Self-Regulatory Organizations; International Securities Exchange, LLC; Order Granting Approval of Proposed Rule Change, as Modified by Amendment No. 1, to More Specifically Address the Number and Size of Counterparties to a Qualified Contingent Cross Order, 19680-19683 [2014-07892]
Download as PDF
19680
Federal Register / Vol. 79, No. 68 / Wednesday, April 9, 2014 / Notices
At any time within 60 days of the
filing of the proposed rule change, the
Commission summarily may
temporarily suspend 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. If the
Commission takes such action, the
Commission shall institute proceedings
to determine whether the proposed rule
should be approved or disapproved.
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:
TKELLEY on DSK3SPTVN1PROD with NOTICES
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
CBOE–2014–033 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–1090.
All submissions should refer to File
Number SR–CBOE–2014–033. This file
number should be included on the
subject line if email 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 Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
efficiency, competition, and capital formation. See
15 U.S.C. 78c(f).
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17:54 Apr 08, 2014
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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–CBOE–
2014–033 and should be submitted on
or before April 30, 2014.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.12
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–07887 Filed 4–8–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–71863; File No. SR–ISE–
2013–72]
Self-Regulatory Organizations;
International Securities Exchange,
LLC; Order Granting Approval of
Proposed Rule Change, as Modified by
Amendment No. 1, to More Specifically
Address the Number and Size of
Counterparties to a Qualified
Contingent Cross Order
April 3, 2014.
I. Introduction
On December 18, 2013, the
International Securities Exchange, LLC
(the ‘‘Exchange’’ or the ‘‘ISE’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (the ‘‘Act’’),1 and
Rule 19b–4 thereunder,2 a proposed rule
change notice to amend Rules 504
(Series of Options Contracts Open for
Trading) and 715 (Types of Orders) to
more specifically address the number
and size of counterparties to a Qualified
Contingent Cross Order (‘‘QCC Order’’).
The proposed rule change was
published for comment in the Federal
Register on January 7, 2014.3 On
February 18, 2014, the Commission
extended the time period for
Commission action to April 7, 2014.4
The Commission received three
comment letters on the proposal.5 On
12 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 See Securities Exchange Act Release No. 71208
(December 31, 2013), 79 FR 0881 (January 7, 2014).
4 See Securities Exchange Act Release No. 71560
(February 18, 2014), 79 FR 10218 (February 24,
2014).
5 See letters to Elizabeth M. Murphy, Secretary,
Commission, from Janet McGuiness, Executive Vice
President, NYSE Euronext, dated March, 11, 2014
(‘‘NYSE Letter’’), Darren Story, CFA, dated March
1 15
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April 2, 2014, the Exchange responded
to the comment letters.6 Additionally,
on April 2, 2014, the Exchange
submitted an amendment to the
proposed rule change.7 This order
approves the proposed rule change, as
modified by Amendment No. 1.
II. Background
As originally approved on ISE, a QCC
Order was required to be comprised of
an order to buy or sell at least 1,000
contracts that is identified as being part
of a qualified contingent trade (‘‘QCT’’),
coupled with a contra-side order to buy
or sell an equal number of contracts.8
Following discussions regarding the
QCC Order with Commission staff, the
Exchange learned that Commission staff
interpreted the Exchange’s rules relating
to QCC Orders to permit only a single
order on the originating side of the QCC
Order and a single order on the contraside, with each such order comprised of
a single party and meeting the 1,000
contract minimum size requirement. In
a Regulatory Information Circular
published by the Exchange on
November 25, 2013, the Exchange
explained that it had always interpreted
the QCC Order definition to mean that
a QCC Order must be comprised of an
unsolicited order to buy or sell at least
1,000 contracts that is identified as part
of a QCT, coupled with a contra-side
order that could be made up of multiple
orders, each of which could be less than
1,000 contracts.9 ISE also stated that it
would seek to amend its rules governing
QCC Orders to codify its interpretation
in its rules.10
On December 18, 2013, the Exchange
filed two proposed rule changes with
the Commission. In addition to this
filing, the Exchange filed SR–ISE–2013–
71, a proposed rule change for
immediate effectiveness to amend the
definition of a QCC Order such that it
must involve a single order for at least
1,000 contracts on the originating side,11
14, 2014 (‘‘Story Letter’’), and Doug Patterson, CCO,
CutlerGroup, LP, dated March 28, 2014 (‘‘Cutler
Letter’’).
6 See letter to Elizabeth M. Murphy, Secretary,
Commission, from Michael J. Simon, Secretary and
General Counsel, ISE, dated April 2, 2014 (‘‘ISE
Response’’).
7 The Commission notes that Amendment No. 1
is not subject to notice and comment because it
does not alter the substance of the proposed rule
change or raise any novel regulatory issues, but
rather describes how the Exchange surveils QCC
Orders. See Section III below.
8 See Securities Exchange Act Release No. 63955
(February 24, 2011), 76 FR 11533 (March 2, 2011)
(SR–ISE–2010–73) (‘‘Original QCC Approval
Order’’).
9 See ISE Regulatory Information Circular 2013–
022 (November 25, 2013).
10 Id.
11 In the case of Mini Options, the minimum size
is 10,000 contracts.
E:\FR\FM\09APN1.SGM
09APN1
Federal Register / Vol. 79, No. 68 / Wednesday, April 9, 2014 / Notices
but may consist of multiple orders on
the opposite, contra-side, so long as
each contra-side order is for at least
1,000 contracts.12 In that filing, the
Exchange explained,
It was always the Exchange’s intent and
understanding when drafting the rule text
that a QCC Order could involve multiple
contra-parties of the QCC trade when the
originating QCC Order consisted of at least
1,000 contracts. However, the rule language
addressing the contra-side of a QCC Order is
drafted from the perspective of how the QCC
Order gets entered into the ISE system.
Specifically, the contra-side order to a QCC
Order will always be entered as a single
order, even if that order consists of multiple
contra-parties who are allocated their portion
of the trade in a post-trade allocation.
Notwithstanding the foregoing, the literal
wording of the current QCC Order rule could
result in a more limited interpretation of the
rule. Therefore, the Exchange now proposes
to make it clear that a QCC Order must
involve a single order for at least 1,000
contracts on the originating side, but that it
may consist of multiple orders on the
opposite, contra-side, so long as each of the
contra-side orders is for at least 1,000
contracts.13
TKELLEY on DSK3SPTVN1PROD with NOTICES
III. Description of the Proposed Rule
Change
In this filing, the Exchange proposes
to remove the requirement that contraside orders of QCC Orders be for at least
1,000 contracts each, thus permitting
multiple contra-side orders on a QCC
Order with a total number of contracts
equaling the originating order size, but
without any size requirement for such
contra-side orders. Under this proposal,
the requirements for the QCC Order’s
originating order remain unchanged,
and thus would require the originating
order to be a single order for a single
party of at least 1,000 contracts, and the
QCC Order must also continue to satisfy
all other requirements of a QCC Order
under the Exchange’s rules.
The Exchange believes that removing
the size limit placed on contra-parties to
QCC Orders may increase liquidity and,
potentially, improve the prices at which
QCC Orders get executed, as the
Exchange states that the ability for
market participants to provide liquidity
in response to large sized orders is
directly proportional to the size and
associated risk of the resulting position.
As support, the Exchange states that
smaller sized trades are often done at a
better price than larger sized trades,
which convey more risk. The Exchange
believes that the ability to pool together
multiple market participants to
12 See Securities Exchange Act Release No. 71183
(December 24, 2013), 78 FR 79721 (December 31,
2013) (SR–ISE–2013–71).
13 Id. at 79722.
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participate on the contra-side of a trade
for any size, as opposed to only
allowing market participants to
participate for a minimum of 1,000
contracts, would have a direct and
positive impact on the ability of those
market participants to provide the best
price as they compete to participate in
the order without being compelled to
provide liquidity with a large minimum
quantity. Further, the Exchange states
that allowing several participants to
offer liquidity to a QCC Order serves to
ensure that the order receives the best
possible price available in the market
and argues that restricting interaction to
only participants who are willing to
trade a minimum of 1,000 contracts
simply guarantees an inferior price
because a trade will be limited to few
liquidity providers who are taking on
more risk as opposed to multiple
liquidity providers being able to share
the overall risk and trade at a better
price.
In the proposal, the Exchange stresses
that the concern has always been and
should continue to be for the originating
order–i.e., the unsolicited part of the
order that is seeking liquidity–and not
the professional responders and
providers of liquidity. The Exchange
believes that allowing smaller orders to
participate on the other side (i.e., contraside) of QCC Orders not only provides
the best price and opportunity for a
trade to occur in a tight and liquid
market, but ensures that the highest
possible number of liquidity providers
are able to participate, and states that
limiting participation only to liquidity
providers who are willing to participate
on the trade for 1,000 contracts
conversely could result in an inferior
price by shutting out some participants
due to the large size and thereby
minimizing the opportunity for
competition and price improvement.
In Amendment No. 1, the Exchange
represents that it tracks and monitors
QCC Orders to determine which is the
originating/agency side of the order and
which is the contra-side(s) of the order
to ensure that Members are complying
with the minimum 1,000 contract size
limitation on the originating/agency
side of the QCC Order. The Exchange
states that it checks to see if Members
are aggregating multiple orders to meet
the 1,000 contract minimum on the
originating/agency side of the trade in
violation of the requirements of the rule.
The rule requires that the originating/
agency side of the trade consist of one
party who is submitting a QCC Order for
at least 1,000 contracts. The Exchange
represents that it enforces compliance
with this portion of the rule by checking
to see if a Member breaks up the
PO 00000
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Fmt 4703
Sfmt 4703
19681
originating/agency side of the order in a
post trade allocation to different
clearing firms, allocating less than 1,000
contracts to a party or multiple parties.
For example, a Member enters a QCC
Order into the system for 1,500
contracts and receives an execution.
Subsequent to the execution, the
Member allocates the originating/agency
side of the order to two different
clearing firms on a post trade allocation
basis, thereby allocating 500 contracts to
one clearing firm and 1,000 contracts to
another clearing firm. The Exchange
states that this type of transaction would
not meet the requirements of a QCC
Order under the current rule.
With regard to order entry, the
Exchange clarifies that a Member must
mark the originating/agency side as the
first order in the system and the contraside(s) as the second. The Exchange
states that it monitors order entries to
ensure that Members are properly
entering QCC Orders into the system.
IV. Summary of Comment Letters and
ISE’s Response to Comments
The Commission received three
comment letters opposing the proposed
rule change.14 As described in more
detail below, the commenters primarily
expressed concerns about QCC Orders
generally, as opposed to the rule
modifications proposed by the
Exchange.
In the NYSE Letter, the commenter
does not raise new concerns, but rather
concurs with the issues expressed in a
comment letter submitted by the
Chicago Board Options Exchange
(‘‘CBOE’’) in response to a separate
filing by another exchange—SR–Phlx–
2013–106–which proposed to permit
multiple contra-side parties on either
side of a QCC Order and eliminate the
minimum size requirement, but which
was subsequently withdrawn. The
commenter asserts that CBOE’s
comments are applicable to the instant
proposal.15 Specifically, this commenter
echoes CBOE’s belief that QCC trades,
by their nature, harm options markets
by enabling market participants to effect
listed options transactions without
exposing their order to the market—
hampering liquidity by reduced
transparency and eliminating the
possibility of price improvement.16 In
14 See
supra note 5.
letter to Elizabeth M. Murphy, Secretary,
Commission, from Angelo Evangelou, Associate
General Counsel, Chicago Board Options Exchange,
Incorporated, dated December 13, 2013 (‘‘CBOE
Letter’’). SR–Phlx–2013–106 was withdrawn on
February 3, 2014. CBOE did not submit a comment
letter on this filing.
16 See NYSE Letter at 1; see also CBOE Letter at
2–3.
15 See
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19682
Federal Register / Vol. 79, No. 68 / Wednesday, April 9, 2014 / Notices
addition, the commenter concurs with
CBOE’s conclusion that an expansion of
the use of the QCC Order by reducing
the minimum size required to
participate in a QCC trade would
exacerbate the harm to the options
markets resulting from QCC trades.17
Another commenter to the instant
filing claims that market participants
use QCC Orders to disadvantage
customers and avoid due diligence
obligations.18 In support of this
contention, the commenter notes that
QCC Orders allow market participants
to execute the stock portion of a stock/
option order outside the NBBO,
resulting in inferior net execution prices
for customers.19 The commenter states
that such use of QCC Orders allows
orders to be effected which do not need
to adhere to best-executions on a net
cash basis to the detriment of customers,
and argues that requiring exposure of
orders would curtail this abuse.20
This commenter also argues that the
fee structure in place for QCC Orders
creates a conflict of interest among
market participants in that a rebate is
paid to executing brokers that initiate a
QCC Order while a fee is charged to the
counter-parties.21 The commenter
believes that the incentive to obtain the
rebate offered for QCC Orders can cause
brokers to ignore their responsibility to
obtain the best price on a trade and
mitigate unnecessary fees whenever
possible.22
The third commenter requested that
the Commission disapprove the
proposal, stating that the filing defies
the general principles that all orders be
exposed to as many sources of liquidity
as possible.23 The commenter believes
that without exposure there is no
incentive for market makers to display
liquidity, provide liquidity, or offer
price improvement, resulting in the
general public failing to receive the best
possible price on any order.24
In response to the comment letters,
ISE states that it does not believe that
the commenters raise any issues related
to removing the contra-party size
restriction for QCC Orders as
proposed.25 Further, ISE notes that the
issues raised by the commenters were
well vetted by the Commission prior to
the Original QCC Approval Order and
therefore does not believe that the
TKELLEY on DSK3SPTVN1PROD with NOTICES
17 See
NYSE Letter at 1; see also CBOE Letter at
3.
18 See
Story Letter at 1.
Story Letter at 1–2.
20 See id.
21 See Story Letter at 3.
22 See id.
23 See Cutler Letter at 1.
24 See id.
25 See ISE Response at 1.
19 See
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commenters raise new issues relevant to
the current proposal.26
V. Discussion and Commission Findings
The Commission finds that the
proposed rule change is consistent with
the requirements of the Act and the
rules and regulations thereunder
applicable to a national securities
exchange.27 Specifically, the
Commission finds that the proposed
rule change is consistent with Section
6(b)(5) of the Act,28 which requires,
among other things, that the rules of a
national securities exchange be
designed to prevent fraudulent and
manipulative acts and practices, 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.
In its original approval of the QCC
Order for ISE, the Commission noted the
benefits of contingent trades to investors
and the market as a whole.29
Specifically, in providing for an
exemption from certain requirements of
Regulation NMS for QCTs, the
Commission recognized that contingent
trades can be ‘‘useful trading tools for
investors and other market participants,
particularly those who trade the
securities of issuers involved in
mergers, different classes of shares of
the same issuer, convertible securities,
and equity derivatives such as options’’
[italics added].30 In the Original QCC
Approval Order, the Commission also
reiterated the finding from its Original
QCT Exemption that those transactions
that meet the specified requirements of
the QCT exemption could be of benefit
to the market as a whole and a
contribution to the efficient functioning
of the securities markets and the price
discovery process.31
In analyzing ISE’s original QCC Order,
the Commission weighed the benefits of
QCTs, of which QCC Orders are a
subset, against the benefits provided by
the general requirement for exposure of
orders in the options markets.32 In the
Original QCC Approval Order, the
Commission stated that the QCC Order
26 Id.
27 In approving the proposed rule change, the
Commission has considered the proposed rule’s
impact on efficiency, competition, and capital
formation. See 15 U.S.C.
28 15 U.S.C. 78f(b)(5).
29 See Original QCC Approval Order, supra note
8, at 11540–11541.
30 See Securities Exchange Act Release No. 54389
(August 31, 2006, 71 FR 52829, 52830 (September
7, 2006) (‘‘Original QCT Exemption’’).
31 See Original QCC Approval Order, supra note
8 at text accompanying footnote 115.
32 Id. at 11541.
PO 00000
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Fmt 4703
Sfmt 4703
strikes an appropriate balance for the
options market in that it is narrowly
drawn and establishes a limited
exception to the general principle of
exposure and retains the general
principle of customer priority in the
options markets because QCC Orders are
required to be: (1) Part of a QCT under
Regulation NMS; (2) for at least 1,000
contracts; (3) executed at a price at or
between the national best bid or offer;
and (4) cancelled if there is a Priority
Customer Order on ISE’s limit order
book at the same price.33 The
Commission specifically noted that a
QCC Order must not only be part of a
QCT by satisfying each of the six
underlying requirements of the NMS
QCT Exemption, but must be for a
minimum size of 1,000 contracts, and
that these requirements provide another
limit to its use by ensuring only
transactions of significant size may avail
themselves of this order type.34 Given
the requirements for QCC Orders, the
Commission also noted its belief that
those customers participating in QCC
Orders would likely be sophisticated
investors who should understand that
their order would not be exposed for
potential price improvement, and that
these customers should be able to
themselves assess whether the net
prices they are receiving for their QCC
Order are competitive.35 The
Commission also specifically noted that
broker-dealers are subject to a duty of
best execution for their customers’
orders, and that duty does not change
for QCC Orders.36
In considering ISE’s proposal to
eliminate the minimum size
requirement for the contra-side of QCC
Orders, the Commission has again
weighed whether the benefits of this
order type, as proposed to be modified,
to investors and the market outweigh
the benefits provided by the general
requirement for exposure of orders in
the options markets. The Commission
notes that ISE’s proposal does not
change the requirements that a QCC
Order must be: (1) Part of a QCT under
Regulation NMS; (2) executed at a price
at or between the national best bid or
offer; and (3) cancelled if there is a
Priority Customer Order on ISE’s limit
order book. In addition, the changes to
QCC Orders under SR–ISE–2013–7137
permit multiple contra-side orders for
QCC Orders, so long as each such
contra-side order is for at least 1,000
contracts. In this filing, the only
33 Id.
34 Id.
35 Id.
36 Id.
37 See
E:\FR\FM\09APN1.SGM
supra note 12.
09APN1
TKELLEY on DSK3SPTVN1PROD with NOTICES
Federal Register / Vol. 79, No. 68 / Wednesday, April 9, 2014 / Notices
requirement that ISE proposes to change
is to eliminate the requirement that
contra-side orders of a QCC Order be for
at least 1,000 contracts.
The Commission believes that this
change to the minimum size
requirement for the contra-side(s) of
QCC Orders is narrowly tailored and,
significantly, the Exchange’s rule text
clearly requires that the originating side
of a QCC Order must be comprised of
a single order (i.e., a single party) for at
least 1,000 contracts. The Commission
believes that retention of the
requirements that the original side be
comprised of a single order from a
single party and that such single order
be for at least 1,000 contracts will
continue to ensure that sophisticated
investors, who are aware that their
orders will not be exposed for price
improvement, and who themselves
should be able to assess whether the net
prices for their QCC Orders are
competitive, will initiate QCC Orders in
an effort to effectuate a complex
transaction that complies with all the
requirements of the QCC Order.
The proposed rule change will allow
multiple contra-parties with order sizes
of less than 1,000 to aggregate their
interest to pair against the originating
side of a QCC Order to facilitate the
execution of the QCC Order. The
Commission believes that allowing
smaller orders from multiple parties to
participate on the contra-side of QCC
Orders may provide a better opportunity
for QCC Orders to be executed and,
potentially, at better prices. The
Commission acknowledges that limiting
participation on the contra-side of a
QCC Order only to liquidity providers
who are willing to participate on the
trade for 1,000 contracts, could result in
less interest in the trade than if contraside orders were not required to meet
the 1,000 contract minimum, potentially
diminishing the opportunity for
competition and price improvement.
The Commission believes that the
proposed modification to the definition
of QCC Order is narrowly drawn in that
it does not impact the fundamental
aspects of this order type, and merely
permits QCC Orders to include multiple
contra-parties, regardless of size on the
contra-side, while preserving the 1,000
contract minimum on the originating
side of a QCC Order. Accordingly, the
Commission finds the proposed rule
consistent with the Act.
The issues raised in the comment
letters do not specifically address the
changes proposed in the instant filing,
and the Commission agrees with ISE
that the commenters on the proposed
rule change do not present any
arguments that were not considered
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17:54 Apr 08, 2014
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fully in Original QCC Approving Order
(i.e., QCC Orders harm the market by
not requiring exposure), or are outside
the scope of this proposal (i.e., fee
rebates for initiating QCC Orders create
a conflict of interest for brokers).38
The Commission notes that, given the
differing requirements as between the
originating side and contra-side for QCC
Orders, it is essential that the Exchange
be able to clearly identify and monitor—
throughout the life of a QCC Order,
beginning at time of order entry on the
Exchange through the post-trade
allocation process—each side of the
QCC Order and ensure that the
requirements of the order type are being
satisfied including, importantly, those
relating to the originating side. The
Commission believes this to be critical
so that the Exchange can ensure that
market participants are not able to
circumvent the requirements of the QCC
Order (as amended by this proposed
rule change), each of which the
Commission continues to believe are
critical to ensuring that the QCC Order
is narrowly drawn.39 Further, the
Commission notes that, in Amendment
No. 1, the Exchange has made certain
representations regarding its
enforcement and surveillance of its
Members’ use of QCC Orders, including,
for example, not only at the time of
order entry, but through the post-trade
allocation process as well.
For the foregoing reasons, the
Commission believes that the proposed
rule change is consistent with the Act.
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act 40 that the
proposed rule change (SR–ISE–2013–
72), as modified by Amendment No.1,
be, and it hereby is, approved.
38 In addition, the Commission again emphasizes,
as it did in the Original QCC Approval Order, that
broker-dealers are subject to a duty of best
execution for their customers’ orders, and that duty
does not change for QCC Orders. See supra note 36.
39 The Commission expects the Exchange to have
the capability to enable it to surveil that such
requirements are being met. Though the Exchange
has stated its ability to do so in Amendment No.
1, if the Exchange is not able to have such
monitoring at any point in time, the Commission
would expect the Exchange to take other steps to
ensure that the QCC Order cannot be improperly
used. For example, if the Exchange were not able
to identify and monitor which side of a QCC Order
is the originating order, the Commission would
expect that it would require that both sides of the
QCC Order meet the more stringent requirements of
the originating side, i.e., that it be for a single order
for at least 1,000 contracts.
40 15 U.S.C. 78s(b)(2).
PO 00000
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19683
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.41
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–07892 Filed 4–8–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–71853; File No. SR–CME–
2014–11]
Self-Regulatory Organizations;
Chicago Mercantile Exchange Inc.;
Notice of Filing and Immediate
Effectiveness of Proposed Rule
Change Regarding Clarifications to Its
Chapter 7 Delivery Rules
April 3, 2014.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Exchange Act’’ or ‘‘Act’’),1 and Rule
19b–4 thereunder,2 notice is hereby
given that on March 27, 2014, Chicago
Mercantile Exchange Inc. (‘‘CME’’) filed
with the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change described in Items
I and II, below, which Items have been
prepared primarily by CME. CME filed
the proposal pursuant to Section
19(b)(3)(A)(i) of the Act 3 and Rule 19b–
4(f)(1) 4 thereunder so that the proposal
was effective upon filing with the
Commission. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
CME is filing the proposed rule
change that is limited to its business as
a derivatives clearing organization.
More specifically, the proposed rule
change would clarify certain aspects of
CME’s Chapter 7 rules with respect to
deliveries of futures products.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission,
CME included statements concerning
the purpose and basis for the proposed
rule change and discussed any
comments it received on the proposed
rule change. The text of these statements
41 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 15 U.S.C. 78s(b)(3)(A)(i).
4 17 CFR 240.19b–4(f)(1).
1 15
E:\FR\FM\09APN1.SGM
09APN1
Agencies
[Federal Register Volume 79, Number 68 (Wednesday, April 9, 2014)]
[Notices]
[Pages 19680-19683]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-07892]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-71863; File No. SR-ISE-2013-72]
Self-Regulatory Organizations; International Securities Exchange,
LLC; Order Granting Approval of Proposed Rule Change, as Modified by
Amendment No. 1, to More Specifically Address the Number and Size of
Counterparties to a Qualified Contingent Cross Order
April 3, 2014.
I. Introduction
On December 18, 2013, the International Securities Exchange, LLC
(the ``Exchange'' or the ``ISE'') filed with the Securities and
Exchange Commission (``Commission''), pursuant to Section 19(b)(1) of
the Securities Exchange Act of 1934 (the ``Act''),\1\ and Rule 19b-4
thereunder,\2\ a proposed rule change notice to amend Rules 504 (Series
of Options Contracts Open for Trading) and 715 (Types of Orders) to
more specifically address the number and size of counterparties to a
Qualified Contingent Cross Order (``QCC Order''). The proposed rule
change was published for comment in the Federal Register on January 7,
2014.\3\ On February 18, 2014, the Commission extended the time period
for Commission action to April 7, 2014.\4\ The Commission received
three comment letters on the proposal.\5\ On April 2, 2014, the
Exchange responded to the comment letters.\6\ Additionally, on April 2,
2014, the Exchange submitted an amendment to the proposed rule
change.\7\ This order approves the proposed rule change, as modified by
Amendment No. 1.
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 71208 (December 31,
2013), 79 FR 0881 (January 7, 2014).
\4\ See Securities Exchange Act Release No. 71560 (February 18,
2014), 79 FR 10218 (February 24, 2014).
\5\ See letters to Elizabeth M. Murphy, Secretary, Commission,
from Janet McGuiness, Executive Vice President, NYSE Euronext, dated
March, 11, 2014 (``NYSE Letter''), Darren Story, CFA, dated March
14, 2014 (``Story Letter''), and Doug Patterson, CCO, CutlerGroup,
LP, dated March 28, 2014 (``Cutler Letter'').
\6\ See letter to Elizabeth M. Murphy, Secretary, Commission,
from Michael J. Simon, Secretary and General Counsel, ISE, dated
April 2, 2014 (``ISE Response'').
\7\ The Commission notes that Amendment No. 1 is not subject to
notice and comment because it does not alter the substance of the
proposed rule change or raise any novel regulatory issues, but
rather describes how the Exchange surveils QCC Orders. See Section
III below.
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II. Background
As originally approved on ISE, a QCC Order was required to be
comprised of an order to buy or sell at least 1,000 contracts that is
identified as being part of a qualified contingent trade (``QCT''),
coupled with a contra-side order to buy or sell an equal number of
contracts.\8\ Following discussions regarding the QCC Order with
Commission staff, the Exchange learned that Commission staff
interpreted the Exchange's rules relating to QCC Orders to permit only
a single order on the originating side of the QCC Order and a single
order on the contra-side, with each such order comprised of a single
party and meeting the 1,000 contract minimum size requirement. In a
Regulatory Information Circular published by the Exchange on November
25, 2013, the Exchange explained that it had always interpreted the QCC
Order definition to mean that a QCC Order must be comprised of an
unsolicited order to buy or sell at least 1,000 contracts that is
identified as part of a QCT, coupled with a contra-side order that
could be made up of multiple orders, each of which could be less than
1,000 contracts.\9\ ISE also stated that it would seek to amend its
rules governing QCC Orders to codify its interpretation in its
rules.\10\
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\8\ See Securities Exchange Act Release No. 63955 (February 24,
2011), 76 FR 11533 (March 2, 2011) (SR-ISE-2010-73) (``Original QCC
Approval Order'').
\9\ See ISE Regulatory Information Circular 2013-022 (November
25, 2013).
\10\ Id.
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On December 18, 2013, the Exchange filed two proposed rule changes
with the Commission. In addition to this filing, the Exchange filed SR-
ISE-2013-71, a proposed rule change for immediate effectiveness to
amend the definition of a QCC Order such that it must involve a single
order for at least 1,000 contracts on the originating side,\11\
[[Page 19681]]
but may consist of multiple orders on the opposite, contra-side, so
long as each contra-side order is for at least 1,000 contracts.\12\ In
that filing, the Exchange explained,
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\11\ In the case of Mini Options, the minimum size is 10,000
contracts.
\12\ See Securities Exchange Act Release No. 71183 (December 24,
2013), 78 FR 79721 (December 31, 2013) (SR-ISE-2013-71).
It was always the Exchange's intent and understanding when
drafting the rule text that a QCC Order could involve multiple
contra-parties of the QCC trade when the originating QCC Order
consisted of at least 1,000 contracts. However, the rule language
addressing the contra-side of a QCC Order is drafted from the
perspective of how the QCC Order gets entered into the ISE system.
Specifically, the contra-side order to a QCC Order will always be
entered as a single order, even if that order consists of multiple
contra-parties who are allocated their portion of the trade in a
post-trade allocation. Notwithstanding the foregoing, the literal
wording of the current QCC Order rule could result in a more limited
interpretation of the rule. Therefore, the Exchange now proposes to
make it clear that a QCC Order must involve a single order for at
least 1,000 contracts on the originating side, but that it may
consist of multiple orders on the opposite, contra-side, so long as
each of the contra-side orders is for at least 1,000 contracts.\13\
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\13\ Id. at 79722.
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III. Description of the Proposed Rule Change
In this filing, the Exchange proposes to remove the requirement
that contra-side orders of QCC Orders be for at least 1,000 contracts
each, thus permitting multiple contra-side orders on a QCC Order with a
total number of contracts equaling the originating order size, but
without any size requirement for such contra-side orders. Under this
proposal, the requirements for the QCC Order's originating order remain
unchanged, and thus would require the originating order to be a single
order for a single party of at least 1,000 contracts, and the QCC Order
must also continue to satisfy all other requirements of a QCC Order
under the Exchange's rules.
The Exchange believes that removing the size limit placed on
contra-parties to QCC Orders may increase liquidity and, potentially,
improve the prices at which QCC Orders get executed, as the Exchange
states that the ability for market participants to provide liquidity in
response to large sized orders is directly proportional to the size and
associated risk of the resulting position. As support, the Exchange
states that smaller sized trades are often done at a better price than
larger sized trades, which convey more risk. The Exchange believes that
the ability to pool together multiple market participants to
participate on the contra-side of a trade for any size, as opposed to
only allowing market participants to participate for a minimum of 1,000
contracts, would have a direct and positive impact on the ability of
those market participants to provide the best price as they compete to
participate in the order without being compelled to provide liquidity
with a large minimum quantity. Further, the Exchange states that
allowing several participants to offer liquidity to a QCC Order serves
to ensure that the order receives the best possible price available in
the market and argues that restricting interaction to only participants
who are willing to trade a minimum of 1,000 contracts simply guarantees
an inferior price because a trade will be limited to few liquidity
providers who are taking on more risk as opposed to multiple liquidity
providers being able to share the overall risk and trade at a better
price.
In the proposal, the Exchange stresses that the concern has always
been and should continue to be for the originating order-i.e., the
unsolicited part of the order that is seeking liquidity-and not the
professional responders and providers of liquidity. The Exchange
believes that allowing smaller orders to participate on the other side
(i.e., contra-side) of QCC Orders not only provides the best price and
opportunity for a trade to occur in a tight and liquid market, but
ensures that the highest possible number of liquidity providers are
able to participate, and states that limiting participation only to
liquidity providers who are willing to participate on the trade for
1,000 contracts conversely could result in an inferior price by
shutting out some participants due to the large size and thereby
minimizing the opportunity for competition and price improvement.
In Amendment No. 1, the Exchange represents that it tracks and
monitors QCC Orders to determine which is the originating/agency side
of the order and which is the contra-side(s) of the order to ensure
that Members are complying with the minimum 1,000 contract size
limitation on the originating/agency side of the QCC Order. The
Exchange states that it checks to see if Members are aggregating
multiple orders to meet the 1,000 contract minimum on the originating/
agency side of the trade in violation of the requirements of the rule.
The rule requires that the originating/agency side of the trade consist
of one party who is submitting a QCC Order for at least 1,000
contracts. The Exchange represents that it enforces compliance with
this portion of the rule by checking to see if a Member breaks up the
originating/agency side of the order in a post trade allocation to
different clearing firms, allocating less than 1,000 contracts to a
party or multiple parties. For example, a Member enters a QCC Order
into the system for 1,500 contracts and receives an execution.
Subsequent to the execution, the Member allocates the originating/
agency side of the order to two different clearing firms on a post
trade allocation basis, thereby allocating 500 contracts to one
clearing firm and 1,000 contracts to another clearing firm. The
Exchange states that this type of transaction would not meet the
requirements of a QCC Order under the current rule.
With regard to order entry, the Exchange clarifies that a Member
must mark the originating/agency side as the first order in the system
and the contra-side(s) as the second. The Exchange states that it
monitors order entries to ensure that Members are properly entering QCC
Orders into the system.
IV. Summary of Comment Letters and ISE's Response to Comments
The Commission received three comment letters opposing the proposed
rule change.\14\ As described in more detail below, the commenters
primarily expressed concerns about QCC Orders generally, as opposed to
the rule modifications proposed by the Exchange.
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\14\ See supra note 5.
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In the NYSE Letter, the commenter does not raise new concerns, but
rather concurs with the issues expressed in a comment letter submitted
by the Chicago Board Options Exchange (``CBOE'') in response to a
separate filing by another exchange--SR-Phlx-2013-106-which proposed to
permit multiple contra-side parties on either side of a QCC Order and
eliminate the minimum size requirement, but which was subsequently
withdrawn. The commenter asserts that CBOE's comments are applicable to
the instant proposal.\15\ Specifically, this commenter echoes CBOE's
belief that QCC trades, by their nature, harm options markets by
enabling market participants to effect listed options transactions
without exposing their order to the market--hampering liquidity by
reduced transparency and eliminating the possibility of price
improvement.\16\ In
[[Page 19682]]
addition, the commenter concurs with CBOE's conclusion that an
expansion of the use of the QCC Order by reducing the minimum size
required to participate in a QCC trade would exacerbate the harm to the
options markets resulting from QCC trades.\17\
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\15\ See letter to Elizabeth M. Murphy, Secretary, Commission,
from Angelo Evangelou, Associate General Counsel, Chicago Board
Options Exchange, Incorporated, dated December 13, 2013 (``CBOE
Letter''). SR-Phlx-2013-106 was withdrawn on February 3, 2014. CBOE
did not submit a comment letter on this filing.
\16\ See NYSE Letter at 1; see also CBOE Letter at 2-3.
\17\ See NYSE Letter at 1; see also CBOE Letter at 3.
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Another commenter to the instant filing claims that market
participants use QCC Orders to disadvantage customers and avoid due
diligence obligations.\18\ In support of this contention, the commenter
notes that QCC Orders allow market participants to execute the stock
portion of a stock/option order outside the NBBO, resulting in inferior
net execution prices for customers.\19\ The commenter states that such
use of QCC Orders allows orders to be effected which do not need to
adhere to best-executions on a net cash basis to the detriment of
customers, and argues that requiring exposure of orders would curtail
this abuse.\20\
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\18\ See Story Letter at 1.
\19\ See Story Letter at 1-2.
\20\ See id.
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This commenter also argues that the fee structure in place for QCC
Orders creates a conflict of interest among market participants in that
a rebate is paid to executing brokers that initiate a QCC Order while a
fee is charged to the counter-parties.\21\ The commenter believes that
the incentive to obtain the rebate offered for QCC Orders can cause
brokers to ignore their responsibility to obtain the best price on a
trade and mitigate unnecessary fees whenever possible.\22\
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\21\ See Story Letter at 3.
\22\ See id.
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The third commenter requested that the Commission disapprove the
proposal, stating that the filing defies the general principles that
all orders be exposed to as many sources of liquidity as possible.\23\
The commenter believes that without exposure there is no incentive for
market makers to display liquidity, provide liquidity, or offer price
improvement, resulting in the general public failing to receive the
best possible price on any order.\24\
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\23\ See Cutler Letter at 1.
\24\ See id.
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In response to the comment letters, ISE states that it does not
believe that the commenters raise any issues related to removing the
contra-party size restriction for QCC Orders as proposed.\25\ Further,
ISE notes that the issues raised by the commenters were well vetted by
the Commission prior to the Original QCC Approval Order and therefore
does not believe that the commenters raise new issues relevant to the
current proposal.\26\
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\25\ See ISE Response at 1.
\26\ Id.
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V. Discussion and Commission Findings
The Commission finds that the proposed rule change is consistent
with the requirements of the Act and the rules and regulations
thereunder applicable to a national securities exchange.\27\
Specifically, the Commission finds that the proposed rule change is
consistent with Section 6(b)(5) of the Act,\28\ which requires, among
other things, that the rules of a national securities exchange be
designed to prevent fraudulent and manipulative acts and practices, 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.
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\27\ In approving the proposed rule change, the Commission has
considered the proposed rule's impact on efficiency, competition,
and capital formation. See 15 U.S.C.
\28\ 15 U.S.C. 78f(b)(5).
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In its original approval of the QCC Order for ISE, the Commission
noted the benefits of contingent trades to investors and the market as
a whole.\29\ Specifically, in providing for an exemption from certain
requirements of Regulation NMS for QCTs, the Commission recognized that
contingent trades can be ``useful trading tools for investors and other
market participants, particularly those who trade the securities of
issuers involved in mergers, different classes of shares of the same
issuer, convertible securities, and equity derivatives such as
options'' [italics added].\30\ In the Original QCC Approval Order, the
Commission also reiterated the finding from its Original QCT Exemption
that those transactions that meet the specified requirements of the QCT
exemption could be of benefit to the market as a whole and a
contribution to the efficient functioning of the securities markets and
the price discovery process.\31\
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\29\ See Original QCC Approval Order, supra note 8, at 11540-
11541.
\30\ See Securities Exchange Act Release No. 54389 (August 31,
2006, 71 FR 52829, 52830 (September 7, 2006) (``Original QCT
Exemption'').
\31\ See Original QCC Approval Order, supra note 8 at text
accompanying footnote 115.
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In analyzing ISE's original QCC Order, the Commission weighed the
benefits of QCTs, of which QCC Orders are a subset, against the
benefits provided by the general requirement for exposure of orders in
the options markets.\32\ In the Original QCC Approval Order, the
Commission stated that the QCC Order strikes an appropriate balance for
the options market in that it is narrowly drawn and establishes a
limited exception to the general principle of exposure and retains the
general principle of customer priority in the options markets because
QCC Orders are required to be: (1) Part of a QCT under Regulation NMS;
(2) for at least 1,000 contracts; (3) executed at a price at or between
the national best bid or offer; and (4) cancelled if there is a
Priority Customer Order on ISE's limit order book at the same
price.\33\ The Commission specifically noted that a QCC Order must not
only be part of a QCT by satisfying each of the six underlying
requirements of the NMS QCT Exemption, but must be for a minimum size
of 1,000 contracts, and that these requirements provide another limit
to its use by ensuring only transactions of significant size may avail
themselves of this order type.\34\ Given the requirements for QCC
Orders, the Commission also noted its belief that those customers
participating in QCC Orders would likely be sophisticated investors who
should understand that their order would not be exposed for potential
price improvement, and that these customers should be able to
themselves assess whether the net prices they are receiving for their
QCC Order are competitive.\35\ The Commission also specifically noted
that broker-dealers are subject to a duty of best execution for their
customers' orders, and that duty does not change for QCC Orders.\36\
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\32\ Id. at 11541.
\33\ Id.
\34\ Id.
\35\ Id.
\36\ Id.
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In considering ISE's proposal to eliminate the minimum size
requirement for the contra-side of QCC Orders, the Commission has again
weighed whether the benefits of this order type, as proposed to be
modified, to investors and the market outweigh the benefits provided by
the general requirement for exposure of orders in the options markets.
The Commission notes that ISE's proposal does not change the
requirements that a QCC Order must be: (1) Part of a QCT under
Regulation NMS; (2) executed at a price at or between the national best
bid or offer; and (3) cancelled if there is a Priority Customer Order
on ISE's limit order book. In addition, the changes to QCC Orders under
SR-ISE-2013-71\37\ permit multiple contra-side orders for QCC Orders,
so long as each such contra-side order is for at least 1,000 contracts.
In this filing, the only
[[Page 19683]]
requirement that ISE proposes to change is to eliminate the requirement
that contra-side orders of a QCC Order be for at least 1,000 contracts.
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\37\ See supra note 12.
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The Commission believes that this change to the minimum size
requirement for the contra-side(s) of QCC Orders is narrowly tailored
and, significantly, the Exchange's rule text clearly requires that the
originating side of a QCC Order must be comprised of a single order
(i.e., a single party) for at least 1,000 contracts. The Commission
believes that retention of the requirements that the original side be
comprised of a single order from a single party and that such single
order be for at least 1,000 contracts will continue to ensure that
sophisticated investors, who are aware that their orders will not be
exposed for price improvement, and who themselves should be able to
assess whether the net prices for their QCC Orders are competitive,
will initiate QCC Orders in an effort to effectuate a complex
transaction that complies with all the requirements of the QCC Order.
The proposed rule change will allow multiple contra-parties with
order sizes of less than 1,000 to aggregate their interest to pair
against the originating side of a QCC Order to facilitate the execution
of the QCC Order. The Commission believes that allowing smaller orders
from multiple parties to participate on the contra-side of QCC Orders
may provide a better opportunity for QCC Orders to be executed and,
potentially, at better prices. The Commission acknowledges that
limiting participation on the contra-side of a QCC Order only to
liquidity providers who are willing to participate on the trade for
1,000 contracts, could result in less interest in the trade than if
contra-side orders were not required to meet the 1,000 contract
minimum, potentially diminishing the opportunity for competition and
price improvement. The Commission believes that the proposed
modification to the definition of QCC Order is narrowly drawn in that
it does not impact the fundamental aspects of this order type, and
merely permits QCC Orders to include multiple contra-parties,
regardless of size on the contra-side, while preserving the 1,000
contract minimum on the originating side of a QCC Order. Accordingly,
the Commission finds the proposed rule consistent with the Act.
The issues raised in the comment letters do not specifically
address the changes proposed in the instant filing, and the Commission
agrees with ISE that the commenters on the proposed rule change do not
present any arguments that were not considered fully in Original QCC
Approving Order (i.e., QCC Orders harm the market by not requiring
exposure), or are outside the scope of this proposal (i.e., fee rebates
for initiating QCC Orders create a conflict of interest for
brokers).\38\
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\38\ In addition, the Commission again emphasizes, as it did in
the Original QCC Approval Order, that broker-dealers are subject to
a duty of best execution for their customers' orders, and that duty
does not change for QCC Orders. See supra note 36.
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The Commission notes that, given the differing requirements as
between the originating side and contra-side for QCC Orders, it is
essential that the Exchange be able to clearly identify and monitor--
throughout the life of a QCC Order, beginning at time of order entry on
the Exchange through the post-trade allocation process--each side of
the QCC Order and ensure that the requirements of the order type are
being satisfied including, importantly, those relating to the
originating side. The Commission believes this to be critical so that
the Exchange can ensure that market participants are not able to
circumvent the requirements of the QCC Order (as amended by this
proposed rule change), each of which the Commission continues to
believe are critical to ensuring that the QCC Order is narrowly
drawn.\39\ Further, the Commission notes that, in Amendment No. 1, the
Exchange has made certain representations regarding its enforcement and
surveillance of its Members' use of QCC Orders, including, for example,
not only at the time of order entry, but through the post-trade
allocation process as well.
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\39\ The Commission expects the Exchange to have the capability
to enable it to surveil that such requirements are being met. Though
the Exchange has stated its ability to do so in Amendment No. 1, if
the Exchange is not able to have such monitoring at any point in
time, the Commission would expect the Exchange to take other steps
to ensure that the QCC Order cannot be improperly used. For example,
if the Exchange were not able to identify and monitor which side of
a QCC Order is the originating order, the Commission would expect
that it would require that both sides of the QCC Order meet the more
stringent requirements of the originating side, i.e., that it be for
a single order for at least 1,000 contracts.
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For the foregoing reasons, the Commission believes that the
proposed rule change is consistent with the Act.
It is therefore ordered, pursuant to Section 19(b)(2) of the Act
\40\ that the proposed rule change (SR-ISE-2013-72), as modified by
Amendment No.1, be, and it hereby is, approved.
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\40\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\41\
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\41\ 17 CFR 200.30-3(a)(12).
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Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-07892 Filed 4-8-14; 8:45 am]
BILLING CODE 8011-01-P