Law 111-203, 124 Stat. 1376 (2010).
\2\ Release No. 34-68621 (Jan. 10, 2013), 78 FR 3960 (Jan. 17,
2013). NSCC also filed a proposed rule change pursuant to Section
19(b)(1) of the Exchange Act on December 17, 2012 seeking Commission
approval to permit NSCC to change its rules to reflect the proposed
change described herein. The Commission published notice of the
proposed rule change on December 28, 2012. Release No. 34-68549
(Dec. 28, 2012), 78 FR 792 (Jan. 4, 2013). The Commission extended
the period of review of the proposed rule change on February 5,
2013. Release No. 34-68829 (Feb. 5, 2013), 78 FR 9751 (Feb. 11,
2013).
\3\ Comment Letter from Lek Securities Corporation dated January
25, 2013 (https://sec.gov/comments/sr-nscc-2012-810/nscc2012810-1.pdf), and Comment Letter from Lek Securities Corporation dated
March 18, 2013 (https://sec.gov/comments/sr-nscc-2012-810/nscc2012810-3.pdf) (collectively, the ``Lek Letters'').
\4\ Response Letter from NSCC dated February 22, 2013 (https://sec.gov/comments/sr-nscc-2012-810/nscc2012810-2.pdf), and Response
Letter from NSCC dated March 21, 2013 (https://sec.gov/comments/sr-nscc-2012-810/nscc2012810-4.pdf).
---------------------------------------------------------------------------
II. Analysis
NSCC filed the Advance Notice to permit it to make rule changes to
its Rules & Procedures (``Rules'') designed to eliminate the offset of
NSCC obligations with institutional delivery (``ID'') transactions that
settle at The Depository Trust Company (``DTC'') for the purpose of
calculating the NSCC clearing fund (``Clearing Fund'') under Procedure
XV of its Rules, as discussed below.
A. ID Offset
NSCC maintains a Clearing Fund to have on deposit assets sufficient
to satisfy losses that may otherwise be incurred by NSCC as the result
of the default of an NSCC member (``Member'') and the resulting
closeout of that Member's unsettled positions under NSCC's trade
guaranty. Each Member is required to contribute to the Clearing Fund
pursuant to a formula calculated daily. The Clearing Fund formula
accounts for a variety of risk factors through the application of a
number of components, including Value-at-Risk
[[Page 21434]]
(``VaR'') \5\ and Market Maker Domination (``MMDOM'').\6\
---------------------------------------------------------------------------
\5\ The VaR component of the Clearing Fund calculation is a core
component of the formula and is designed to calculate the amount of
money that may be lost on a portfolio over a given period of time
that is assumed necessary to liquidate the portfolio, within a given
level of confidence. See Release No. 34-68621 (Jan. 10, 2013), 78 FR
3960 (Jan. 17, 2013).
\6\ The MMDOM component of the Clearing Fund calculation is
charged to market makers or firms that clear for them. In
calculating the MMDOM, if the sum of the absolute values of net
unsettled positions in a security for which the firm in question
makes a market is greater than that firm's excess net capital, NSCC
may then charge the firm an amount equal to such excess or the sum
of each of the absolute values of the affected net unsettled
positions, or a combination of both. MMDOM operates to identify
concentration within a given CUSIP. See Release No. 34-68621 (Jan.
10, 2013), 78 FR 3960 (Jan. 17, 2013).
---------------------------------------------------------------------------
NSCC currently calculates the VaR and MMDOM components of a
Member's Clearing Fund required deposit after allowing for a Member's
net unsettled NSCC positions in a particular CUSIP to be offset by any
pending ID transactions settling at DTC in the same CUSIP, which have
been confirmed and/or affirmed through an institutional delivery system
acceptable to NSCC (``ID Offset'').\7\ ID Offset is based on the
assumption that in the event of a Member's insolvency NSCC will be able
to close out any trade for which there is a corresponding ID
transaction settling at DTC by completing that ID transaction.\8\
---------------------------------------------------------------------------
\7\ For purposes of the ID Offset, NSCC includes ID transactions
that are confirmed and/or affirmed on trade date, as well as ID
transactions affirmed one day after trade date and remain affirmed
through settlement date. See Release No. 34-68621 (Jan. 10, 2013),
78 FR 3960 (Jan. 17, 2013).
\8\ ID transactions are included in the ID Offset only if they
are on the opposite side of the market from the Member's net NSCC
position (i.e., only if they reduce the net position). See Release
No. 34-68621 (Jan. 10, 2013), 78 FR 3960 (Jan. 17, 2013).
---------------------------------------------------------------------------
B. Potential Inability To Complete ID Transactions
Generally, when NSCC ceases to act for a Member, it is obligated,
for those transactions that it has guaranteed, to pay for deliveries
made by non-defaulting Members that are due to the failed Member on the
day they are due. If NSCC is unable to complete the ID transactions as
contemplated by the current Clearing Fund calculation, then NSCC may
need to liquidate a portfolio that could be substantially different
than the portfolio for which NSCC collected its Clearing Fund, leaving
NSCC potentially under-collateralized and exposed to market risk.
A defaulting Member's pending ID transactions may not be completed
for a number of reasons. Completion of an ID transaction by its
institutional counterparty is voluntary because that counterparty is
not a Member, which means it is not bound by NSCC's Rules and is not
party to any legally binding contract with NSCC that requires it or its
custodian to complete the transaction. Moreover, based on news that a
Member may be in distress or insolvent, the institutional counterparty
or its investment adviser may take immediate market action with respect
to the ID transaction, in order to reduce its market risk, which
effectively eliminates the option for NSCC to complete the
transactions. Finally, ID transactions settle trade-by-trade between
the executing broker and the custodian; the netted ID positions used to
offset the NSCC position could be comprised of thousands of individual
trades with hundreds of different counterparties. In the event of a
Member default, it could be time consuming for NSCC to contact the
counterparties individually to get their agreement to complete the ID
transactions. Even if NSCC were to get all of the counterparties to
agree to complete the ID transactions, this could delay the prompt
closeout of the defaulter's open positions and possibly expose NSCC to
additional market risk in excess of the Clearing Fund.
Due to the risk that, in the event it ceases to act for a Member
with pending ID transactions, NSCC may be unable to complete the
pending ID transactions in the timeframe contemplated by its current
Clearing Fund calculations and, as a result, may have insufficient
margin in its Clearing Fund, as described above, NSCC will eliminate
the ID Offset calculation from the VaR and MMDOM components of a
Member's Clearing Fund requirement deposit.
C. Implementation Schedule
In order to mitigate the impact of this rule change on its Members,
NSCC will implement the changes set forth in the Advance Notice over an
18-month period. On a date no earlier than 10 days following notice to
Members by Important Notice (``Initial Implementation Date''), NSCC
will eliminate ID Offset from ID transactions that have only been
confirmed, but have not yet been affirmed. Beginning on a date
approximately 12 months from the Initial Implementation Date, and no
earlier than 10 days following notice to Members by Important Notice,
NSCC will eliminate from ID Offset all affirmed ID transactions that
have reached settlement date at the time the Clearing Fund calculations
are run. Three months later, or approximately 15 months following the
Initial Implementation Date, and on a date no earlier than 10 days
following notice to Members by Important Notice, NSCC will eliminate
from ID Offset all affirmed ID transactions that have reached either
settlement date or the day prior to settlement date. Finally, on a date
approximately 18 months following the Initial Implementation Date, and
no earlier than 10 days following notice to Members by Important
Notice, NSCC will eliminate ID Offset entirely for all ID transactions.
Members will be advised of each proposed implementation date through
issuance of NSCC Important Notices, which are publicly available at
www.dtcc.com.
III. Discussion
Although Title VIII does not specify a standard of review for an
Advance Notice, the stated purpose of Title VIII is instructive.\9\ The
stated purpose of Title VIII is to mitigate systemic risk in the
financial system and promote financial stability by, among other
things, promoting uniform risk management standards for systemically-
important financial market utilities (``FMUs'') and providing an
enhanced role for the Federal Reserve Board in the supervision of risk
management standards for systemically-important FMUs.\10\
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\9\ 12 U.S.C. 5461(b).
\10\ Id.
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Section 805(a)(2) of the Clearing Supervision Act \11\ authorizes
the Commission to prescribe risk management standards for the payment,
clearing, and settlement activities of designated clearing entities and
financial institutions engaged in designated activities for which it is
the supervisory agency or the appropriate financial regulator. Section
805(b) of the Clearing Supervision Act \12\ states that the objectives
and principles for the risk management standards prescribed under
Section 805(a) shall be to:
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\11\ 12 U.S.C. 5464(a)(2).
\12\ 12 U.S.C. 5464(b).
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Promote robust risk management;
promote safety and soundness;
reduce systemic risks; and
support the stability of the broader financial system.
The Commission adopted risk management standards under Section
805(a)(2) of the Clearing Supervision Act on October 22, 2012
(``Clearing Agency Standards'').\13\ The Clearing Agency Standards
became effective on January 2, 2013 and require clearing agencies that
perform central counterparty (``CCP'') services to establish,
implement, maintain, and
[[Page 21435]]
enforce written policies and procedures that are reasonably designed to
meet certain minimum requirements for their operations and risk
management practices on an ongoing basis.\14\ As such, it is
appropriate for the Commission to review Advance Notices against these
risk management standards that the Commission promulgated under Section
805(a) and the objectives and principles of these risk management
standards as described in Section 805(b).
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\13\ Release No. 34-68080 (Oct. 22, 2012), 77 FR 66219 (Nov. 2,
2012).
\14\ The Clearing Agency Standards are substantially similar to
the risk management standards established by the Board of Governors
of the Federal Reserve System (``Board of Governors'') governing the
operations of designated FMUs that are not clearing entities and
financial institutions engaged in designated activities for which
the Commission or the Commodity Futures Trading Commission is the
Supervisory Agency. See Financial Market Utilities, 77 FR 45907
(Aug. 2, 2012).
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As a CCP, NSCC occupies an important role in the securities
settlement system by interposing itself between counterparties to
financial transactions, thereby reducing certain risks faced by Members
and contributing to global financial stability. In this role, however,
NSCC is necessarily subject to certain risks in the event of the
default of a Member.
NSCC's proposal to eliminate ID Offsets, as described above, is
designed to help mitigate the risk that NSCC will be under-
collateralized if it ceases to act for a defaulting Member and is
unable to complete the offsetting ID transactions in the time currently
contemplated by its Clearing Fund calculation. Consistent with Section
805(a), the Commission believes this proposal promotes robust risk
management, as well as the safety and soundness of NSCC's operations,
while reducing systemic risks and supporting the stability of the
broader financial system, by improving NSCC's risk management systems
in preparation for a possible Member default via a more accurate
representation of risk in its Clearing Fund calculation. As discussed
above, NSCC's calculation of its Clearing Fund margin will be more
accurate in that it will not include an assumption of trade closeouts
following a Member insolvency with respect to trades for which there is
a corresponding ID transaction.
Additionally, Commission Rule 17Ad-22(b)(1) regarding measurement
and management of credit exposure,\15\ adopted as part of the Clearing
Agency Standards,\16\ requires a CCP to establish, implement, maintain
and enforce written policies and procedures reasonably designed to
measure its credit exposures to its participants at least once a day
and limit its exposures to potential losses from defaults by its
participants under normal market conditions so that the operations of
the CCP would not be disrupted and non-defaulting participants would
not be exposed to losses that they cannot anticipate or control.\17\
Here, as described in detail above, NSCC's proposal to eliminate ID
Offsets should help to limit its exposure and non-defaulting members'
exposure to potential losses from a defaulting Member, while minimizing
disruption to its CCP operations, by more accurately reflecting its
risks in the calculation of its Clearing Fund margin.
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\15\ 17 CFR 240.17Ad-22(b)(1).
\16\ Release No. 34-68080 (Oct. 22, 2012), 77 FR 66219 (Nov. 2,
2012).
\17\ 17 CFR 240.17Ad-22(b)(1).
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Furthermore, Commission Rules 17Ad-22(d)(4) regarding
identification and mitigation of operational risk,\18\ and 17Ad-
22(d)(11) regarding default procedures,\19\ also both adopted as part
of the Clearing Agency Standards,\20\ require that registered clearing
agencies ``establish, implement, maintain and enforce written policies
and procedures reasonably designed to, as applicable: * * * Identify
sources of operational risk and minimize them through the development
of appropriate systems, controls, and procedures * * * '',\21\ and `` *
* * establish default procedures that ensure that the clearing agency
can take timely action to contain losses and liquidity pressures and to
continue meeting its obligations in the event of a participant
default,\22\ respectively. Here, as described in detail above, the
elimination of ID Offsets should help NSCC better minimize settlement
risks and better ensure that it can contain losses and liquidity
pressures, and meet its obligations in a timely fashion, by more
accurately accounting for those risks in a Clearing Fund calculation
that is designed to satisfy potential losses in a timely manner.
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\18\ 17 CFR 240.17Ad-22(d)(4).
\19\ 17 CFR 240.17Ad-22(d)(11).
\20\ Release No. 34-68080 (Oct. 22, 2012), 77 FR 66219 (Nov. 2,
2012).
\21\ 17 CFR 240.17Ad-22(d)(4).
\22\ 17 CFR 240.17Ad-22(d)(11).
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In its assessment of the Advance Notice, the Commission assessed
whether the issues raised by the Lek Letters relate to the level or
nature of risks presented by NSCC's proposal, which is designed to
mitigate risks to NSCC, as discussed above. After evaluating NSCC's
responses to the Lek Letters, the Commission believes that the issues
raised in the Lek Letters relate to the potential competitive effects
of NSCC's proposal, not the level or nature of risks presented by
it.\23\ As such, the issues raised by the Lek Letters are not
considered within the context of this Notice of No Objection to the
Advance Notice under Title VIII; rather, they are considered within an
analysis of the proposal's consistency with Section 17A of the Exchange
Act and the applicable rules and regulations thereunder, which the
Commission did in its ``Order Approving Proposed Rule Change to
Eliminate the Offset of [NSCC's] Obligations with Institutional
Delivery Transactions that Settle at The Depository Trust Company for
the Purpose of Calculating Its Clearing Fund Under Procedure XV of Its
Rules & Procedures'' (File No. SR-NSCC-2012-10).\24\
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\23\ See Lek Letters, supra note 3.
\24\ See Release No. 34-69302 (Apr. 4, 2013).
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IV. Conclusion
It is therefore noticed, pursuant to Section 806(e)(1)(I) of the
Clearing Supervision Act,\25\ that the Commission does not object to
the proposed rule change described in the Advance Notice (File No. SR-
NSCC-2012-810) and that NSCC be and hereby is authorized to implement
the proposed rule change as of the date of this notice or the date of
the ``Order Approving Proposed Rule Change to Eliminate the Offset of
[NSCC's] Obligations with Institutional Delivery Transactions that
Settle at The Depository Trust Company for the Purpose of Calculating
Its Clearing Fund Under Procedure XV of Its Rules & Procedures'' (File
No. SR-NSCC-2012-10),\26\ whichever is later.
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\25\ 12 U.S.C. 5465(e)(1)(I).
\26\ Release No. 34-69302 (Apr. 4, 2013).
By the Commission.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2013-08306 Filed 4-9-13; 8:45 am]
BILLING CODE 8011-01-P