Self-Regulatory Organizations; Fixed Income Clearing Corporation; Order Approving Proposed Rule Change To Amend the Government Securities Division Rulebook in Order To Establish an Early Unwind Intraday Charge in Connection With the Inclusion of GCF Repo® Positions in GSD's Intraday Participant Clearing Fund Requirement, and GSD's Hourly Internal Surveillance Cycles, 63456-63458 [2014-25207]
Download as PDF
63456
Federal Register / Vol. 79, No. 205 / Thursday, October 23, 2014 / Notices
Section 6(b) of the Act,6 in general, and
furthers the objectives of Sections
6(b)(5) 7 and 6(b)(7) 8 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,
• to remove impediments to and
perfect the mechanism of a free and
open market and a national market
system, and in general, to protect
investors and the public interest, and
• to provide a fair procedure for the
disciplining of members.
The Exchange believes that the
proposed rule change will strengthen its
ability to carry out its responsibilities as
a self-regulatory organization by
clarifying that CFE may hold any parties
to and Authorized Reporters for an
ECRP transaction responsible for
compliance with the related rule
depending on the facts and
circumstances and by adding violations
to its Minor Rule Violation Rule. CFE
also believes that the additions to the
Minor Rule Violation Rule will serve as
an effective deterrent to future violative
conduct and as an effective and efficient
means of disciplining for infractions
that do not warrant a regular
disciplinary proceeding. CFE
additionally believes that these
additions will promote consistent
application of sanctions by the
Exchange for minor rule violations,
establish a fair procedure for the
disciplining of TPHs for minor rule
violations and reinforce its surveillance
and enforcement functions.
mstockstill on DSK4VPTVN1PROD with NOTICES
B. Self-Regulatory Organization’s
Statement on Burden on Competition
CFE does not believe that the
proposed rule change will impose any
burden on competition not necessary or
appropriate in furtherance of the
purposes of the Act, in that the rule
change makes enhancements to CFE’s
ability to deter and discipline certain
infractions. The Exchange believes that
the proposed rule change is equitable
and not unfairly discriminatory because
the clarification of compliance
responsibilities with respect to ECRP
transactions and all of the additions to
the Minor Rule Violation Rule would
apply equally to all parties that are
subject to the applicable requirements.
6 15
U.S.C. 78f(b).
U.S.C. 78f(b)(5).
8 15 U.S.C. 78f(b)(7).
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
No written comments were solicited
or received with respect to the proposed
rule change.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
The proposed rule change will
become effective on October 16, 2014.
At any time within 60 days of the date
of effectiveness of the proposed rule
change, the Commission, after
consultation with the CFTC, may
summarily abrogate the proposed rule
change and require that the proposed
rule change be refiled in accordance
with the provisions of Section 19(b)(1)
of the Act.9
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 Number SR–
CFE–2014–003 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–CFE–2014–003. 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
7 15
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9 15
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U.S.C. 78s(b)(1).
Frm 00080
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printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of such
filing also will be available for
inspection and copying at the principal
offices of the Exchange. All comments
received will be posted without change;
the Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–CFE–
2014–003, and should be submitted on
or before November 13, 2014.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.10
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–25201 Filed 10–22–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–73389; File No. SR–FICC–
2014–01]
Self-Regulatory Organizations; Fixed
Income Clearing Corporation; Order
Approving Proposed Rule Change To
Amend the Government Securities
Division Rulebook in Order To
Establish an Early Unwind Intraday
Charge in Connection With the
Inclusion of GCF Repo® Positions in
GSD’s Intraday Participant Clearing
Fund Requirement, and GSD’s Hourly
Internal Surveillance Cycles
October 17, 2014.
I. Introduction
On August 11, 2014, the Fixed Income
Clearing Corporation (‘‘FICC’’) filed
with the Securities and Exchange
Commission (‘‘Commission’’) proposed
rule change SR–FICC–2014–01 pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder.2 The proposed rule
10 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4. FICC also filed a proposed
change as an advance notice concerning GSD’s
inclusion of GCF® repo positions in its intraday
participant clearing fund requirement calculation
and its hourly internal surveillance cycles under
Section 806(e)(1) of the Payment, Clearing, and
Settlement Supervision Act of 2010 (‘‘Payment,
Clearing and Settlement Supervision Act). 12 U.S.C.
5465(e)(1). Securities Exchange Act Release No.
71469 (February 4, 2014), 79 FR 7722 (February 10,
2014) (SR–FICC–2014–801). FICC subsequently
amended the advance notice to establish the Early
Unwind Intraday Charge described herein.
Securities Exchange Act Release No. 73187
1 15
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Federal Register / Vol. 79, No. 205 / Thursday, October 23, 2014 / Notices
change was published for comment in
the Federal Register on August 29,
2014.3 The Commission received no
comment letters in response to the
proposed rule change. For the reasons
discussed below, the Commission is
approving the proposed rule change.
II. Description
FICC proposed to amend the
Government Securities Division
(‘‘GSD’’) Rulebook (the ‘‘Rules’’) in
order to establish an Early Unwind
Intraday Charge (‘‘EUIC’’) to protect
against the exposure that may result
from a member’s intraday substitution
of cash for securities that were used as
collateral for a GCF Repo® position the
prior day (‘‘Cash Substitution’’) or a
clearing bank unwind of the cash
lending side of the transaction for an
inter-bank GCF Repo transaction at 7:30
a.m. (ET) (‘‘Early Unwind’’) 4 in
connection with including the
underlying collateral pertaining to the
GCF Repo® 5 positions in GSD’s noon
intraday 6 participant Clearing Fund
requirement (‘‘CFR’’) calculation, and its
hourly internal surveillance cycles.
Background
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On January 10, 2014, FICC filed
advance notice SR–FICC–2014–801 7
(‘‘Advance Notice’’) with the
Commission. This filing describes
FICC’s proposal to include the
underlying collateral pertaining to the
GCF Repo® positions in its noon
intraday participant CFR calculation,
and its hourly internal surveillance
cycles. FICC intended this enhancement
to align GSD’s risk management
calculations and monitoring with the
changes that have been implemented to
the tri-party infrastructure by the TriParty Repo Infrastructure Reform Task
(September 23, 2014), 79 FR 58007 (September 26,
2014) (SR–FICC–2014–801).
3 Securities Exchange Act Release No. 72908
(August 25, 2014), 79 FR 51630 (August 29, 2014)
(SR–FICC–2014–01).
4 The Early Unwind refers to the automatic return
of the collateral from the reverse repo side (cash
lender) to FICC’s account at the repo side’s (cash
borrower’s) settlement bank and the return of cash
to the reverse repo side, which typically occurs
before the opening of Fedwire.
5 The GCF Repo® service enables dealers to trade
general collateral repos, based on rate, term, and
underlying product, throughout the day without
requiring intra-day, trade-for- trade settlement on a
Deliver-versus-Payment (‘‘DVP’’) basis. The service
fosters a highly liquid market for securities
financing. GCF Repo® is a registered trademark of
The Depository Trust & Clearing Corporation.
6 Noon intraday refers to the routine intraday
margining cycle which is based on a 12:00 p.m. (ET)
position snap shot. Pursuant to Rule 4, FICC may
request additional margin outside of the formal
intraday margin calls.
7 See supra note 2.
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16:52 Oct 22, 2014
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Force (‘‘Task Force’’),8 specifically, with
respect to locking up of GCF Repo®
collateral until 3:30 p.m. (ET) rather
than 7:30 a.m. (ET). Subsequent to the
initial Advance Notice filing, FICC
discovered that under the proposed
change, a potential exposure may result
from a GCF Repo® participant’s Cash
Substitutions and Early Unwinds. As a
result, on August 11, 2014, FICC filed
this proposed rule change.9
Specifically, FICC discovered that
there were instances where exposure to
FICC arose as a result of certain Cash
Substitutions or Early Unwind. This is
because the noon intraday underlying
collateral pertaining to the GCF Repo®
positions of impacted participants may
exhibit a different risk profile than their
same end-of-day (‘‘EOD’’) 10 positions.
The impact could be to increase or
decrease the Value-at-Risk (‘‘VaR’’)
component of the CFR.
In certain instances, Cash
Substitutions, for repo and reverse repo
positions and Early Unwinds for reverse
repo positions, could result in higher
cash balances in the underlying
collateral pertaining to GCF Repo®
positions at noon intraday than the
same EOD, and could present a
potential under-margin condition
because cash collateral is not margined.
In addition, FICC noted that it is likely
that the cash will be replaced by
securities in the next GCF Repo®
allocation of collateral. The undermargin condition will exist overnight
because the VaR on the GCF Repo®
collateral in the same EOD cycle will
not be calculated until after Fedwire is
closed thus precluding members from
satisfying margin deficits until the
morning of the next business day.
(b) Proposed Change
FICC’s rule change amends GSD’s
Rules to establish the EUIC to protect
against the exposure that may result
from a member’s Cash Substitutions or
Early Unwinds.11 GSD will adjust the
8 The Task Force was formed in September 2009
under the auspices of the Payments Risk
Committee, a private-sector body sponsored by the
Federal Reserve Bank of New York. The Task
Force’s goal is to enhance the repo market’s ability
to navigate stressed market conditions by
implementing changes that help better safeguard
the market. DTCC, FICC’s parent company, has
worked in close collaboration with the Task Force
on their reform initiatives.
9 At the same time, FICC filed Amendment No. 1
to the Advance Notice with the Commission, which
contains the same change. See supra note 2.
10 As used herein, ‘‘prior EOD’’ refers to the end
of day cycle immediately preceding the current
noon intraday cycle and ‘‘same EOD’’ refers to the
end of day cycle immediately subsequent to the
current noon intraday cycle.
11 If, however, a member is assessed an EUIC
under circumstances that were not initially
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63457
noon intraday CFR in the form of an
EUIC to address this risk. In order to
determine whether an EUIC should be
applied, GSD will take the following
steps:
1. At noon, GSD will compare the
prior EOD VaR component of the CFR
calculation with the current day’s noon
intraday VaR component of the CFR
calculation.
2. If the current day’s noon intraday
VaR calculation is equal to or higher
than the prior EOD’s VaR calculation
then GSD will not apply an EUIC. If
however, the current day’s noon
calculation is lower, then GSD will
proceed to the step 3 below.
3. GSD will review the GCF Repo®
participant’s DVP and GCF Repo®
portfolio to determine whether the
reduction in the noon calculation may
be attributable to Cash Substitutions or
Early Unwinds. If so, then GSD will
apply the EUIC.
4. At the participant level, the EUIC 12
will be the lesser of (i) the net VaR
decrease that may be deemed to be
attributable to either cash substitutions
and/or early unwind of interbank
allocations or (ii) the prior EOD VaR
minus the noon intraday VaR.13
The EUIC for Cash Substitutions will
apply to the repo side (cash borrower)
and the reverse repo side (cash lender)
of the transaction. As such, the reverse
repo side is subject to the EUIC
notwithstanding its inability to control
the Cash Substitutions. The EUIC for
Cash Substitutions applies to the reverse
repo side because although they do not
initiate the Cash Substitutions, the Cash
Substitutions change the participant’s
risk profile and as a result, their noon
contemplated and the EUIC charge is deemed
unnecessary, FICC management has the discretion
to waive such charge.
12 The EUIC will be included in the noon intraday
participant CFR, but not the same EOD CFR. This
is because the risk associated with cash lockups
exists at intraday, that is, at any time before at EOD.
At EOD in the normal course of business, GCF
Repo® positions consist of 100% eligible non-cash
securities. GCF Repo® is used for overnight
financing of securities inventory. Absent
extraordinary circumstances, participants do not
use cash to collateralized overnight cash loans.
Cash Substitutions occur at intraday as participants
substitute in cash to withdraw securities they need
for intraday deliveries.
13 In the event that a Cash Substitution or Early
Unwind impacts the CFR, the prior end of day CFR
is used as a proxy for the same end of day CFR for
the portion of the portfolio that is impacted by such
Cash Substitutions or Early Unwind of interbank
allocations. The EUIC is designed to prevent the
impact of Cash Substitutions and Early Unwind of
interbank allocations from unduly reducing noon
intraday CFR relative to the prior EOD CFR
calculation, thus the EUIC will not increase the
noon intraday CFR above the prior EOD CFR
calculation. (But the noon intraday CFR calculation
exclusive of EUIC could be higher than the prior
EOD CFR calculation).
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Federal Register / Vol. 79, No. 205 / Thursday, October 23, 2014 / Notices
mstockstill on DSK4VPTVN1PROD with NOTICES
intraday CFR could be unduly reduced.
The EUIC for Early Unwinds will only
apply to the reverse repo side (cash
lender) since it is only the reverse side
whose lockup is unwound early. The
securities subject to the Early Unwind
are not returned to the repo side (cash
borrower) in connection with Early
Unwinds. Early Unwinds are performed
on the reverse repo side to ensure that
the underlying collateral is available to
the repo side at its settlement bank. As
such, the reverse repo side is subject to
the EUIC notwithstanding its inability to
control the Early Unwind as their noon
intraday CFR could be unduly reduced
as a result of such Early Unwinds. GSD
has discussed the EUIC with the
participants that are likely to be
materially impacted by this proposed
charge. These participants did not
express any concerns about the EUIC.
There is no automatic unwind (return
of securities) to the repo side. If the repo
side needs its securities before the 3:30
p.m. (ET) scheduled unwind, it may
perform a securities-for-securities
substitution or a cash-for-securities
substitution (in which case it may be
subject to the EUIC).
III. Discussion
Section 19(b)(2)(C) of the Act 14
directs the Commission to approve a
self-regulatory organization’s proposed
rule change if the Commission finds that
such proposed rule change is consistent
with the requirements of the Act and the
rules and regulations thereunder
applicable to such organization. Section
17A(b)(3)(F) of the Act 15 requires,
among other things, that the rules of a
clearing agency are designed 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.
The Commission finds that the
proposed rule change to establish the
EUIC to protect against the exposure
that may result from intraday Cash
Substitutions and Early Unwinds in
connection with FICC’s proposal to
include the underlying collateral
pertaining to the GCF Repo® positions
in GSD’s noon intraday participant CFR
calculation and hourly internal
surveillance cycles is consistent with
Section 17A(b)(3)(F) of the Act.16
Although the inclusion of GCF Repo®
positions into intraday participant CFR
calculations and hourly surveillance
cycles may better reflect the actual risk
in its members’ portfolios, the inclusion
of the EUIC may allow FICC to use even
14 15
U.S.C. 78s(b)(2)(C).
U.S.C. 78q–1(b)(3)(F).
16 15 U.S.C. 78q–1(b)(3)(F).
15 15
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16:52 Oct 22, 2014
Jkt 235001
more accurate and current position
information in its margin calculations
and mitigate the effects of Cash
Substitutions and Early Unwinds that
occur during the intraday period. This
more accurate margin calculation may
allow FICC to better safeguard and
secure securities and funds which are in
its custody or control or for which it is
responsible.
The proposed change is also
consistent with Rule 17Ad–22 17 of the
Clearing Agency Standards which
establishes the minimum requirements
regarding how registered clearing
agencies must maintain effective risk
management procedures and controls.
Specifically, Rule 17Ad–22(b)(1)
requires a clearing agency that performs
CCP services to establish, implement,
maintain, and enforce written policies
reasonably designed to measure its
credit exposures at least daily and to
limit exposures to potential losses from
defaults by participants under normal
market conditions so that the operations
of the clearing agency should not be
disrupt and non-defaulting participants
would not be exposed to losses that they
cannot anticipate or control.18 Rule
17Ad–22(b)(2) requires FICC to
establish, implement, maintain, and
enforce written policies and procedures
reasonably designed to use margin
requirements to limit its credit
exposures to participants under normal
market conditions and use risk-based
models and parameters to set margin
requirements.19 To these ends, the
change may provide FICC with a more
accurate measurement of daily credit
exposure using a risk-based model and
is designed to address exposures that
may occur from intraday activity. In
sum, FICC’s more accurate and timely
calculations around and monitoring of
GCF Repo® activity should better enable
FICC to respond in the event that a
member defaults.
IV. Conclusion
On the basis of the foregoing, the
Commission concludes that the
proposal is consistent with the
requirements of the Act, particularly the
requirements of Section 17A of the
Act,20 and the rules and regulations
thereunder.
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,21 that the
17 17
CFR 240.17Ad–22.
CFR 240.17Ad–22(b)(1).
19 17 CFR 240.17Ad–22(b)(2).
20 15 U.S.C. 78q–1.
21 15 U.S.C. 78s(b)(2).
22 In approving the proposed rule change, the
Commission considered the proposal’s impact on
efficiency, competition, and capital formation. 15
U.S.C. 78c(f).
18 17
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Frm 00082
Fmt 4703
Sfmt 4703
proposed rule change (File No. SR–
FICC–2014–01) be and hereby is
approved.22
For the Commission by the Division of
Trading and Markets, pursuant to delegated
authority.23
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–25207 Filed 10–22–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–73388; File No. SR–FICC–
2014–801]
Self-Regulatory Organizations; The
Fixed Income Clearing Corporation;
Notice of No Objection to Advance
Notice Filing, as Amended by
Amendment No. 1, Concerning the
Government Security Division’s
Inclusion of GCF Repo® Positions in
Its Intraday Participant Clearing Fund
Requirement Calculation, and Its
Hourly Internal Surveillance Cycles
October 17, 2014.
On January 10, 2014, The Fixed
Income Clearing Corporation (‘‘FICC’’)
filed with the Securities and Exchange
Commission (‘‘Commission’’) advance
notice SR–FICC–2014–801 (‘‘Advance
Notice’’) pursuant to Section
806(e)(1)(A) of the Payment, Clearing,
and Settlement Supervision Act of 2010
(‘‘Payment, Clearing and Settlement
Supervision Act’’ or ‘‘Title VIII’’) 1 and
Rule 19b–4(n)(1)(i) of the Securities
Exchange Act of 1934 (‘‘Act’’).2 The
Advance Notice was published for
comment in the Federal Register on
February 10, 2014.3 On March 10, 2014,
the Commission staff sent FICC a letter,
pursuant to Section 806(e)(1)(D) 4 and
Commission authorization, requesting
additional information regarding this
advance notice.5 FICC filed an
amendment to the Advance Notice on
August 11, 2014, which was published
23 17
CFR 200.30–3(a)(12).
U.S.C. 5465(e)(1)(A). The Financial Stability
Oversight Council designated FICC a systemically
important financial market utility 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, FICC is
required to comply with Title VIII of the Payment,
Clearing and Settlement Supervision Act.
2 17 CFR 240.19b–4(n)(1)(i).
3 Securities Exchange Act Release No. 71469 (Feb.
4, 2014), 79 FR 7722 (Feb. 10, 2014) (SR–FICC–
2014–801).
4 12 U.S.C. 5465(e)(1)(D).
5 The Commission received a response to this
request for additional information August 19, 2014,
at which time a 60 day review period for the
Advance Notice began pursuant to Section
806(e)(1)(G). 12 U.S.C. 5465(e)(1)(G).
1 12
E:\FR\FM\23OCN1.SGM
23OCN1
Agencies
[Federal Register Volume 79, Number 205 (Thursday, October 23, 2014)]
[Notices]
[Pages 63456-63458]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-25207]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-73389; File No. SR-FICC-2014-01]
Self-Regulatory Organizations; Fixed Income Clearing Corporation;
Order Approving Proposed Rule Change To Amend the Government Securities
Division Rulebook in Order To Establish an Early Unwind Intraday Charge
in Connection With the Inclusion of GCF Repo[supreg] Positions in GSD's
Intraday Participant Clearing Fund Requirement, and GSD's Hourly
Internal Surveillance Cycles
October 17, 2014.
I. Introduction
On August 11, 2014, the Fixed Income Clearing Corporation
(``FICC'') filed with the Securities and Exchange Commission
(``Commission'') proposed rule change SR-FICC-2014-01 pursuant to
Section 19(b)(1) of the Securities Exchange Act of 1934 (``Act'') \1\
and Rule 19b-4 thereunder.\2\ The proposed rule
[[Page 63457]]
change was published for comment in the Federal Register on August 29,
2014.\3\ The Commission received no comment letters in response to the
proposed rule change. For the reasons discussed below, the Commission
is approving the proposed rule change.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4. FICC also filed a proposed change as an
advance notice concerning GSD's inclusion of GCF[supreg] repo
positions in its intraday participant clearing fund requirement
calculation and its hourly internal surveillance cycles under
Section 806(e)(1) of the Payment, Clearing, and Settlement
Supervision Act of 2010 (``Payment, Clearing and Settlement
Supervision Act). 12 U.S.C. 5465(e)(1). Securities Exchange Act
Release No. 71469 (February 4, 2014), 79 FR 7722 (February 10, 2014)
(SR-FICC-2014-801). FICC subsequently amended the advance notice to
establish the Early Unwind Intraday Charge described herein.
Securities Exchange Act Release No. 73187 (September 23, 2014), 79
FR 58007 (September 26, 2014) (SR-FICC-2014-801).
\3\ Securities Exchange Act Release No. 72908 (August 25, 2014),
79 FR 51630 (August 29, 2014) (SR-FICC-2014-01).
---------------------------------------------------------------------------
II. Description
FICC proposed to amend the Government Securities Division (``GSD'')
Rulebook (the ``Rules'') in order to establish an Early Unwind Intraday
Charge (``EUIC'') to protect against the exposure that may result from
a member's intraday substitution of cash for securities that were used
as collateral for a GCF Repo[supreg] position the prior day (``Cash
Substitution'') or a clearing bank unwind of the cash lending side of
the transaction for an inter-bank GCF Repo transaction at 7:30 a.m.
(ET) (``Early Unwind'') \4\ in connection with including the underlying
collateral pertaining to the GCF Repo[supreg] \5\ positions in GSD's
noon intraday \6\ participant Clearing Fund requirement (``CFR'')
calculation, and its hourly internal surveillance cycles.
---------------------------------------------------------------------------
\4\ The Early Unwind refers to the automatic return of the
collateral from the reverse repo side (cash lender) to FICC's
account at the repo side's (cash borrower's) settlement bank and the
return of cash to the reverse repo side, which typically occurs
before the opening of Fedwire.
\5\ The GCF Repo[supreg] service enables dealers to trade
general collateral repos, based on rate, term, and underlying
product, throughout the day without requiring intra-day, trade-for-
trade settlement on a Deliver-versus-Payment (``DVP'') basis. The
service fosters a highly liquid market for securities financing. GCF
Repo[supreg] is a registered trademark of The Depository Trust &
Clearing Corporation.
\6\ Noon intraday refers to the routine intraday margining cycle
which is based on a 12:00 p.m. (ET) position snap shot. Pursuant to
Rule 4, FICC may request additional margin outside of the formal
intraday margin calls.
---------------------------------------------------------------------------
Background
On January 10, 2014, FICC filed advance notice SR-FICC-2014-801 \7\
(``Advance Notice'') with the Commission. This filing describes FICC's
proposal to include the underlying collateral pertaining to the GCF
Repo[supreg] positions in its noon intraday participant CFR
calculation, and its hourly internal surveillance cycles. FICC intended
this enhancement to align GSD's risk management calculations and
monitoring with the changes that have been implemented to the tri-party
infrastructure by the Tri-Party Repo Infrastructure Reform Task Force
(``Task Force''),\8\ specifically, with respect to locking up of GCF
Repo[supreg] collateral until 3:30 p.m. (ET) rather than 7:30 a.m.
(ET). Subsequent to the initial Advance Notice filing, FICC discovered
that under the proposed change, a potential exposure may result from a
GCF Repo[supreg] participant's Cash Substitutions and Early Unwinds. As
a result, on August 11, 2014, FICC filed this proposed rule change.\9\
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\7\ See supra note 2.
\8\ The Task Force was formed in September 2009 under the
auspices of the Payments Risk Committee, a private-sector body
sponsored by the Federal Reserve Bank of New York. The Task Force's
goal is to enhance the repo market's ability to navigate stressed
market conditions by implementing changes that help better safeguard
the market. DTCC, FICC's parent company, has worked in close
collaboration with the Task Force on their reform initiatives.
\9\ At the same time, FICC filed Amendment No. 1 to the Advance
Notice with the Commission, which contains the same change. See
supra note 2.
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Specifically, FICC discovered that there were instances where
exposure to FICC arose as a result of certain Cash Substitutions or
Early Unwind. This is because the noon intraday underlying collateral
pertaining to the GCF Repo[supreg] positions of impacted participants
may exhibit a different risk profile than their same end-of-day
(``EOD'') \10\ positions. The impact could be to increase or decrease
the Value-at-Risk (``VaR'') component of the CFR.
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\10\ As used herein, ``prior EOD'' refers to the end of day
cycle immediately preceding the current noon intraday cycle and
``same EOD'' refers to the end of day cycle immediately subsequent
to the current noon intraday cycle.
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In certain instances, Cash Substitutions, for repo and reverse repo
positions and Early Unwinds for reverse repo positions, could result in
higher cash balances in the underlying collateral pertaining to GCF
Repo[supreg] positions at noon intraday than the same EOD, and could
present a potential under-margin condition because cash collateral is
not margined. In addition, FICC noted that it is likely that the cash
will be replaced by securities in the next GCF Repo[supreg] allocation
of collateral. The under-margin condition will exist overnight because
the VaR on the GCF Repo[supreg] collateral in the same EOD cycle will
not be calculated until after Fedwire is closed thus precluding members
from satisfying margin deficits until the morning of the next business
day.
(b) Proposed Change
FICC's rule change amends GSD's Rules to establish the EUIC to
protect against the exposure that may result from a member's Cash
Substitutions or Early Unwinds.\11\ GSD will adjust the noon intraday
CFR in the form of an EUIC to address this risk. In order to determine
whether an EUIC should be applied, GSD will take the following steps:
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\11\ If, however, a member is assessed an EUIC under
circumstances that were not initially contemplated and the EUIC
charge is deemed unnecessary, FICC management has the discretion to
waive such charge.
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1. At noon, GSD will compare the prior EOD VaR component of the CFR
calculation with the current day's noon intraday VaR component of the
CFR calculation.
2. If the current day's noon intraday VaR calculation is equal to
or higher than the prior EOD's VaR calculation then GSD will not apply
an EUIC. If however, the current day's noon calculation is lower, then
GSD will proceed to the step 3 below.
3. GSD will review the GCF Repo[supreg] participant's DVP and GCF
Repo[supreg] portfolio to determine whether the reduction in the noon
calculation may be attributable to Cash Substitutions or Early Unwinds.
If so, then GSD will apply the EUIC.
4. At the participant level, the EUIC \12\ will be the lesser of
(i) the net VaR decrease that may be deemed to be attributable to
either cash substitutions and/or early unwind of interbank allocations
or (ii) the prior EOD VaR minus the noon intraday VaR.\13\
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\12\ The EUIC will be included in the noon intraday participant
CFR, but not the same EOD CFR. This is because the risk associated
with cash lockups exists at intraday, that is, at any time before at
EOD. At EOD in the normal course of business, GCF Repo[supreg]
positions consist of 100% eligible non-cash securities. GCF
Repo[supreg] is used for overnight financing of securities
inventory. Absent extraordinary circumstances, participants do not
use cash to collateralized overnight cash loans. Cash Substitutions
occur at intraday as participants substitute in cash to withdraw
securities they need for intraday deliveries.
\13\ In the event that a Cash Substitution or Early Unwind
impacts the CFR, the prior end of day CFR is used as a proxy for the
same end of day CFR for the portion of the portfolio that is
impacted by such Cash Substitutions or Early Unwind of interbank
allocations. The EUIC is designed to prevent the impact of Cash
Substitutions and Early Unwind of interbank allocations from unduly
reducing noon intraday CFR relative to the prior EOD CFR
calculation, thus the EUIC will not increase the noon intraday CFR
above the prior EOD CFR calculation. (But the noon intraday CFR
calculation exclusive of EUIC could be higher than the prior EOD CFR
calculation).
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The EUIC for Cash Substitutions will apply to the repo side (cash
borrower) and the reverse repo side (cash lender) of the transaction.
As such, the reverse repo side is subject to the EUIC notwithstanding
its inability to control the Cash Substitutions. The EUIC for Cash
Substitutions applies to the reverse repo side because although they do
not initiate the Cash Substitutions, the Cash Substitutions change the
participant's risk profile and as a result, their noon
[[Page 63458]]
intraday CFR could be unduly reduced. The EUIC for Early Unwinds will
only apply to the reverse repo side (cash lender) since it is only the
reverse side whose lockup is unwound early. The securities subject to
the Early Unwind are not returned to the repo side (cash borrower) in
connection with Early Unwinds. Early Unwinds are performed on the
reverse repo side to ensure that the underlying collateral is available
to the repo side at its settlement bank. As such, the reverse repo side
is subject to the EUIC notwithstanding its inability to control the
Early Unwind as their noon intraday CFR could be unduly reduced as a
result of such Early Unwinds. GSD has discussed the EUIC with the
participants that are likely to be materially impacted by this proposed
charge. These participants did not express any concerns about the EUIC.
There is no automatic unwind (return of securities) to the repo
side. If the repo side needs its securities before the 3:30 p.m. (ET)
scheduled unwind, it may perform a securities-for-securities
substitution or a cash-for-securities substitution (in which case it
may be subject to the EUIC).
III. Discussion
Section 19(b)(2)(C) of the Act \14\ directs the Commission to
approve a self-regulatory organization's proposed rule change if the
Commission finds that such proposed rule change is consistent with the
requirements of the Act and the rules and regulations thereunder
applicable to such organization. Section 17A(b)(3)(F) of the Act \15\
requires, among other things, that the rules of a clearing agency are
designed 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.
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\14\ 15 U.S.C. 78s(b)(2)(C).
\15\ 15 U.S.C. 78q-1(b)(3)(F).
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The Commission finds that the proposed rule change to establish the
EUIC to protect against the exposure that may result from intraday Cash
Substitutions and Early Unwinds in connection with FICC's proposal to
include the underlying collateral pertaining to the GCF Repo[supreg]
positions in GSD's noon intraday participant CFR calculation and hourly
internal surveillance cycles is consistent with Section 17A(b)(3)(F) of
the Act.\16\ Although the inclusion of GCF Repo[supreg] positions into
intraday participant CFR calculations and hourly surveillance cycles
may better reflect the actual risk in its members' portfolios, the
inclusion of the EUIC may allow FICC to use even more accurate and
current position information in its margin calculations and mitigate
the effects of Cash Substitutions and Early Unwinds that occur during
the intraday period. This more accurate margin calculation may allow
FICC to better safeguard and secure securities and funds which are in
its custody or control or for which it is responsible.
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\16\ 15 U.S.C. 78q-1(b)(3)(F).
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The proposed change is also consistent with Rule 17Ad-22 \17\ of
the Clearing Agency Standards which establishes the minimum
requirements regarding how registered clearing agencies must maintain
effective risk management procedures and controls. Specifically, Rule
17Ad-22(b)(1) requires a clearing agency that performs CCP services to
establish, implement, maintain, and enforce written policies reasonably
designed to measure its credit exposures at least daily and to limit
exposures to potential losses from defaults by participants under
normal market conditions so that the operations of the clearing agency
should not be disrupt and non-defaulting participants would not be
exposed to losses that they cannot anticipate or control.\18\ Rule
17Ad-22(b)(2) requires FICC to establish, implement, maintain, and
enforce written policies and procedures reasonably designed to use
margin requirements to limit its credit exposures to participants under
normal market conditions and use risk-based models and parameters to
set margin requirements.\19\ To these ends, the change may provide FICC
with a more accurate measurement of daily credit exposure using a risk-
based model and is designed to address exposures that may occur from
intraday activity. In sum, FICC's more accurate and timely calculations
around and monitoring of GCF Repo[supreg] activity should better enable
FICC to respond in the event that a member defaults.
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\17\ 17 CFR 240.17Ad-22.
\18\ 17 CFR 240.17Ad-22(b)(1).
\19\ 17 CFR 240.17Ad-22(b)(2).
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IV. Conclusion
On the basis of the foregoing, the Commission concludes that the
proposal is consistent with the requirements of the Act, particularly
the requirements of Section 17A of the Act,\20\ and the rules and
regulations thereunder.
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\20\ 15 U.S.C. 78q-1.
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It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\21\ that the proposed rule change (File No. SR-FICC-2014-01) be
and hereby is approved.\22\
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\21\ 15 U.S.C. 78s(b)(2).
\22\ In approving the proposed rule change, the Commission
considered the proposal's impact on efficiency, competition, and
capital formation. 15 U.S.C. 78c(f).
\23\ 17 CFR 200.30-3(a)(12).
For the Commission by the Division of Trading and Markets,
pursuant to delegated authority.\23\
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-25207 Filed 10-22-14; 8:45 am]
BILLING CODE 8011-01-P