Self-Regulatory Organizations; The Options Clearing Corporation; Notice of Filing of Advance Notice of and No Objection to The Options Clearing Corporation's Proposal To Enter a New Credit Facility Agreement, 60214-60217 [2014-23698]
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Federal Register / Vol. 79, No. 193 / Monday, October 6, 2014 / Notices
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.6
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–23697 Filed 10–3–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–73257; File No. SR–OCC–
2014–806]
Self-Regulatory Organizations; The
Options Clearing Corporation; Notice
of Filing of Advance Notice of and No
Objection to The Options Clearing
Corporation’s Proposal To Enter a New
Credit Facility Agreement
September 30, 2014.
Notice is hereby given that, on
September 11, 2014, The Options
Clearing Corporation (‘‘OCC’’) filed an
advance notice with the Securities and
Exchange Commission (‘‘Commission’’)
pursuant to Section 806(e) of Title VIII
of the Dodd-Frank Wall Street Reform
and Consumer Protection Act,1 entitled
the Payment, Clearing, and Settlement
Supervision Act of 2010 (‘‘Payment,
Clearing, and Settlement Supervision
Act’’), and Rule 19b–4(n)(1)(i) of the
Securities Exchange Act of 1934
(‘‘Exchange Act’’).2 The advance notice
is described in Items I and II below,
which Items have been prepared by
OCC. The Commission is publishing
this notice to solicit comments from
interested persons, and to provide
notice that the Commission has no
objection to the changes set forth in the
advance notice and authorizes OCC to
implement those changes earlier than 60
days after the filing of the advance
notice.
I. Clearing Agency’s Statement of the
Terms of Substance of the Advance
Notice
This advance notice is filed by OCC
in connection with a proposed change
to its operations to replace an existing
credit facility OCC maintains for the
purposes of meeting obligations arising
17 CFR 200.30–3(a)(12).
Wall Street Reform and Consumer
Protection Act, Pub. L. 111–203, 124 Stat. 1376
(2010). OCC was designated as a systemically
important financial market utility by the Financial
Stability Oversight Council on July 18, 2012. See
Financial Stability Oversight Council 2012 Annual
Report, Appendix A, https://www.treasury.gov/
initiatives/fsoc/Documents/
2012%20Annual%20Report.pdf. Therefore, OCC is
required to comply with Title VIII of the DoddFrank Wall Street Reform and Consumer Protection
Act.
2 17 CFR 240.19b–4(n)(1)(i).
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1 Dodd-Frank
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out of the default or suspension of a
clearing member, in anticipation of a
potential default by a clearing member,
or the failure of a bank or securities or
commodities clearing organization to
perform its obligations due to its
bankruptcy, insolvency, receivership or
suspension of operations.
II. Clearing Agency’s Statement of the
Purpose of, and Statutory Basis for, the
Advance Notice
In its filing with the Commission,
OCC included statements concerning
the purpose of and basis for the advance
notice and discussed any comments it
received on the advance notice. The text
of these statements may be examined at
the places specified in Item IV below.
OCC has prepared summaries, set forth
in sections A and B below, of the most
significant aspects of these statements.
A. Clearing Agency’s Statement on
Comments on the Advance Notice
Received From Members, Participants or
Others
Written comments were not and are
not intended to be solicited with respect
to the advance notice and none have
been received.
B. Advance Notices Filed Pursuant to
Section 806(e) of the Payment, Clearing,
and Settlement Supervision Act
(i) Description of Change
This advance notice is being filed in
connection with a proposed change in
the form of the replacement of a credit
facility that OCC maintains for the
purposes of meeting obligations arising
out of the default or suspension of a
clearing member, in anticipation of a
potential default by a clearing member,
or the failure of a bank or securities or
commodities clearing organization to
perform its obligations due to its
bankruptcy, insolvency, receivership or
suspension of operations. OCC’s
existing credit facility (the ‘‘Existing
Facility’’) was implemented on October
10, 2013 through the execution of a
Credit Agreement among OCC,
JPMorgan Chase Bank, N.A.
(‘‘JPMorgan’’), as administrative agent,
and the lenders that are parties to the
agreement from time to time, which
provides short-term secured borrowings
in an aggregate principal amount of $2
billion and may be increased to $3
billion.3
3 On May 12, 2014, OCC executed an amendment
to the Existing Facility regarding its ability to
pledge Canadian Government securities to support
borrowings. To hold Canadian Government
securities and Canadian dollars pledged by OCC,
JPMorgan established at its London branch a
securities and a deposit account in the name of
JPMorgan, as administrative agent for the Existing
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The Existing Facility is set to expire
on October 9, 2014 and OCC is therefore
currently negotiating the terms of a new
credit facility (the ‘‘New Facility’’) on
substantially similar terms as the
Existing Facility, except that
enhancements are being added for a
back-up administrative agent in case the
primary administrative agent is unable
to perform its obligations and to allow
OCC to request borrowings directly from
individual lenders. A back-up
administrative agent would provide
OCC with additional safety and stability
in the event the primary administrative
agent is not able to perform its duties
under the new Facility. On September 5,
2014, OCC received a Commitment
Letter with regard to the New Facility
from: JPMorgan, the administrative
agent, collateral agent, and a lender for
the New Facility; J.P. Morgan Securities
LLC (‘‘JPMorgan Securities’’), the joint
lead arranger for the New Facility;
Merrill Lynch, Pierce, Fenner & Smith
Incorporated (‘‘MLPF&S’’), the joint lead
arranger for the New Facility; and Bank
of America, N.A. (‘‘BANA’’), the
syndication agent and a lender for the
New Facility.
The terms and conditions applicable
to the New Facility are set forth in the
Summary of Terms and Conditions
attached to this filing as Exhibit 3. The
conditions to the availability of the new
facility include the execution and
delivery of (i) a credit agreement
between OCC, JPMorgan, BANA and the
various lenders under the New Facility,
(ii) a pledge agreement between OCC
and JPMorgan, and (iii) a custodian
agreement between OCC and JPMorgan
which OCC anticipates will occur on or
before October 7, 2014.
Upon the successful syndication of
the New Facility, a syndicate of banks,
financial institutions and other entities
will make loans to OCC on request. The
aggregate amount of loans available
under the facility, subject to the value
of eligible collateral, is up to $2 billion.
During the term of the New Facility, the
amount of the New Facility may be
increased to up to $3 billion if OCC so
requests and if sufficient commitments
from lenders are received and
accepted.4
The Existing Facility included a
tranche that could be drawn on in
Facility. OCC and JPMorgan executed an English
law governed charge agreement pursuant to which
OCC pledged the securities and cash at any time
deposited in such accounts. A new English law
governed charge agreement is expected to be
entered into in connection with the New Facility.
4 OCC is in the process of finalizing an additional
$1 billion of liquidity with a non-bank provider to
promote observance of its minimum liquidity
requirements.
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Federal Register / Vol. 79, No. 193 / Monday, October 6, 2014 / Notices
dollars or euros and a dollar-only
tranche. The dollar equivalent of the
total loans denominated in euros under
the euro/dollar tranche of the Existing
Facility could not exceed $100 million.
The New Facility does not contain a
euro/dollar tranche, the ability to
borrow in euros or a euro administrative
agent because OCC no longer has any
euro-denominated product lines.
Additionally, the Existing Facility
provided OCC with the ability to make
test borrowings, which become due and
payable on the day after such
borrowings are made, in an amount not
greater than $10,000,000 for the purpose
of testing communication and draw
procedures. Under the New Facility, the
$10,000,000 cap on test borrowings will
be removed so that test draws can more
closely simulate the dollar amount of an
actual draw and to be consistent with
other credit facilities in the marketplace
that do not have caps on test draws.
The New Facility is available on a
revolving basis for a 364-day term. OCC
may request a loan under the New
Facility on any business day by
providing a notice to JPMorgan, as
administrative agent, which will then
notify the lenders, who will be required
to fund their pro rata share of any
requested loan within a specified period
of time after receiving notice from
JPMorgan. The funding deadline is
designed to permit OCC to obtain funds
on the date of the request, subject to a
cutoff time after which funding will
occur on the next business day. Each
loan issued pursuant to the New Facility
matures and is payable 30 days after the
borrowing date, except for test
borrowings under the facility, which
mature and are payable one business
day after the borrowing date. Proceeds
of loans under the New Facility must be
used to meet the obligations of OCC
arising out of the default or suspension
of a clearing member, in anticipation of
a potential default by a clearing
member, or the failure of a bank or
securities or commodities clearing
organization to perform its obligations
to OCC. In order to obtain a loan under
the facility, OCC must pledge as
collateral U.S. dollars or securities
issued or guaranteed by the U.S.
Government or the Government of
Canada that are margin deposits of
suspended members or that are held in
OCC’s clearing fund, and in either case
the administrative agent must have a
valid and enforceable first priority
perfected lien and security interest in
such collateral under the applicable
laws of the United States or other
applicable jurisdiction. Securities
issued by the Government of Canada
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will only be eligible to be pledged as
collateral if they have a minimum rating
of AAA/Aaa as determined by S&P or
Moody’s. OCC has the authority to
pledge these assets in connection with
borrowings under Section 5(e) of Article
VIII of its By-Laws and Rule 1104(b).
The amount available under the New
Facility at any given point in time is
equal to the lesser of (i) $2 billion, or the
increased size of the facility, if
applicable, and (ii) the sum of (A) 90%
of the value of OCC’s clearing fund that
is not subject to liens or encumbrances
granted by OCC other than in
connection with the New Facility and
(B) 90% of the value of unencumbered
margin deposits of suspended clearing
members that are not subject to liens or
encumbrances granted by OCC other
than in connection with the New
Facility. If the aggregate principal
amount of loans under the New Facility
exceeds the amount available under this
formula, OCC must prepay loans, obtain
the release of liens and/or require
additional margin and/or clearing fund
deposits to cure the deficiency. A
condition to the making of any loan
under the New Facility is that, after
giving effect to the loan, the dollar value
of the aggregate loans under the New
Facility may not exceed the ‘‘borrowing
base.’’ The borrowing base is
determined by adding the value of all
collateral pledged in connection with all
loans under the New Facility, after
applying ‘‘haircuts’’ to U.S. and
Canadian Government securities based
on their remaining maturity. If the
borrowing base is less than the sum of
100% of the outstanding loans under
the New Facility, OCC must repay loans
or pledge additional collateral to cure
the deficiency. There are additional
customary conditions to the making of
any loan under the New Facility,
including that OCC is not in default.
Importantly, however, the absence of a
material adverse change affecting OCC
is not a condition to the making of a
loan. Loans may be prepaid at any time
without penalty.
Events of default by OCC under the
New Facility include, but are not
limited to, non-payment of principal,
interest, fees or other amounts when
due; non-compliance with a daily
borrowing base when loans are
outstanding; material inaccuracy of
representations and warranties;
bankruptcy events; fundamental
changes; and failure to maintain a first
priority perfected security interest in
collateral. In the event of a default, the
interest rate applicable to outstanding
loans would increase by 2.00%. The
New Facility also includes customary
defaulting lender provisions, including
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provisions that restrict the defaulting
lender’s voting rights, permit set-offs of
payments against the defaulting lender
and suspend the defaulting lender’s
right to receive commitment fees.
The New Facility involves a variety of
customary fees payable by OCC,
including: (1) A one-time arrangement
fee payable to JPMorgan Securities and
MLPF&S; (2) a one-time administrative
and collateral agent fee payable to
JPMorgan if the New Facility closes; (3)
upfront commitment fees payable to the
lenders based on the amount of their
commitments; and (4) an ongoing
quarterly commitment fee based on the
unused amount of the New Facility.
(ii) Anticipated Effect on and
Management of Risk
Overall, the New Facility reduces the
risks to OCC, its clearing members and
the options market in general because it
will allow OCC to obtain short-term
funds to address liquidity demands
arising out of the default or suspension
of a clearing member, in anticipation of
a potential default or suspension of
clearing members or the insolvency of a
bank or another securities or
commodities clearing organization. The
existence of the New Facility could
enable OCC to minimize losses in the
event of such a default, suspension or
insolvency, by allowing it to obtain
funds on extremely short notice to
ensure that the clearance and settlement
of transactions in options and other
contracts occurs without interruption.
By drawing on the facility OCC would
be able to avoid liquidating margin or
clearing fund assets in what would
likely be volatile market conditions,
which would preserve funds available
to cover any losses resulting from the
failure of a clearing member, bank or
another clearing organization. OCC’s
entering into the New Facility will not
increase the risks associated with its
clearing function because it is entered
into on substantially the same terms as
the Existing Facility.
Two additional features carried
through from the Existing Facility to the
New Facility will enhance OCC
liquidity and reduce risk. The inclusion
of Canadian Government securities as
eligible collateral will increase the
amount of OCC collateral that can be
pledged to support borrowings under
the New Facility, resulting in increased
availability of loans. The clarification
that OCC may borrow under the New
Facility in anticipation of a potential
default by or suspension of a clearing
member may be subject to a requirement
that OCC provide JPMorgan with
documentation supporting its
authorization to do so.
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While the New Facility will, in
general, reduce the risks associated with
OCC’s clearing function, like any
lending arrangement the New Facility
involves risks. One of the primary risks
to OCC and its clearing function
associated with the New Facility is the
risk that a lender fails to fund when
OCC requests a loan, because of the
lender’s insolvency or otherwise. This
risk is mitigated through the use of a
syndicated facility, which does not
depend on the creditworthiness of a
small number of lenders. In addition,
the New Facility has lender default
provisions designed to discourage
lenders from failing to fund loans.
Moreover, OCC has the ability under the
New Facility to replace a defaulting
lender. Finally, in the event a particular
lender fails to fund its portion of the
requested loan, the New Facility
includes provisions pursuant to which
OCC may request ‘‘covering’’ loans from
non-defaulting lenders to make up the
shortfall. Alternatively, OCC may
simply make a second borrowing
request for the shortfall amount that
lenders are committed to make, subject
to OCC’s satisfying the borrowing
conditions for the second loan, although
in either case the total amount available
for borrowing under the New Facility
would be reduced by the unfunded
commitment of the defaulting lender.
The failure by one or more lenders to
fund the first loan does not relieve the
lenders of their commitment to fund the
second loan.
A second risk associated with the
New Facility is the risk that OCC is
unable to repay a loan within 30 days,
which would allow the lenders to seize
the pledged collateral and liquidate it,
potentially at depressed prices that
would result in losses to OCC. OCC
believes that this risk is at a manageable
level, because 30 days should be an
adequate period of time to allow OCC to
generate funds to repay the loans under
the New Facility, such as by liquidating
clearing fund assets other than those
pledged to secure the loans. As
provided in Section 5(e) of Article VIII
of its By-Laws, if the loans have not
been repaid within 30 days, the amount
of clearing fund assets used to secure
the loans will be considered to be an
actual loss to the clearing fund, which
will be allocated in accordance with
Section 5 of Article VIII, and the
proceeds of such allocation can be used
to repay the loans.
(iii) Consistency With the Payment,
Clearing, and Settlement Supervision
Act
OCC believes that the proposed
change is consistent with Section 805(b)
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of the Payment, Clearing and Settlement
Supervision Act 5 because it will
promote robust risk management.6 The
New Facility would provide OCC with
an additional source of liquidity to meet
its settlement obligations while at the
same time being structured to address
certain risks, as described above, that
arise in connection with the New
Facility. The New Facility could also
enable OCC to minimize losses in the
event of a default, suspension or
insolvency, by allowing it to obtain
funds on extremely short notice to
ensure that the clearance and settlement
of transactions in options and other
contracts occurs without interruption.
Moreover, the New Facility would
permit OCC to avoid liquidating margin
or clearing fund assets in what would
likely be volatile market conditions and
preserve sufficient financial resources to
cover any losses resulting from the
failure of a clearing member, bank or
other clearing organization.
be implemented in less than 60 days
from the date the advance notice is
filed, or the date further information
requested by the Commission is
received, if the Commission notifies the
clearing agency in writing that it does
not object to the proposed change and
authorizes the clearing agency to
implement the proposed change on an
earlier date, subject to any conditions
imposed by the Commission.
The clearing agency shall post notice
on its Web site of proposed changes that
are implemented.
The proposal shall not take effect
until all regulatory actions required
with respect to the proposal are
completed.
(iv) Accelerated Commission Action
Requested
Pursuant to Section 806(e)(1)(I) of the
Payment, Clearing and Settlement
Supervision Act,7 OCC requests that the
Commission notify OCC that it has no
objection to the change no later than
September 30, 2014, which is one week
prior to the October 7, 2014 effective
date of the New Facility. OCC requests
Commission action one week in
advance of the effective date to ensure
that there is no period of time that OCC
operates without a credit facility, given
the importance of the borrowing
capacity in connection with OCC’s risk
management.
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–
OCC–2014–806 on the subject line.
III. Date of Effectiveness of the Advance
Notice and Timing for Commission
Action
The proposed change may be
implemented if the Commission does
not object to the proposed change
within 60 days of the later of (i) the date
that the proposed change was filed with
the Commission or (ii) the date that any
additional information requested by the
Commission is received. The clearing
agency shall not implement the
proposed change if the Commission has
any objection to the proposed change.
The Commission may extend the
period for review by an additional 60
days if the proposed change raises novel
or complex issues, subject to the
Commission providing the clearing
agency with prompt written notice of
the extension. A proposed change may
5 12
U.S.C. 5464(b).
U.S.C. 5464(b)(1).
7 12 U.S.C. 5465(e)(1)(I).
6 12
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IV. Solicitation of Comments
Interested persons are invited to
submit written data, views and
arguments concerning the foregoing.
Comments may be submitted by any of
the following methods:
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–OCC–2014–806. 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 of submission. 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 change that
are filed with the Commission, and all
written communications relating to the
proposed 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 Section, 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 such
filing also will be available for
inspection and copying at the principal
office of OCC and on OCC’s Web site at
https://www.theocc.com/components/
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docs/legal/rules_and_bylaws/sr_occ_14_
806.pdf.
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–OCC–2014–806 and should
be submitted on or before October 27,
2014.
V. Commission’s Findings and Notice of
No Objection
Section 806(e)(1)(G) of the Payment,
Clearing, and Settlement Supervision
Act 8 provides that a designated
financial market utility may implement
a change if it has not received an
objection from the Commission within
60 days of the later of (i) the date that
the Commission receives notice of the
proposed change or (ii) the date the
Commission receives any further
information it requests for consideration
of the notice. A designated financial
market utility may implement a
proposed change in less than 60 days
from the date of receipt of the notice of
the change by the Commission, or the
date the Commission receives any
further information it requested, if the
Commission notifies the designated
financial market utility in writing that it
does not object to the proposed change
and authorizes the designated financial
market utility to implement the
proposed change on an earlier date,
subject to any conditions imposed by
the Commission.
In its filing with the Commission,
OCC requested that the Commission
notify OCC that it has no objection to
the change no later than September 30,
2014, which is one week before the
October 7, 2014 effective date of the
New Facility. OCC requested
Commission action by this date to
ensure that there is no period of time
that OCC operates without a credit
facility, given the importance of the
borrowing capacity in connection with
OCC’s risk-management framework.
The Commission does not object to
the proposed change. Ensuring that OCC
has uninterrupted access to a credit
facility will promote the safety and
soundness of the broader financial
system by providing OCC with an
additional source of liquidity to meet its
clearance and settlement obligations in
the event of the failure of a clearing
member, bank, or clearing organization
doing business with OCC. Having access
to a credit facility will help OCC
minimize losses in the event of such a
8 12
U.S.C. 5465(e)(1)(G).
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failure by allowing it to access funds on
extremely short notice, and without
having to liquidate assets at a time when
market prices could be falling
precipitously.
VI. Conclusion
Pursuant to Section 806(e)(1)(I) of the
Payment, Clearing, and Settlement
Supervision Act,9 the Commission does
not object to the proposed change, and
authorizes OCC to implement the
change (SR–OCC–2014–806) as of the
date of this Order.
By the Commission.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–23698 Filed 10–3–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–73255; File No. SR–
NYSEMKT–2014–82]
Self-Regulatory Organizations; NYSE
MKT LLC; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change Amending Exchange
Rule 900.3NY (Orders Defined) To
Delete WAIT Orders From Its Rules
September 30, 2014.
Pursuant to Section 19(b)(1) 1 of the
Securities Exchange Act of 1934 (the
‘‘Act’’) 2 and Rule 19b–4 thereunder,3
notice is hereby given that on
September 24, 2014, NYSE MKT LLC
(the ‘‘Exchange’’ or ‘‘NYSE MKT’’) filed
with the Securities and Exchange
Commission (the ‘‘Commission’’) the
proposed rule change as described in
Items I and II below, which Items have
been prepared by the self-regulatory
organization. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to amend
Rule 900.3NY (Orders Defined) by
deleting WAIT orders from its rules. The
text of the proposed rule change is
available on the Exchange’s Web site at
www.nyse.com, at the principal office of
the Exchange, and at the Commission’s
Public Reference Room.
9 12
U.S.C. 5465(e)(1)(I).
U.S.C.78s(b)(1).
2 15 U.S.C. 78a.
3 17 CFR 240.19b–4.
1 15
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60217
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
self-regulatory organization included
statements concerning the purpose of,
and basis for, the proposed rule change
and discussed any comments it received
on the proposed rule change. The text
of those statements may be examined at
the places specified in Item IV below.
The Exchange has prepared summaries,
set forth in sections A, B, and C below,
of the most significant parts of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange proposes to amend
Rule 900.3NY (Orders Defined) to delete
WAIT Orders from its rules.
Per Rule 900.3NY(t), an order
designated as a WAIT Order, ‘‘is held
for one second without processing for
potential display and/or execution.
After one second, the order is processed
for potential display and/or execution in
accordance with all order entry
instructions as determined by the
entering party.’’ Due to a lack of demand
for WAIT Orders, the Exchange
proposes to discontinue functionality
supporting the order type. Accordingly,
the Exchange proposes to delete the
definition of WAIT Order from Rule
900.3NY(t) and hold this provision as
Reserved. The Exchange will announce
the implementation date of this change
through a Trader Update.
2. Statutory Basis
The proposed rule change is
consistent with Section 6(b) of the
Securities Exchange Act of 1934 (the
‘‘Act’’), in general, and furthers the
objectives of Section 6(b)(5), in
particular, in that it is designed to
prevent fraudulent and manipulative
acts and practices, to promote just and
equitable principles of trade, to foster
cooperation and coordination with
persons engaged in facilitating
transactions in securities, and to remove
impediments to and perfect the
mechanism of a free and open market
and a national market system.
Specifically, the Exchange believes that
by eliminating a little-used order type
the proposal will remove impediments
to and perfect the mechanisms of a free
and open market and add transparency
and clarity to the Exchange’s rules. The
Exchange further believes that deleting
an order type rarely used by investors
E:\FR\FM\06OCN1.SGM
06OCN1
Agencies
[Federal Register Volume 79, Number 193 (Monday, October 6, 2014)]
[Notices]
[Pages 60214-60217]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-23698]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-73257; File No. SR-OCC-2014-806]
Self-Regulatory Organizations; The Options Clearing Corporation;
Notice of Filing of Advance Notice of and No Objection to The Options
Clearing Corporation's Proposal To Enter a New Credit Facility
Agreement
September 30, 2014.
Notice is hereby given that, on September 11, 2014, The Options
Clearing Corporation (``OCC'') filed an advance notice with the
Securities and Exchange Commission (``Commission'') pursuant to Section
806(e) of Title VIII of the Dodd-Frank Wall Street Reform and Consumer
Protection Act,\1\ entitled the Payment, Clearing, and Settlement
Supervision Act of 2010 (``Payment, Clearing, and Settlement
Supervision Act''), and Rule 19b-4(n)(1)(i) of the Securities Exchange
Act of 1934 (``Exchange Act'').\2\ The advance notice is described in
Items I and II below, which Items have been prepared by OCC. The
Commission is publishing this notice to solicit comments from
interested persons, and to provide notice that the Commission has no
objection to the changes set forth in the advance notice and authorizes
OCC to implement those changes earlier than 60 days after the filing of
the advance notice.
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\1\ Dodd-Frank Wall Street Reform and Consumer Protection Act,
Pub. L. 111-203, 124 Stat. 1376 (2010). OCC was designated as a
systemically important financial market utility by the Financial
Stability Oversight Council on July 18, 2012. See Financial
Stability Oversight Council 2012 Annual Report, Appendix A, https://www.treasury.gov/initiatives/fsoc/Documents/2012%20Annual%20Report.pdf. Therefore, OCC is required to comply
with Title VIII of the Dodd-Frank Wall Street Reform and Consumer
Protection Act.
\2\ 17 CFR 240.19b-4(n)(1)(i).
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I. Clearing Agency's Statement of the Terms of Substance of the Advance
Notice
This advance notice is filed by OCC in connection with a proposed
change to its operations to replace an existing credit facility OCC
maintains for the purposes of meeting obligations arising out of the
default or suspension of a clearing member, in anticipation of a
potential default by a clearing member, or the failure of a bank or
securities or commodities clearing organization to perform its
obligations due to its bankruptcy, insolvency, receivership or
suspension of operations.
II. Clearing Agency's Statement of the Purpose of, and Statutory Basis
for, the Advance Notice
In its filing with the Commission, OCC included statements
concerning the purpose of and basis for the advance notice and
discussed any comments it received on the advance notice. The text of
these statements may be examined at the places specified in Item IV
below. OCC has prepared summaries, set forth in sections A and B below,
of the most significant aspects of these statements.
A. Clearing Agency's Statement on Comments on the Advance Notice
Received From Members, Participants or Others
Written comments were not and are not intended to be solicited with
respect to the advance notice and none have been received.
B. Advance Notices Filed Pursuant to Section 806(e) of the Payment,
Clearing, and Settlement Supervision Act
(i) Description of Change
This advance notice is being filed in connection with a proposed
change in the form of the replacement of a credit facility that OCC
maintains for the purposes of meeting obligations arising out of the
default or suspension of a clearing member, in anticipation of a
potential default by a clearing member, or the failure of a bank or
securities or commodities clearing organization to perform its
obligations due to its bankruptcy, insolvency, receivership or
suspension of operations. OCC's existing credit facility (the
``Existing Facility'') was implemented on October 10, 2013 through the
execution of a Credit Agreement among OCC, JPMorgan Chase Bank, N.A.
(``JPMorgan''), as administrative agent, and the lenders that are
parties to the agreement from time to time, which provides short-term
secured borrowings in an aggregate principal amount of $2 billion and
may be increased to $3 billion.\3\
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\3\ On May 12, 2014, OCC executed an amendment to the Existing
Facility regarding its ability to pledge Canadian Government
securities to support borrowings. To hold Canadian Government
securities and Canadian dollars pledged by OCC, JPMorgan established
at its London branch a securities and a deposit account in the name
of JPMorgan, as administrative agent for the Existing Facility. OCC
and JPMorgan executed an English law governed charge agreement
pursuant to which OCC pledged the securities and cash at any time
deposited in such accounts. A new English law governed charge
agreement is expected to be entered into in connection with the New
Facility.
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The Existing Facility is set to expire on October 9, 2014 and OCC
is therefore currently negotiating the terms of a new credit facility
(the ``New Facility'') on substantially similar terms as the Existing
Facility, except that enhancements are being added for a back-up
administrative agent in case the primary administrative agent is unable
to perform its obligations and to allow OCC to request borrowings
directly from individual lenders. A back-up administrative agent would
provide OCC with additional safety and stability in the event the
primary administrative agent is not able to perform its duties under
the new Facility. On September 5, 2014, OCC received a Commitment
Letter with regard to the New Facility from: JPMorgan, the
administrative agent, collateral agent, and a lender for the New
Facility; J.P. Morgan Securities LLC (``JPMorgan Securities''), the
joint lead arranger for the New Facility; Merrill Lynch, Pierce, Fenner
& Smith Incorporated (``MLPF&S''), the joint lead arranger for the New
Facility; and Bank of America, N.A. (``BANA''), the syndication agent
and a lender for the New Facility.
The terms and conditions applicable to the New Facility are set
forth in the Summary of Terms and Conditions attached to this filing as
Exhibit 3. The conditions to the availability of the new facility
include the execution and delivery of (i) a credit agreement between
OCC, JPMorgan, BANA and the various lenders under the New Facility,
(ii) a pledge agreement between OCC and JPMorgan, and (iii) a custodian
agreement between OCC and JPMorgan which OCC anticipates will occur on
or before October 7, 2014.
Upon the successful syndication of the New Facility, a syndicate of
banks, financial institutions and other entities will make loans to OCC
on request. The aggregate amount of loans available under the facility,
subject to the value of eligible collateral, is up to $2 billion.
During the term of the New Facility, the amount of the New Facility may
be increased to up to $3 billion if OCC so requests and if sufficient
commitments from lenders are received and accepted.\4\
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\4\ OCC is in the process of finalizing an additional $1 billion
of liquidity with a non-bank provider to promote observance of its
minimum liquidity requirements.
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The Existing Facility included a tranche that could be drawn on in
[[Page 60215]]
dollars or euros and a dollar-only tranche. The dollar equivalent of
the total loans denominated in euros under the euro/dollar tranche of
the Existing Facility could not exceed $100 million. The New Facility
does not contain a euro/dollar tranche, the ability to borrow in euros
or a euro administrative agent because OCC no longer has any euro-
denominated product lines. Additionally, the Existing Facility provided
OCC with the ability to make test borrowings, which become due and
payable on the day after such borrowings are made, in an amount not
greater than $10,000,000 for the purpose of testing communication and
draw procedures. Under the New Facility, the $10,000,000 cap on test
borrowings will be removed so that test draws can more closely simulate
the dollar amount of an actual draw and to be consistent with other
credit facilities in the marketplace that do not have caps on test
draws.
The New Facility is available on a revolving basis for a 364-day
term. OCC may request a loan under the New Facility on any business day
by providing a notice to JPMorgan, as administrative agent, which will
then notify the lenders, who will be required to fund their pro rata
share of any requested loan within a specified period of time after
receiving notice from JPMorgan. The funding deadline is designed to
permit OCC to obtain funds on the date of the request, subject to a
cutoff time after which funding will occur on the next business day.
Each loan issued pursuant to the New Facility matures and is payable 30
days after the borrowing date, except for test borrowings under the
facility, which mature and are payable one business day after the
borrowing date. Proceeds of loans under the New Facility must be used
to meet the obligations of OCC arising out of the default or suspension
of a clearing member, in anticipation of a potential default by a
clearing member, or the failure of a bank or securities or commodities
clearing organization to perform its obligations to OCC. In order to
obtain a loan under the facility, OCC must pledge as collateral U.S.
dollars or securities issued or guaranteed by the U.S. Government or
the Government of Canada that are margin deposits of suspended members
or that are held in OCC's clearing fund, and in either case the
administrative agent must have a valid and enforceable first priority
perfected lien and security interest in such collateral under the
applicable laws of the United States or other applicable jurisdiction.
Securities issued by the Government of Canada will only be eligible to
be pledged as collateral if they have a minimum rating of AAA/Aaa as
determined by S&P or Moody's. OCC has the authority to pledge these
assets in connection with borrowings under Section 5(e) of Article VIII
of its By-Laws and Rule 1104(b).
The amount available under the New Facility at any given point in
time is equal to the lesser of (i) $2 billion, or the increased size of
the facility, if applicable, and (ii) the sum of (A) 90% of the value
of OCC's clearing fund that is not subject to liens or encumbrances
granted by OCC other than in connection with the New Facility and (B)
90% of the value of unencumbered margin deposits of suspended clearing
members that are not subject to liens or encumbrances granted by OCC
other than in connection with the New Facility. If the aggregate
principal amount of loans under the New Facility exceeds the amount
available under this formula, OCC must prepay loans, obtain the release
of liens and/or require additional margin and/or clearing fund deposits
to cure the deficiency. A condition to the making of any loan under the
New Facility is that, after giving effect to the loan, the dollar value
of the aggregate loans under the New Facility may not exceed the
``borrowing base.'' The borrowing base is determined by adding the
value of all collateral pledged in connection with all loans under the
New Facility, after applying ``haircuts'' to U.S. and Canadian
Government securities based on their remaining maturity. If the
borrowing base is less than the sum of 100% of the outstanding loans
under the New Facility, OCC must repay loans or pledge additional
collateral to cure the deficiency. There are additional customary
conditions to the making of any loan under the New Facility, including
that OCC is not in default. Importantly, however, the absence of a
material adverse change affecting OCC is not a condition to the making
of a loan. Loans may be prepaid at any time without penalty.
Events of default by OCC under the New Facility include, but are
not limited to, non-payment of principal, interest, fees or other
amounts when due; non-compliance with a daily borrowing base when loans
are outstanding; material inaccuracy of representations and warranties;
bankruptcy events; fundamental changes; and failure to maintain a first
priority perfected security interest in collateral. In the event of a
default, the interest rate applicable to outstanding loans would
increase by 2.00%. The New Facility also includes customary defaulting
lender provisions, including provisions that restrict the defaulting
lender's voting rights, permit set-offs of payments against the
defaulting lender and suspend the defaulting lender's right to receive
commitment fees.
The New Facility involves a variety of customary fees payable by
OCC, including: (1) A one-time arrangement fee payable to JPMorgan
Securities and MLPF&S; (2) a one-time administrative and collateral
agent fee payable to JPMorgan if the New Facility closes; (3) upfront
commitment fees payable to the lenders based on the amount of their
commitments; and (4) an ongoing quarterly commitment fee based on the
unused amount of the New Facility.
(ii) Anticipated Effect on and Management of Risk
Overall, the New Facility reduces the risks to OCC, its clearing
members and the options market in general because it will allow OCC to
obtain short-term funds to address liquidity demands arising out of the
default or suspension of a clearing member, in anticipation of a
potential default or suspension of clearing members or the insolvency
of a bank or another securities or commodities clearing organization.
The existence of the New Facility could enable OCC to minimize losses
in the event of such a default, suspension or insolvency, by allowing
it to obtain funds on extremely short notice to ensure that the
clearance and settlement of transactions in options and other contracts
occurs without interruption. By drawing on the facility OCC would be
able to avoid liquidating margin or clearing fund assets in what would
likely be volatile market conditions, which would preserve funds
available to cover any losses resulting from the failure of a clearing
member, bank or another clearing organization. OCC's entering into the
New Facility will not increase the risks associated with its clearing
function because it is entered into on substantially the same terms as
the Existing Facility.
Two additional features carried through from the Existing Facility
to the New Facility will enhance OCC liquidity and reduce risk. The
inclusion of Canadian Government securities as eligible collateral will
increase the amount of OCC collateral that can be pledged to support
borrowings under the New Facility, resulting in increased availability
of loans. The clarification that OCC may borrow under the New Facility
in anticipation of a potential default by or suspension of a clearing
member may be subject to a requirement that OCC provide JPMorgan with
documentation supporting its authorization to do so.
[[Page 60216]]
While the New Facility will, in general, reduce the risks
associated with OCC's clearing function, like any lending arrangement
the New Facility involves risks. One of the primary risks to OCC and
its clearing function associated with the New Facility is the risk that
a lender fails to fund when OCC requests a loan, because of the
lender's insolvency or otherwise. This risk is mitigated through the
use of a syndicated facility, which does not depend on the
creditworthiness of a small number of lenders. In addition, the New
Facility has lender default provisions designed to discourage lenders
from failing to fund loans. Moreover, OCC has the ability under the New
Facility to replace a defaulting lender. Finally, in the event a
particular lender fails to fund its portion of the requested loan, the
New Facility includes provisions pursuant to which OCC may request
``covering'' loans from non-defaulting lenders to make up the
shortfall. Alternatively, OCC may simply make a second borrowing
request for the shortfall amount that lenders are committed to make,
subject to OCC's satisfying the borrowing conditions for the second
loan, although in either case the total amount available for borrowing
under the New Facility would be reduced by the unfunded commitment of
the defaulting lender. The failure by one or more lenders to fund the
first loan does not relieve the lenders of their commitment to fund the
second loan.
A second risk associated with the New Facility is the risk that OCC
is unable to repay a loan within 30 days, which would allow the lenders
to seize the pledged collateral and liquidate it, potentially at
depressed prices that would result in losses to OCC. OCC believes that
this risk is at a manageable level, because 30 days should be an
adequate period of time to allow OCC to generate funds to repay the
loans under the New Facility, such as by liquidating clearing fund
assets other than those pledged to secure the loans. As provided in
Section 5(e) of Article VIII of its By-Laws, if the loans have not been
repaid within 30 days, the amount of clearing fund assets used to
secure the loans will be considered to be an actual loss to the
clearing fund, which will be allocated in accordance with Section 5 of
Article VIII, and the proceeds of such allocation can be used to repay
the loans.
(iii) Consistency With the Payment, Clearing, and Settlement
Supervision Act
OCC believes that the proposed change is consistent with Section
805(b) of the Payment, Clearing and Settlement Supervision Act \5\
because it will promote robust risk management.\6\ The New Facility
would provide OCC with an additional source of liquidity to meet its
settlement obligations while at the same time being structured to
address certain risks, as described above, that arise in connection
with the New Facility. The New Facility could also enable OCC to
minimize losses in the event of a default, suspension or insolvency, by
allowing it to obtain funds on extremely short notice to ensure that
the clearance and settlement of transactions in options and other
contracts occurs without interruption. Moreover, the New Facility would
permit OCC to avoid liquidating margin or clearing fund assets in what
would likely be volatile market conditions and preserve sufficient
financial resources to cover any losses resulting from the failure of a
clearing member, bank or other clearing organization.
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\5\ 12 U.S.C. 5464(b).
\6\ 12 U.S.C. 5464(b)(1).
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(iv) Accelerated Commission Action Requested
Pursuant to Section 806(e)(1)(I) of the Payment, Clearing and
Settlement Supervision Act,\7\ OCC requests that the Commission notify
OCC that it has no objection to the change no later than September 30,
2014, which is one week prior to the October 7, 2014 effective date of
the New Facility. OCC requests Commission action one week in advance of
the effective date to ensure that there is no period of time that OCC
operates without a credit facility, given the importance of the
borrowing capacity in connection with OCC's risk management.
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\7\ 12 U.S.C. 5465(e)(1)(I).
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III. Date of Effectiveness of the Advance Notice and Timing for
Commission Action
The proposed change may be implemented if the Commission does not
object to the proposed change within 60 days of the later of (i) the
date that the proposed change was filed with the Commission or (ii) the
date that any additional information requested by the Commission is
received. The clearing agency shall not implement the proposed change
if the Commission has any objection to the proposed change.
The Commission may extend the period for review by an additional 60
days if the proposed change raises novel or complex issues, subject to
the Commission providing the clearing agency with prompt written notice
of the extension. A proposed change may be implemented in less than 60
days from the date the advance notice is filed, or the date further
information requested by the Commission is received, if the Commission
notifies the clearing agency in writing that it does not object to the
proposed change and authorizes the clearing agency to implement the
proposed change on an earlier date, subject to any conditions imposed
by the Commission.
The clearing agency shall post notice on its Web site of proposed
changes that are implemented.
The proposal shall not take effect until all regulatory actions
required with respect to the proposal are completed.
IV. Solicitation of Comments
Interested persons are invited to submit written data, views and
arguments concerning the foregoing. 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 Number SR-OCC-2014-806 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-OCC-2014-806. 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 of submission. 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 change that are
filed with the Commission, and all written communications relating to
the proposed 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 Section, 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 such filing also will be
available for inspection and copying at the principal office of OCC and
on OCC's Web site at https://www.theocc.com/components/
[[Page 60217]]
docs/legal/rules_and_bylaws/sr_occ_14_806.pdf.
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-OCC-2014-806
and should be submitted on or before October 27, 2014.
V. Commission's Findings and Notice of No Objection
Section 806(e)(1)(G) of the Payment, Clearing, and Settlement
Supervision Act \8\ provides that a designated financial market utility
may implement a change if it has not received an objection from the
Commission within 60 days of the later of (i) the date that the
Commission receives notice of the proposed change or (ii) the date the
Commission receives any further information it requests for
consideration of the notice. A designated financial market utility may
implement a proposed change in less than 60 days from the date of
receipt of the notice of the change by the Commission, or the date the
Commission receives any further information it requested, if the
Commission notifies the designated financial market utility in writing
that it does not object to the proposed change and authorizes the
designated financial market utility to implement the proposed change on
an earlier date, subject to any conditions imposed by the Commission.
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\8\ 12 U.S.C. 5465(e)(1)(G).
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In its filing with the Commission, OCC requested that the
Commission notify OCC that it has no objection to the change no later
than September 30, 2014, which is one week before the October 7, 2014
effective date of the New Facility. OCC requested Commission action by
this date to ensure that there is no period of time that OCC operates
without a credit facility, given the importance of the borrowing
capacity in connection with OCC's risk-management framework.
The Commission does not object to the proposed change. Ensuring
that OCC has uninterrupted access to a credit facility will promote the
safety and soundness of the broader financial system by providing OCC
with an additional source of liquidity to meet its clearance and
settlement obligations in the event of the failure of a clearing
member, bank, or clearing organization doing business with OCC. Having
access to a credit facility will help OCC minimize losses in the event
of such a failure by allowing it to access funds on extremely short
notice, and without having to liquidate assets at a time when market
prices could be falling precipitously.
VI. Conclusion
Pursuant to Section 806(e)(1)(I) of the Payment, Clearing, and
Settlement Supervision Act,\9\ the Commission does not object to the
proposed change, and authorizes OCC to implement the change (SR-OCC-
2014-806) as of the date of this Order.
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\9\ 12 U.S.C. 5465(e)(1)(I).
By the Commission.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-23698 Filed 10-3-14; 8:45 am]
BILLING CODE 8011-01-P