Self-Regulatory Organizations; Chicago Mercantile Exchange Inc.; Notice of Filing of Proposed Rule Change Related to Enhancements to Its Risk Model for Credit Default Swaps, 48805-48809 [2014-19527]
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Federal Register / Vol. 79, No. 159 / Monday, August 18, 2014 / Notices
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–72834; File No. SR–CME–
2014–28]
Self-Regulatory Organizations;
Chicago Mercantile Exchange Inc.;
Notice of Filing of Proposed Rule
Change Related to Enhancements to
Its Risk Model for Credit Default Swaps
August 13, 2014.
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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 August 8, 2014, Chicago
Mercantile Exchange Inc. (‘‘CME’’) filed
with the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change described in Items
I, II and III below, which Items have
been prepared primarily by CME. The
Commission is publishing this notice to
solicit comments on the proposed rule
change for interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The proposed change relating to the
Risk Model for Credit Default Swaps
(‘‘CDS’’) (the ‘‘CDS Risk Model’’) (such
enhanced model, the ‘‘Proposed CDS
Risk Model’’) will apply only to broadbased index CDS products cleared by
CME and will not apply to securitybased swaps. CME will file separate
proposed rule changes with the
Commission in the future to implement
any CDS risk model applicable to the
clearing of security-based swaps.
CME is proposing to change its
current CDS Margin Model as follows
(such new model, the ‘‘Proposed CDS
Margin Model’’):
• Replacing the current multiple
market risk factors with a single market
risk component calculated by reference
to scenarios obtained within a statistical
framework that addresses relevant
market risk factors affecting a given CDS
portfolio;
• Enhancing the Idiosyncratic Risk
Component with a more systematic
approach that avoids double counting of
risk with other elements of the Proposed
CDS Margin Model;
• Enhancing the Liquidity/
Concentration Risk Component to
incorporate reference entity or index
series and maturity-specific liquidity
features and to address liquidation risk
for highly concentrated positions with a
progressively increasing margin
requirement;
1 15
2 17
U.S.C. 78s(b)(1).
CFR 240.19b–4.
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• Adding a risk component for
interest rate/discount curve risk; and
• Addressing foreign exchange (‘‘F/
X’’) related risk that may result from
CDS portfolios that include CDS
positions denominated in multiple
currencies.
CME is additionally proposing to add
a new CDS Guaranty Fund charge to
CDS Clearing Members that clear CDS
Products that reference themselves or
their affiliates and delete the current
threshold based approach.
Further, CME proposes to amend its
CDS Stress Test Methodology to align
with the Proposed CDS Margin Model
framework. The CDS Guaranty Fund
will continue to be sized so that CME’s
financial resources are sufficient to meet
its financial obligations to its CDS
Clearing Members notwithstanding a
default by the two CDS Clearing
Members creating the largest loss in
extreme but plausible market conditions
based upon the results of the new CDS
Stress Test Methodology. In addition,
CME proposes to add a new risk
component to its CDS Stress Test
Methodology to capture self-referencing
risk arising from contracts that include
component transactions for which the
reference entity is a clearing member or
one of its affiliates. In addition, CME
proposes to add a new stress exposure
calculation to size the self-referencing
risk discussed above.
The text of the proposed change is
also available at the CME’s Web site at
https://www.cmegroup.com, at the
principal office of CME, and at the
Commission’s Public Reference Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission,
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
may be examined at the places specified
in Item IV below. CME has prepared
summaries, set forth in sections A, B,
and C below, of the most significant
aspects of such statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
a. Purpose
1. Description of the Proposed Changes
to the CDS Margin Model
CME is proposing to make changes to
the existing CDS Margin Model by
changing the current Market Risk
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48805
Factor, the Idiosyncratic Risk Factor and
the Liquidity/Concentration Risk Factor
as well as adding a new Interest Rate
Sensitivity Component, and a
methodology for addressing new F/X
related risks for CDS portfolios
denominated in multiple currencies.
The Proposed CDS Margin Model aims
to holistically model the risk of a CDS
portfolio comprised of a variety of index
and single-name CDS products using
statistically derived scenarios.
1.1 Proposed Changes for Market Risk
Component
To reflect the variations in market
value of a CDS portfolio, which may be
comprised of positions in different
index and single-name CDS products
with different maturities, CME is
proposing to use a scenario-based
approach which relies on a statistical
model, for the Market Risk Component.
The statistical model is designed to
generate scenarios that aim to reproduce
the salient characteristics of marginal
and joint movement of credit spreads
across different index series or reference
entity and maturity combinations.
The scenarios used for the modeling
of the Market Risk Component are based
on the log changes in:
• Par-spreads for ‘‘run-rank’’ (on-therun (‘‘OTR’’), OTR–1, OTR–2, . . .)
index CDS at standard maturities (1, 3,
5, 7 and 10 years); and
• Par-spreads for single-name CDS at
standard maturities (1, 3, 5, 7 and 10
years).
A joint probability distribution for the
5-day log changes in par spreads is
estimated using historical data on daily
log changes in par spreads, which are
the driving risk factors of the Proposed
CDS Margin Model. The distributional
characteristics of these risk factors are
represented through time-varying
autocorrelations, volatilities and tail risk
parameters.
The volatility of each risk factor is an
exponentially weighted moving average
floored at an equal-weighted long-run
average. The dependence across risk
factors is modeled by historical and
stressed correlation matrices combined
with a copula function to model tail-risk
dependence. The new statistical model
allows CME to generate extreme but
plausible spread scenarios across
different index series and/or reference
entities and maturities. Both the
volatility floor and stressed correlation
matrices add counter-cyclical features to
the Market Risk Component.
CME will employ a Monte Carlo
simulation approach to generate spread
scenarios for computing the Market Risk
Component as further described below.
The proposed Market Risk Component
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(‘‘MR’’) is represented by the following
formula:
MR = BMR + DR
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Where
• the Base Market Risk Component
(‘‘BMR’’) is determined as the Value-at-Risk
(‘‘VaR’’) at a 99% confidence level for the
CDS portfolio’s theoretical changes in value
over 5 days. This corresponds to the 1%
greatest negative change in the CDS portfolio
value based on spread scenarios generated by
Monte Carlo simulation by reference to
historical correlation matrix estimate; and
• the Dependence Risk Component (‘‘DR’’)
is determined by computing the VaR at a
99% confidence level under stressed
correlation scenarios for the CDS portfolio’s
theoretical changes in value over 5 days. A
low and high correlation VaR is estimated
through the 1% greatest negative change in
the CDS portfolio value based on spread
scenarios generated by Monte Carlo
simulation by reference to stressed low and
high correlation matrices, respectively. DR is
computed as the excess of the greater of the
low and high correlation VaR over BMR,
multiplied by a risk-aversion coefficient.3
The proposed Market Risk
Component aims to more accurately
capture different sources of market risk
through a holistic and theoretically
coherent scenario-based approach that
is driven by conservative statistical
assumptions. CME notes that the current
CDS Margin Model relies on separate
add-on factors which are modeled and
calibrated in isolation and gives rise to
the potential for double counting.
Varying degrees of volatility and tail
risks across par spreads of different
index series or reference entities at
different maturities are not represented
in the current CDS Margin Model.
Historical correlations, tail dependence
and correlation risk are not explicitly
and consistently accounted for within
the current CDS Margin Model. In
contrast, spread volatility and tail risks
are modeled precisely and consistently
in the Proposed CDS Margin Model. The
effects of historical correlations, tail
dependence and correlation risk on the
co-movement of spreads of CDS
products are explicitly addressed in the
Proposed CDS Margin Model.
The risk factors of the current CDS
Margin Model such as curve, sector and
convergence/divergence are replaced by
a scenario-based approach which
incorporates historical correlation
matrices into the market risk
computation. The Market Risk
Component also aims to capture
correlation risk that might arise from
relying exclusively on historicallyestimated correlations which can
change under extreme market
3 The risk-aversion coefficient was determined by
back testing a collection of theoretical and
production portfolios.
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conditions. The correlation risk is
addressed by employing two extreme
correlation scenarios (high correlations
and low correlations) to compute DR
which addresses the risk of long-short or
diversified portfolios driven by
correlation uncertainty.
Additionally, the proposed Market
Risk Component incorporates countercyclical features for calibration and
modeling of volatilities, autocorrelations
and correlations.
In comparison to the existing model,
the proposed change to the manner in
which the market risk is assessed may,
in isolation, result in a reduction in the
margin requirement for market risk.
CME believes that this margin reduction
does not come at the expense of adding
more risk to the CME Clearing House
since the statistical model and its
different components were shown to
appropriately cover the risk of a wide
range of theoretical and production
portfolios under extreme but plausible
market conditions and in historical back
testing, going back to 2008.
1.2 Proposed Idiosyncratic Risk
Component
The Idiosyncratic Risk Component is
intended to address CME’s potential
exposure to possible ‘‘jump-to-default’’
(‘‘JTD’’) risk due to default of a reference
entity as well as ‘‘jump to health’’
(‘‘JTH’’) risk where a reference entity
benefits from an extreme drop in credit
spreads (due to an improvement in
credit quality) (in each case, beyond
what is covered by the Market Risk
Component). JTD risk of a reference
entity is driven by the exposure to a
scenario which reduces the price of the
reference entity to a stressed recovery
rate. JTH risk of a reference entity is
driven by the exposure to a scenario
which is a drastic improvement in
credit quality of the entity. In addition
to the price differential under current
market and idiosyncratic scenarios, both
JTD and JTH margin requirements take
into account the risk concentration to a
reference entity through dependence on
position size. Within the Proposed CDS
Margin Model, only the marginal risk
contribution of idiosyncratic events will
be reflected in the risk component. This
is accomplished by coherent modeling
of the associated market and
idiosyncratic risks. Both JTD and JTH
margin requirements are estimated by
the difference between the pure market
risk of the portfolio and the sum of the
idiosyncratic risk and the market risk of
the portfolio, excluding positions in the
reference entity which drives the
Idiosyncratic Risk Component.
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1.3 New Interest Rate Sensitivity
Component
CME is proposing to introduce a new
Interest Rate Sensitivity Component to
capture the effect of changes in interest
rates (relevant to the underlying
discount curve) on the market value of
CDS portfolios. The calculation of the
Interest Rate Sensitivity Component
relies on applying parallel up and down
shocks to the discount curve relevant to
the index series or reference entity.
1.4 Proposed Change to the Liquidity/
Concentration Risk Component
The Liquidity/Concentration Risk
Component is designed to reflect CME’s
costs during the liquidation of a CDS
portfolio following a CDS Clearing
Member default, resulting from
widening bid/ask spreads and/or
increasing liquidation times due to the
size of the CDS portfolio and/or eventdriven liquidity squeezes. The proposed
changes to the Liquidity/Concentration
Risk Component are intended to add
granularity to the modeling of liquidity/
concentration risk by taking into
account varying liquidity profiles across
index series or reference entities and
relevant maturities. The different
liquidity characteristics of various index
families/series and reference entities are
modeled using trading volume data on
the specific index series or reference
entities. The dependence on trading
volume data enables the model to more
sensitively react to changes in trading
activity. The modeling of relative
liquidity of instruments at different
maturities relies on an analysis of bid/
ask spreads across maturities for both
index and single-name CDS products.
Concentration risk is addressed by a
progressively increasing super-linear
dependence on position size relative to
the trading volume of the underlying
reference entity or index series and
relevant maturity.
The enhancements in the proposed
Liquidity/Concentration Risk
Component result in higher liquidity
risk margin requirements for off-the-run
indices, which are generally in line with
the change in observed trading activity
when a series becomes off-the-run. For
single-name CDS, the proposed
Liquidity/Concentration Risk
Component results in higher liquidity
risk margin requirements for reference
entities with relatively low trading
volume. Furthermore, the proposed
Liquidity/Concentration Risk
Component generally yields higher
liquidity risk margin requirements for
short and long dated contracts.
An analysis of proposed Liquidity/
Concentration Risk Component on an
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indicative set of CDS portfolios reveals
that the proposed Liquidity/
Concentration Risk Component
responds as expected to concentration,
diversification and hedging. The overall
effect of the enhancements made to the
Liquidity/Concentration Risk
Component is to reduce risk to the CME
Clearing House by conservatively
increasing margin requirements for
positions which are expected to be more
difficult to close out.
1.5 New F/X Related Risk Component
CME is proposing to address F/X
related risks associated with the
inclusion of non-USD denominated CDS
positions in CDS portfolios (each a
‘‘Non-USD CDS Positions’’). As
proposed above, CME will allow for
correlation based risk offsets with
respect to both Market Risk Components
and Idiosyncratic Risk Components of
the Proposed CDS Margin Model. The
calculation of such risk offsets will
require that the Market Risk
Components and Idiosyncratic Risk
Components be calculated in USD (or
other such common/base currency as
may be chosen from time to time). In
order to calculate the USD
requirements, profit and loss due to
market and idiosyncratic factors
(‘‘P&L’’) will be converted into their
USD equivalents based on conservative
F/X rates. The USD equivalent
requirements for the Market Risk
Component and the Idiosyncratic Risk
Component will then be apportioned
into each currency specific sub-portfolio
based on its Market Risk Component
and Idiosyncratic Risk Component
requirements.
With respect to the Interest Rate
Sensitivity Component and the
Liquidity Risk/Concentration
Component of the Proposed CDS Margin
Model, where CME does not propose to
offer risk or diversification offsets, only
currency specific margin requirements
are computed.
The overall risk requirement for each
specific currency is then calculated as
the sum of (a) the currency specific
Liquidity/Concentration Risk
Component requirement, (b) the
currency specific Interest Rate
Sensitivity Component requirement,
and (c) the sum of the Market Risk
Component and the Idiosyncratic Risk
Component requirement (apportioned to
each specific currency). Under the
Proposed CDS Margin Model, CME will
inform clearing members of their margin
requirements with respect to their
multi-currency CDS positions in
amounts that are required to be posted
for each denominated currency in their
portfolios.
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2. Description of the Proposed
Changes to Stress Test Methodology
2.1 Proposed Changes to CDS Stress
Test Methodology for Sizing and
Allocation of CDS Financial Resources
CME currently utilizes a stressed
extension of its margin model to size the
CDS Guaranty Fund and CDS
Assessments (as defined in the CME
Rules). The ‘‘potential residual loss’’
used to size and allocate the CDS
Guaranty Fund and CDS Assessments is
determined as the excess of the stressed
exposure for CDS products over the
margin deposited for CDS products.
CME is proposing changes to the CDS
Stress Test Methodology in order to
align it with the Proposed CDS Margin
Model. The proposed CDS Stress Test
Methodology will rely on more extreme
and counter-cyclical scenarios for the
calculation of the different risk
components compared to the scenarios
used in the Proposed CDS Margin
Model.
2.2 New Self-Referencing Risk
Component
Although CME does not permit a CDS
Clearing Member or a customer to enter
into or maintain a single-name CDS
position referencing the clearing
member or an affiliate, a self-referencing
CDS position may arise where the CDS
Clearing Member or its affiliate is the
Reference Entity in respect of a
component transaction within the index
referenced in a CDS position. For
example, such a situation may arise in
the context of index CDS contracts
which reference CDS Clearing Members
or their affiliates. In such cases, the CDS
Clearing Member (a ‘‘CDS SR Clearing
Member’’), either through its own
account or that of a customer, has
exposure to a CDS Product that
references itself or its affiliate (each an
‘‘SR Transaction’’). CME proposes to
address this potential exposure to selfreferencing risk by allocating an
additional JTD risk for each CDS SR
Clearing Member under its Stress Test
Methodology. CME considers a CDS
Clearing Member default to be an
extreme tail risk event which is subject
to the CDS financial safeguards,
including mutualization across all other
CDS Clearing Members via the CDS
Guaranty Fund.
Currently, CDS SR Clearing Members,
clearing self-referencing indices for
itself or its customers, are required to
collateralize the self-referencing
exposure in an amount specified in the
CME Rules. CME is now proposing to
adopt a risk based approach without
reference to any preset threshold, to
capture this self-referencing risk. The
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48807
additional risk associated with CDS SR
Clearing Members will be added to the
stress scenarios used to size the CDS
Guaranty Fund and CME will require
each CDS SR Clearing Member to make
an additional CDS Guaranty Fund
Deposit to address this risk (such
additional deposit, the ‘‘CDS SR
Deposit’’). The net theoretical selfreferencing exposure of each CDS
Clearing Member is computed as the
additional theoretical self-referencing
‘‘potential residual loss’’ to CME in
extreme but plausible market conditions
using the stress testing methodology
determined by the CDS Risk Committee.
The aggregate amount of CDS SR
Deposits will be sized to cover the sum
of the net theoretical self-referencing
exposures of two CDS SR Clearing
Members which would create the two
largest net theoretical self-referencing
exposures.4 The required CDS SR
Deposit will then be allocated to each
CDS SR Clearing Member in proportion
to each such CDS SR Clearing Member’s
net self-referencing exposure.
A new CME Rule 8H06 (CDS SR
Deposit) has been added to accurately
reflect these proposed changes to the
CDS Guaranty Fund in the CME Rules,
and CME Rule 8H802.B (Satisfaction of
Clearing House Obligations) has been
amended to reflect the introduction of
the CDS SR Deposit. In addition,
provisions in CME Rule 80104.A
(Clearing Through Clearing Member’s
House (or Proprietary) Account) and
CME Rule 80104.B (Clearing Through
Clearing Members Customer Account)
that relate to the requirement by
clearing members that clear selfreferencing indices for themselves or
their customers to collateralize the selfreferencing exposure in an amount
specified in the CME Rules have been
deleted.
A CDS Clearing Member default may
result in contagion among financial
institutions, widening spreads and
exposing portfolios consisting of index
CDS that reference financial entities to
potential wrong-way risk. For example,
the default of a CDS Clearing Member
based in the United States, which is not
referenced in an index referencing
European names, could lead to overall
widening of the credit spreads among
financial institutions worldwide,
leading to widening of spreads in nonUS indices. This may lead to variations
in correlations between such non-US
indices and other North American
indices, potentially adversely impacting
4 For purposes of determining the two largest
potential residual losses, the self-referencing
exposure of a CDS SR Clearing Member will be
aggregated with that of any affiliated CDS SR
Clearing Member.
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certain portfolios which are sensitive to
such correlations. This increase in
potential exposure caused by contagion
is addressed in the CME Proposed CDS
Risk Model and Stress Test
Methodology via incorporation of
stressed correlation scenarios.
2.3 Portfolio Margining Implications
The Proposed CDS Margin Model
relies on a statistical model to support
a scenario-based approach in line with
the joint probability distribution
characteristics of par spreads of index
series or reference entities across
standard maturities. The Market Risk
Component of the Proposed CDS Margin
Model provides risk offsets between
single-name CDS positions and index
CDS positions. Such risk offsets are
driven by the dependence structure
across spread scenarios imposed by
historical and counter-cyclical stressed
correlations.
The Interest Rate Sensitivity
Component for a portfolio containing
index and single-name CDS products is
designed as an aggregate risk component
across index and single-name CDS
positions.
Under the Proposed CDS Margin
Model, the JTD component of the
margin is computed by aggregating the
exposure to the default of a reference
entity in both single-name CDS
positions and index CDS positions. CME
relies on a decomposition model to
compute the JTD component of the
margin requirement for a CDS portfolio
containing index and single-name CDS
products.
The Liquidity/Concentration Risk
Component of the Proposed CDS Margin
Model is driven by an expected
liquidation process in which the market
risk exposure of the portfolio is first
hedged with the most liquid CDS
instrument and then the resulting basis
(hedged) portfolio is liquidated. The
margin requirements of the Liquidity/
Concentration Risk Component that are
driven by market risk hedging costs are
calculated by aggregating the market
risk exposure of the index and singlename CDS positions. Index and singlename CDS positions are handled
separately for the calculation of the
basis risk margin requirement (due to
unwinding of hedged positions) of the
Liquidity/Concentration Risk
Component and also for the modeling of
the concentration margin requirement as
a function of position size.
b. Statutory Basis
CME believes the proposed rule
change is consistent with the
requirements of the Exchange Act,
including Section 17A of the Exchange
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Act,5 and the applicable regulations
thereunder. The proposed rule change is
designed to promote the prompt and
accurate clearance and settlement of
securities transactions and, to the extent
applicable, derivatives agreements,
contracts, and transactions, to assure the
safeguarding of securities and funds
which are in the custody or control of
the clearing agency or for which it is
responsible, and, in general, to protect
investors and the public interest
consistent with Section 17A(b)(3)(F) of
the Exchange Act.6
The proposed rule change
accomplishes these objectives because it
is intended to more accurately capture
different sources of risk through a
holistic and theoretically coherent
scenario-based approach that is driven
by conservative statistical assumptions,
which in turn allows CME to
appropriately cover the risk of a wide
range of theoretical and production
portfolios under extreme but plausible
market conditions and in historical back
testing, going back to 2008. In
particular, the amendments will
enhance CME’s margin methodology by
more accurately addressing F/X risk and
self-referencing risk presented by
clearing index CDS contracts.
CME will also promote the efficient
use of margin for the clearinghouse and
its Clearing Members and their
customers by enabling CME to provide
appropriate portfolio margining
treatment between index and singlename CDS positions and as such
contribute to the safeguarding of
securities and funds in CME’s custody
or control or for which CME is
responsible and the protection of
investors.7
CME also believes the proposed rule
change is consistent with the
requirements of Rule 17Ad-22 of the
Exchange Act.8 In particular, in terms of
financial resources, CME believes that
the proposed rule change will continue
to ensure sufficient margin to cover its
credit exposure to its clearing members,
consistent with the requirements of Rule
17Ad–22(b)(2) 9 and Rule 17Ad–
22(d)(14) 10 and that the CDS Guaranty
Fund contributions and required
margin, both as modified by the
proposed rule change, will provide
sufficient financial resources to
withstand a default by the two
participant families to which it has the
largest exposures in extreme but
5 15
6 15
U.S.C. 78q–1.
U.S.C. 78q–1(b)(3)(F).
plausible market conditions consistent
with the requirements of Rule 17Ad–
22(b)(3).11 In addition, CME believes
that the proposed rule change is
consistent with CME’s requirement to
limit its exposures to potential losses
from defaults by its participants under
normal market conditions pursuant to
17Ad–22(b)(1).12 CME also believes that
the proposed rule change will continue
to allow for it to take timely action to
contain losses and liquidity pressures
and to continue meeting its obligations
in the event of clearing member
insolvencies or defaults, in accordance
with Rule 17Ad–22(d)(11).13
B. Self-Regulatory Organization’s
Statement on Burden on Competition
CME does not believe that the
proposed rule change will have any
impact, or impose any burden, on
competition. The proposed rule change
reflects enhancements to CME’s CDS
Risk Model. CME does not believe that
any increase in margin or CDS Guaranty
Fund contributions, would significantly
affect the ability of Clearing Members or
other market participants to continue to
clear CDS, consistent with the risk
management requirements of CME, or
otherwise limit market participants’
choices for selecting clearing services.
For the foregoing reasons, the Proposed
CDS Risk Model does not, in CME’s
view, impose any unnecessary or
inappropriate burden on competition.
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
Written comments relating to the
Proposed CDS Risk Model have not
been solicited or received. CME will
notify the Commission of any written
comments received by CME.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
Within 45 days of the date of
publication of this notice in the Federal
Register or within such longer period
up to 90 days (i) as the Commission may
designate if it finds such longer period
to be appropriate and publishes its
reasons for so finding or (ii) as to which
the self-regulatory organization
consents, the Commission will:
(A) by order approve or disapprove
such proposed rule change, or
(B) institute proceedings to determine
whether the proposed rule change
should be disapproved.
7 Id.
8 17
11 17
9 17
CFR 240.19b–4.
CFR 240.17Ad–22(b)(2).
10 17 CFR 240.17Ad–22(d)(14).
12 17
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CFR 240.17Ad–22(b)(3).
CFR 240.17Ad–22(b)(1).
13 17 CFR 240.17Ad–22(d)(11).
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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:
• 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 No. SR–
CME–2014–28 on the subject line.
Paper Comments
mstockstill on DSK4VPTVN1PROD with NOTICES
• 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–CME–2014–28. 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 or
10:00 a.m. and 3:00 p.m. Copies of such
filing also will be available for
inspection and copying at the principal
office of CME and on CME’s Web site at
https://www.cmegroup.com/marketregulation/rule-filings.html.
All comments received will be posted
without change; the Commission does
not edit personal identifying
information from submissions. You
should submit only information that
you wish to make available publicly.
All submissions should refer to File
Number SR–CME–2014–28 and should
be submitted on or before September 8,
2014.
16:57 Aug 15, 2014
[FR Doc. 2014–19527 Filed 8–15–14; 8:45 am]
BILLING CODE 8011–01–P
proposed rule change. The text of these
statements may be examined at the
places specified in Item IV below. The
Exchange has prepared summaries, set
forth in Sections A, B, and C below, of
the most significant parts of such
statements.
SECURITIES AND EXCHANGE
COMMISSION
Electronic Comments
VerDate Mar<15>2010
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.14
Kevin M. O’Neill,
Deputy Secretary.
48809
Jkt 232001
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
[Release No. 34–72821; File No. SR–BATS–
2014–031]
1. Purpose
Self-Regulatory Organizations; BATS
Exchange, Inc.; Notice of Filing and
Immediate Effectiveness of a Proposed
Rule Change To Reflect Changes to
the Means of Achieving the Investment
Objective Applicable to the iShares
Short Maturity Bond Fund
August 12, 2014.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (the
‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that on August 4,
2014, BATS Exchange, Inc. (the
‘‘Exchange’’ or ‘‘BATS’’) filed with the
Securities and Exchange Commission
(‘‘Commission’’) the proposed rule
change as described in Items I and II
below, which Items have been prepared
by the Exchange. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of the Substance
of the Proposed Rule Change
The Exchange filed a proposal to
reflect changes to the means of
achieving the investment objective
applicable to the iShares Short Maturity
Bond Fund (the ‘‘Fund’’). The shares of
the Fund are currently listed and traded
on the Exchange under BATS Rule
14.11(i).
The text of the proposed rule change
is available at the Exchange’s Web site
at https://www.batstrading.com, at the
principal office of the Exchange, and at
the Commission’s Public Reference
Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
Exchange included statements
concerning the purpose of and basis for
the proposed rule change and discussed
any comments it received on the
14 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
1 15
PO 00000
Frm 00090
Fmt 4703
Sfmt 4703
The Commission has approved listing
and trading on the Exchange of shares
of the Fund (‘‘Shares’’), which are
offered by the iShares U.S. ETF Trust
(the ‘‘Trust’’),3 under BATS Rule
14.11(i), which governs the listing of
Managed Fund Shares. The Shares are
currently listed and traded on the
Exchange under BATS Rule 14.11(i).
The Shares are offered by the Trust,
which was established as a Delaware
statutory trust on June 21, 2011. The
Trust is registered with the Commission
as an open-end investment company
and has filed a registration statement on
behalf of the Fund on Form N–1A
(‘‘Registration Statement’’) with the
Commission.4 BlackRock Fund Advisors
is the investment adviser (‘‘BFA’’ or
‘‘Adviser’’) to the Fund.5 BlackRock
Financial Management, Inc. serves as
sub-adviser for the Fund (‘‘SubAdviser’’).6 State Street Bank and Trust
Company is the administrator,
custodian, and transfer agent for the
Trust. BlackRock Investments, LLC
(‘‘Distributor’’) serves as the distributor
for the Trust.
3 See Securities Exchange Act Release No. 67894
(September 20, 2012), 77 FR 59227 (September 26,
2012) (SR–BATS–2012–033 Amendment No. 1) (the
‘‘Prior Filing’’).
4 See Registration Statement on Form N–1A for
the Trust, dated March 1, 2014 (File Nos. 333–
179904 and 811–22649). The descriptions of the
Fund and the Shares contained herein are based, in
part, on information in the Registration Statement.
The Commission has issued an order granting
certain exemptive relief to the Company under the
Investment Company Act of 1940 (15 U.S.C. 80a–
1) (‘‘1940 Act’’) (the ‘‘Exemptive Order’’). See
Investment Company Act Release No. 29571
(January 24, 2011) (File No. 812–13601).
5 BlackRock Fund Advisors is an indirect wholly
owned subsidiary of BlackRock, Inc.
6 The Adviser manages the Fund’s investments
and its business operations subject to the oversight
of the Board of Trustees of the Trust (the ‘‘Board’’).
While BFA is ultimately responsible for the
management of the Fund, it is able to draw upon
the trading, research and expertise of its asset
management affiliates for portfolio decisions and
management with respect to portfolio securities.
The Adviser also has ongoing oversight
responsibility. The Sub-Adviser, subject to the
supervision and oversight of the Adviser and the
Board, is responsible for day-to-day management of
the Fund and, as such, typically makes all decisions
with respect to portfolio holdings.
E:\FR\FM\18AUN1.SGM
18AUN1
Agencies
[Federal Register Volume 79, Number 159 (Monday, August 18, 2014)]
[Notices]
[Pages 48805-48809]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-19527]
[[Page 48805]]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-72834; File No. SR-CME-2014-28]
Self-Regulatory Organizations; Chicago Mercantile Exchange Inc.;
Notice of Filing of Proposed Rule Change Related to Enhancements to Its
Risk Model for Credit Default Swaps
August 13, 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 August 8, 2014, Chicago Mercantile Exchange
Inc. (``CME'') filed with the Securities and Exchange Commission
(``Commission'') the proposed rule change described in Items I, II and
III below, which Items have been prepared primarily by CME. The
Commission is publishing this notice to solicit comments on the
proposed rule change for interested persons.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.&
---------------------------------------------------------------------------
I. Self-Regulatory Organization's Statement of the Terms of Substance
of the Proposed Rule Change
The proposed change relating to the Risk Model for Credit Default
Swaps (``CDS'') (the ``CDS Risk Model'') (such enhanced model, the
``Proposed CDS Risk Model'') will apply only to broad-based index CDS
products cleared by CME and will not apply to security-based swaps. CME
will file separate proposed rule changes with the Commission in the
future to implement any CDS risk model applicable to the clearing of
security-based swaps.
CME is proposing to change its current CDS Margin Model as follows
(such new model, the ``Proposed CDS Margin Model''):
Replacing the current multiple market risk factors with a
single market risk component calculated by reference to scenarios
obtained within a statistical framework that addresses relevant market
risk factors affecting a given CDS portfolio;
Enhancing the Idiosyncratic Risk Component with a more
systematic approach that avoids double counting of risk with other
elements of the Proposed CDS Margin Model;
Enhancing the Liquidity/Concentration Risk Component to
incorporate reference entity or index series and maturity-specific
liquidity features and to address liquidation risk for highly
concentrated positions with a progressively increasing margin
requirement;
Adding a risk component for interest rate/discount curve
risk; and
Addressing foreign exchange (``F/X'') related risk that
may result from CDS portfolios that include CDS positions denominated
in multiple currencies.
CME is additionally proposing to add a new CDS Guaranty Fund charge
to CDS Clearing Members that clear CDS Products that reference
themselves or their affiliates and delete the current threshold based
approach.
Further, CME proposes to amend its CDS Stress Test Methodology to
align with the Proposed CDS Margin Model framework. The CDS Guaranty
Fund will continue to be sized so that CME's financial resources are
sufficient to meet its financial obligations to its CDS Clearing
Members notwithstanding a default by the two CDS Clearing Members
creating the largest loss in extreme but plausible market conditions
based upon the results of the new CDS Stress Test Methodology. In
addition, CME proposes to add a new risk component to its CDS Stress
Test Methodology to capture self-referencing risk arising from
contracts that include component transactions for which the reference
entity is a clearing member or one of its affiliates. In addition, CME
proposes to add a new stress exposure calculation to size the self-
referencing risk discussed above.
The text of the proposed change is also available at the CME's Web
site at https://www.cmegroup.com, at the principal office of CME, and at
the Commission's Public Reference Room.
II. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
In its filing with the Commission, 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 may be examined at the places specified in
Item IV below. CME has prepared summaries, set forth in sections A, B,
and C below, of the most significant aspects of such statements.
A. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
a. Purpose
1. Description of the Proposed Changes to the CDS Margin Model
CME is proposing to make changes to the existing CDS Margin Model
by changing the current Market Risk Factor, the Idiosyncratic Risk
Factor and the Liquidity/Concentration Risk Factor as well as adding a
new Interest Rate Sensitivity Component, and a methodology for
addressing new F/X related risks for CDS portfolios denominated in
multiple currencies. The Proposed CDS Margin Model aims to holistically
model the risk of a CDS portfolio comprised of a variety of index and
single-name CDS products using statistically derived scenarios.
1.1 Proposed Changes for Market Risk Component
To reflect the variations in market value of a CDS portfolio, which
may be comprised of positions in different index and single-name CDS
products with different maturities, CME is proposing to use a scenario-
based approach which relies on a statistical model, for the Market Risk
Component. The statistical model is designed to generate scenarios that
aim to reproduce the salient characteristics of marginal and joint
movement of credit spreads across different index series or reference
entity and maturity combinations.
The scenarios used for the modeling of the Market Risk Component
are based on the log changes in:
Par-spreads for ``run-rank'' (on-the-run (``OTR''), OTR-1,
OTR-2, . . .) index CDS at standard maturities (1, 3, 5, 7 and 10
years); and
Par-spreads for single-name CDS at standard maturities (1,
3, 5, 7 and 10 years).
A joint probability distribution for the 5-day log changes in par
spreads is estimated using historical data on daily log changes in par
spreads, which are the driving risk factors of the Proposed CDS Margin
Model. The distributional characteristics of these risk factors are
represented through time-varying autocorrelations, volatilities and
tail risk parameters.
The volatility of each risk factor is an exponentially weighted
moving average floored at an equal-weighted long-run average. The
dependence across risk factors is modeled by historical and stressed
correlation matrices combined with a copula function to model tail-risk
dependence. The new statistical model allows CME to generate extreme
but plausible spread scenarios across different index series and/or
reference entities and maturities. Both the volatility floor and
stressed correlation matrices add counter-cyclical features to the
Market Risk Component.
CME will employ a Monte Carlo simulation approach to generate
spread scenarios for computing the Market Risk Component as further
described below. The proposed Market Risk Component
[[Page 48806]]
(``MR'') is represented by the following formula:
MR = BMR + DR
Where
the Base Market Risk Component (``BMR'') is determined
as the Value-at-Risk (``VaR'') at a 99% confidence level for the CDS
portfolio's theoretical changes in value over 5 days. This
corresponds to the 1% greatest negative change in the CDS portfolio
value based on spread scenarios generated by Monte Carlo simulation
by reference to historical correlation matrix estimate; and
the Dependence Risk Component (``DR'') is determined by
computing the VaR at a 99% confidence level under stressed
correlation scenarios for the CDS portfolio's theoretical changes in
value over 5 days. A low and high correlation VaR is estimated
through the 1% greatest negative change in the CDS portfolio value
based on spread scenarios generated by Monte Carlo simulation by
reference to stressed low and high correlation matrices,
respectively. DR is computed as the excess of the greater of the low
and high correlation VaR over BMR, multiplied by a risk-aversion
coefficient.\3\
---------------------------------------------------------------------------
\3\ The risk-aversion coefficient was determined by back testing
a collection of theoretical and production portfolios.
The proposed Market Risk Component aims to more accurately capture
different sources of market risk through a holistic and theoretically
coherent scenario-based approach that is driven by conservative
statistical assumptions. CME notes that the current CDS Margin Model
relies on separate add-on factors which are modeled and calibrated in
isolation and gives rise to the potential for double counting. Varying
degrees of volatility and tail risks across par spreads of different
index series or reference entities at different maturities are not
represented in the current CDS Margin Model. Historical correlations,
tail dependence and correlation risk are not explicitly and
consistently accounted for within the current CDS Margin Model. In
contrast, spread volatility and tail risks are modeled precisely and
consistently in the Proposed CDS Margin Model. The effects of
historical correlations, tail dependence and correlation risk on the
co-movement of spreads of CDS products are explicitly addressed in the
Proposed CDS Margin Model.
The risk factors of the current CDS Margin Model such as curve,
sector and convergence/divergence are replaced by a scenario-based
approach which incorporates historical correlation matrices into the
market risk computation. The Market Risk Component also aims to capture
correlation risk that might arise from relying exclusively on
historically-estimated correlations which can change under extreme
market conditions. The correlation risk is addressed by employing two
extreme correlation scenarios (high correlations and low correlations)
to compute DR which addresses the risk of long-short or diversified
portfolios driven by correlation uncertainty.
Additionally, the proposed Market Risk Component incorporates
counter-cyclical features for calibration and modeling of volatilities,
autocorrelations and correlations.
In comparison to the existing model, the proposed change to the
manner in which the market risk is assessed may, in isolation, result
in a reduction in the margin requirement for market risk. CME believes
that this margin reduction does not come at the expense of adding more
risk to the CME Clearing House since the statistical model and its
different components were shown to appropriately cover the risk of a
wide range of theoretical and production portfolios under extreme but
plausible market conditions and in historical back testing, going back
to 2008.
1.2 Proposed Idiosyncratic Risk Component
The Idiosyncratic Risk Component is intended to address CME's
potential exposure to possible ``jump-to-default'' (``JTD'') risk due
to default of a reference entity as well as ``jump to health''
(``JTH'') risk where a reference entity benefits from an extreme drop
in credit spreads (due to an improvement in credit quality) (in each
case, beyond what is covered by the Market Risk Component). JTD risk of
a reference entity is driven by the exposure to a scenario which
reduces the price of the reference entity to a stressed recovery rate.
JTH risk of a reference entity is driven by the exposure to a scenario
which is a drastic improvement in credit quality of the entity. In
addition to the price differential under current market and
idiosyncratic scenarios, both JTD and JTH margin requirements take into
account the risk concentration to a reference entity through dependence
on position size. Within the Proposed CDS Margin Model, only the
marginal risk contribution of idiosyncratic events will be reflected in
the risk component. This is accomplished by coherent modeling of the
associated market and idiosyncratic risks. Both JTD and JTH margin
requirements are estimated by the difference between the pure market
risk of the portfolio and the sum of the idiosyncratic risk and the
market risk of the portfolio, excluding positions in the reference
entity which drives the Idiosyncratic Risk Component.
1.3 New Interest Rate Sensitivity Component
CME is proposing to introduce a new Interest Rate Sensitivity
Component to capture the effect of changes in interest rates (relevant
to the underlying discount curve) on the market value of CDS
portfolios. The calculation of the Interest Rate Sensitivity Component
relies on applying parallel up and down shocks to the discount curve
relevant to the index series or reference entity.
1.4 Proposed Change to the Liquidity/Concentration Risk Component
The Liquidity/Concentration Risk Component is designed to reflect
CME's costs during the liquidation of a CDS portfolio following a CDS
Clearing Member default, resulting from widening bid/ask spreads and/or
increasing liquidation times due to the size of the CDS portfolio and/
or event-driven liquidity squeezes. The proposed changes to the
Liquidity/Concentration Risk Component are intended to add granularity
to the modeling of liquidity/concentration risk by taking into account
varying liquidity profiles across index series or reference entities
and relevant maturities. The different liquidity characteristics of
various index families/series and reference entities are modeled using
trading volume data on the specific index series or reference entities.
The dependence on trading volume data enables the model to more
sensitively react to changes in trading activity. The modeling of
relative liquidity of instruments at different maturities relies on an
analysis of bid/ask spreads across maturities for both index and
single-name CDS products. Concentration risk is addressed by a
progressively increasing super-linear dependence on position size
relative to the trading volume of the underlying reference entity or
index series and relevant maturity.
The enhancements in the proposed Liquidity/Concentration Risk
Component result in higher liquidity risk margin requirements for off-
the-run indices, which are generally in line with the change in
observed trading activity when a series becomes off-the-run. For
single-name CDS, the proposed Liquidity/Concentration Risk Component
results in higher liquidity risk margin requirements for reference
entities with relatively low trading volume. Furthermore, the proposed
Liquidity/Concentration Risk Component generally yields higher
liquidity risk margin requirements for short and long dated contracts.
An analysis of proposed Liquidity/Concentration Risk Component on
an
[[Page 48807]]
indicative set of CDS portfolios reveals that the proposed Liquidity/
Concentration Risk Component responds as expected to concentration,
diversification and hedging. The overall effect of the enhancements
made to the Liquidity/Concentration Risk Component is to reduce risk to
the CME Clearing House by conservatively increasing margin requirements
for positions which are expected to be more difficult to close out.
1.5 New F/X Related Risk Component
CME is proposing to address F/X related risks associated with the
inclusion of non-USD denominated CDS positions in CDS portfolios (each
a ``Non-USD CDS Positions''). As proposed above, CME will allow for
correlation based risk offsets with respect to both Market Risk
Components and Idiosyncratic Risk Components of the Proposed CDS Margin
Model. The calculation of such risk offsets will require that the
Market Risk Components and Idiosyncratic Risk Components be calculated
in USD (or other such common/base currency as may be chosen from time
to time). In order to calculate the USD requirements, profit and loss
due to market and idiosyncratic factors (``P&L'') will be converted
into their USD equivalents based on conservative F/X rates. The USD
equivalent requirements for the Market Risk Component and the
Idiosyncratic Risk Component will then be apportioned into each
currency specific sub-portfolio based on its Market Risk Component and
Idiosyncratic Risk Component requirements.
With respect to the Interest Rate Sensitivity Component and the
Liquidity Risk/Concentration Component of the Proposed CDS Margin
Model, where CME does not propose to offer risk or diversification
offsets, only currency specific margin requirements are computed.
The overall risk requirement for each specific currency is then
calculated as the sum of (a) the currency specific Liquidity/
Concentration Risk Component requirement, (b) the currency specific
Interest Rate Sensitivity Component requirement, and (c) the sum of the
Market Risk Component and the Idiosyncratic Risk Component requirement
(apportioned to each specific currency). Under the Proposed CDS Margin
Model, CME will inform clearing members of their margin requirements
with respect to their multi-currency CDS positions in amounts that are
required to be posted for each denominated currency in their
portfolios.
2. Description of the Proposed Changes to Stress Test Methodology
2.1 Proposed Changes to CDS Stress Test Methodology for Sizing and
Allocation of CDS Financial Resources
CME currently utilizes a stressed extension of its margin model to
size the CDS Guaranty Fund and CDS Assessments (as defined in the CME
Rules). The ``potential residual loss'' used to size and allocate the
CDS Guaranty Fund and CDS Assessments is determined as the excess of
the stressed exposure for CDS products over the margin deposited for
CDS products. CME is proposing changes to the CDS Stress Test
Methodology in order to align it with the Proposed CDS Margin Model.
The proposed CDS Stress Test Methodology will rely on more extreme and
counter-cyclical scenarios for the calculation of the different risk
components compared to the scenarios used in the Proposed CDS Margin
Model.
2.2 New Self-Referencing Risk Component
Although CME does not permit a CDS Clearing Member or a customer to
enter into or maintain a single-name CDS position referencing the
clearing member or an affiliate, a self-referencing CDS position may
arise where the CDS Clearing Member or its affiliate is the Reference
Entity in respect of a component transaction within the index
referenced in a CDS position. For example, such a situation may arise
in the context of index CDS contracts which reference CDS Clearing
Members or their affiliates. In such cases, the CDS Clearing Member (a
``CDS SR Clearing Member''), either through its own account or that of
a customer, has exposure to a CDS Product that references itself or its
affiliate (each an ``SR Transaction''). CME proposes to address this
potential exposure to self-referencing risk by allocating an additional
JTD risk for each CDS SR Clearing Member under its Stress Test
Methodology. CME considers a CDS Clearing Member default to be an
extreme tail risk event which is subject to the CDS financial
safeguards, including mutualization across all other CDS Clearing
Members via the CDS Guaranty Fund.
Currently, CDS SR Clearing Members, clearing self-referencing
indices for itself or its customers, are required to collateralize the
self-referencing exposure in an amount specified in the CME Rules. CME
is now proposing to adopt a risk based approach without reference to
any preset threshold, to capture this self-referencing risk. The
additional risk associated with CDS SR Clearing Members will be added
to the stress scenarios used to size the CDS Guaranty Fund and CME will
require each CDS SR Clearing Member to make an additional CDS Guaranty
Fund Deposit to address this risk (such additional deposit, the ``CDS
SR Deposit''). The net theoretical self-referencing exposure of each
CDS Clearing Member is computed as the additional theoretical self-
referencing ``potential residual loss'' to CME in extreme but plausible
market conditions using the stress testing methodology determined by
the CDS Risk Committee. The aggregate amount of CDS SR Deposits will be
sized to cover the sum of the net theoretical self-referencing
exposures of two CDS SR Clearing Members which would create the two
largest net theoretical self-referencing exposures.\4\ The required CDS
SR Deposit will then be allocated to each CDS SR Clearing Member in
proportion to each such CDS SR Clearing Member's net self-referencing
exposure.
---------------------------------------------------------------------------
\4\ For purposes of determining the two largest potential
residual losses, the self-referencing exposure of a CDS SR Clearing
Member will be aggregated with that of any affiliated CDS SR
Clearing Member.
---------------------------------------------------------------------------
A new CME Rule 8H06 (CDS SR Deposit) has been added to accurately
reflect these proposed changes to the CDS Guaranty Fund in the CME
Rules, and CME Rule 8H802.B (Satisfaction of Clearing House
Obligations) has been amended to reflect the introduction of the CDS SR
Deposit. In addition, provisions in CME Rule 80104.A (Clearing Through
Clearing Member's House (or Proprietary) Account) and CME Rule 80104.B
(Clearing Through Clearing Members Customer Account) that relate to the
requirement by clearing members that clear self-referencing indices for
themselves or their customers to collateralize the self-referencing
exposure in an amount specified in the CME Rules have been deleted.
A CDS Clearing Member default may result in contagion among
financial institutions, widening spreads and exposing portfolios
consisting of index CDS that reference financial entities to potential
wrong-way risk. For example, the default of a CDS Clearing Member based
in the United States, which is not referenced in an index referencing
European names, could lead to overall widening of the credit spreads
among financial institutions worldwide, leading to widening of spreads
in non-US indices. This may lead to variations in correlations between
such non-US indices and other North American indices, potentially
adversely impacting
[[Page 48808]]
certain portfolios which are sensitive to such correlations. This
increase in potential exposure caused by contagion is addressed in the
CME Proposed CDS Risk Model and Stress Test Methodology via
incorporation of stressed correlation scenarios.
2.3 Portfolio Margining Implications
The Proposed CDS Margin Model relies on a statistical model to
support a scenario-based approach in line with the joint probability
distribution characteristics of par spreads of index series or
reference entities across standard maturities. The Market Risk
Component of the Proposed CDS Margin Model provides risk offsets
between single-name CDS positions and index CDS positions. Such risk
offsets are driven by the dependence structure across spread scenarios
imposed by historical and counter-cyclical stressed correlations.
The Interest Rate Sensitivity Component for a portfolio containing
index and single-name CDS products is designed as an aggregate risk
component across index and single-name CDS positions.
Under the Proposed CDS Margin Model, the JTD component of the
margin is computed by aggregating the exposure to the default of a
reference entity in both single-name CDS positions and index CDS
positions. CME relies on a decomposition model to compute the JTD
component of the margin requirement for a CDS portfolio containing
index and single-name CDS products.
The Liquidity/Concentration Risk Component of the Proposed CDS
Margin Model is driven by an expected liquidation process in which the
market risk exposure of the portfolio is first hedged with the most
liquid CDS instrument and then the resulting basis (hedged) portfolio
is liquidated. The margin requirements of the Liquidity/Concentration
Risk Component that are driven by market risk hedging costs are
calculated by aggregating the market risk exposure of the index and
single-name CDS positions. Index and single-name CDS positions are
handled separately for the calculation of the basis risk margin
requirement (due to unwinding of hedged positions) of the Liquidity/
Concentration Risk Component and also for the modeling of the
concentration margin requirement as a function of position size.
b. Statutory Basis
CME believes the proposed rule change is consistent with the
requirements of the Exchange Act, including Section 17A of the Exchange
Act,\5\ and the applicable regulations thereunder. The proposed rule
change is designed to promote the prompt and accurate clearance and
settlement of securities transactions and, to the extent applicable,
derivatives agreements, contracts, and transactions, to assure the
safeguarding of securities and funds which are in the custody or
control of the clearing agency or for which it is responsible, and, in
general, to protect investors and the public interest consistent with
Section 17A(b)(3)(F) of the Exchange Act.\6\
---------------------------------------------------------------------------
\5\ 15 U.S.C. 78q-1.
\6\ 15 U.S.C. 78q-1(b)(3)(F).
---------------------------------------------------------------------------
The proposed rule change accomplishes these objectives because it
is intended to more accurately capture different sources of risk
through a holistic and theoretically coherent scenario-based approach
that is driven by conservative statistical assumptions, which in turn
allows CME to appropriately cover the risk of a wide range of
theoretical and production portfolios under extreme but plausible
market conditions and in historical back testing, going back to 2008.
In particular, the amendments will enhance CME's margin methodology by
more accurately addressing F/X risk and self-referencing risk presented
by clearing index CDS contracts.
CME will also promote the efficient use of margin for the
clearinghouse and its Clearing Members and their customers by enabling
CME to provide appropriate portfolio margining treatment between index
and single-name CDS positions and as such contribute to the
safeguarding of securities and funds in CME's custody or control or for
which CME is responsible and the protection of investors.\7\
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\7\ Id.
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CME also believes the proposed rule change is consistent with the
requirements of Rule 17Ad-22 of the Exchange Act.\8\ In particular, in
terms of financial resources, CME believes that the proposed rule
change will continue to ensure sufficient margin to cover its credit
exposure to its clearing members, consistent with the requirements of
Rule 17Ad-22(b)(2) \9\ and Rule 17Ad-22(d)(14) \10\ and that the CDS
Guaranty Fund contributions and required margin, both as modified by
the proposed rule change, will provide sufficient financial resources
to withstand a default by the two participant families to which it has
the largest exposures in extreme but plausible market conditions
consistent with the requirements of Rule 17Ad-22(b)(3).\11\ In
addition, CME believes that the proposed rule change is consistent with
CME's requirement to limit its exposures to potential losses from
defaults by its participants under normal market conditions pursuant to
17Ad-22(b)(1).\12\ CME also believes that the proposed rule change will
continue to allow for it to take timely action to contain losses and
liquidity pressures and to continue meeting its obligations in the
event of clearing member insolvencies or defaults, in accordance with
Rule 17Ad-22(d)(11).\13\
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\8\ 17 CFR 240.19b-4.
\9\ 17 CFR 240.17Ad-22(b)(2).
\10\ 17 CFR 240.17Ad-22(d)(14).
\11\ 17 CFR 240.17Ad-22(b)(3).
\12\ 17 CFR 240.17Ad-22(b)(1).
\13\ 17 CFR 240.17Ad-22(d)(11).
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B. Self-Regulatory Organization's Statement on Burden on Competition
CME does not believe that the proposed rule change will have any
impact, or impose any burden, on competition. The proposed rule change
reflects enhancements to CME's CDS Risk Model. CME does not believe
that any increase in margin or CDS Guaranty Fund contributions, would
significantly affect the ability of Clearing Members or other market
participants to continue to clear CDS, consistent with the risk
management requirements of CME, or otherwise limit market participants'
choices for selecting clearing services. For the foregoing reasons, the
Proposed CDS Risk Model does not, in CME's view, impose any unnecessary
or inappropriate burden on competition.
C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants, or Others
Written comments relating to the Proposed CDS Risk Model have not
been solicited or received. CME will notify the Commission of any
written comments received by CME.
III. Date of Effectiveness of the Proposed Rule Change and Timing for
Commission Action
Within 45 days of the date of publication of this notice in the
Federal Register or within such longer period up to 90 days (i) as the
Commission may designate if it finds such longer period to be
appropriate and publishes its reasons for so finding or (ii) as to
which the self-regulatory organization consents, the Commission will:
(A) by order approve or disapprove such proposed rule change, or
(B) institute proceedings to determine whether the proposed rule
change should be disapproved.
[[Page 48809]]
IV. Solicitation of Comments
Interested persons are invited to submit written data, views and
arguments concerning the foregoing, including whether the proposed rule
change is consistent with the Act. Comments may be submitted by any of
the following methods:
Electronic Comments
Use the Commission's Internet comment form (https://www.sec.gov/rules/sro.shtml), or
Send an email to rule-comments@sec.gov. Please include
File No. SR-CME-2014-28 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-CME-2014-28. 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 or
10:00 a.m. and 3:00 p.m. Copies of such filing also will be available
for inspection and copying at the principal office of CME and on CME's
Web site at https://www.cmegroup.com/market-regulation/rule-filings.html.
All comments received will be posted without change; the Commission
does not edit personal identifying information from submissions. You
should submit only information that you wish to make available
publicly.
All submissions should refer to File Number SR-CME-2014-28 and
should be submitted on or before September 8, 2014.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\14\
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\14\ 17 CFR 200.30-3(a)(12).
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Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-19527 Filed 8-15-14; 8:45 am]
BILLING CODE 8011-01-P