Self-Regulatory Organizations; The Options Clearing Corporation; Notice of No Objection to Advance Notice Concerning the Implementation of a Committed Master Repurchase Agreement Program as Part of OCC's Overall Liquidity Plan, 1062-1065 [2015-00052]
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1062
Federal Register / Vol. 80, No. 5 / Thursday, January 8, 2015 / Notices
clearly evidences such competition.
NASDAQ is offering a new pricing
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The Exchange has witnessed
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C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received from
Members, Participants, or Others
No written comments were either
solicited or received.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
The foregoing rule change has become
effective pursuant to Section
19(b)(3)(A)(ii) of the Act.6
At any time within 60 days of the
filing of the proposed rule change, the
Commission summarily may
temporarily suspend such rule change if
it appears to the Commission that such
action is: (i) necessary or appropriate in
the public interest; (ii) for the protection
of investors; or (iii) otherwise in
furtherance of the purposes of the Act.
If the Commission takes such action, the
Commission shall institute proceedings
to determine whether the proposed rule
should be approved or disapproved.
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IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
6 15
U.S.C. 78s(b)(3)(A)(ii).
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17:07 Jan 07, 2015
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–
NASDAQ–2014–125 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Brent J. Fields, Secretary, Securities
and Exchange Commission, 100 F Street
NE., Washington, DC 20549–1090.
All submissions should refer to File
Number SR–NASDAQ–2014–125. This
file number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml ). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
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–NASDAQ–2014–125 and
should be submitted on or before
January 29, 2015.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.7
Brent J. Fields,
Secretary.
[FR Doc. 2015–00051 Filed 1–7–15; 8:45 am]
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SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–73979; File No. SR–OCC–
2014–809]
Self-Regulatory Organizations; The
Options Clearing Corporation; Notice
of No Objection to Advance Notice
Concerning the Implementation of a
Committed Master Repurchase
Agreement Program as Part of OCC’s
Overall Liquidity Plan
January 2, 2015.
On November 6, 2014, The Options
Clearing Corporation (‘‘OCC’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’) advance
notice SR–OCC–2014–809 (‘‘Advance
Notice’’) pursuant to Section 806(e)(1) of
the Payment, Clearing, and Settlement
Supervision Act of 2010 (‘‘Clearing
Supervision Act’’ or ‘‘Title VIII’’) 1 and
Rule 19b–4(n)(1)(i) under the Securities
Exchange Act of 1934 (‘‘Exchange
Act’’).2 The Advance Notice was
published for comment in the Federal
Register on December 9, 2014.3 The
Commission did not receive any
comments on the Advance Notice
publication. This publication serves as a
notice of no objection to the Advance
Notice.
I. Description of the Advance Notice
a. Background
The purpose of the proposed change
is to allow OCC to implement a
committed master repurchase agreement
program (‘‘MRA Program’’) in order to
access an additional committed source
of liquidity to meet its settlement
obligations in a manner that does not
increase the concentration of OCC’s
counterparty exposure, given OCC’s
existing affiliations between a number
of commercial banking institutions and
OCC’s clearing members. According to
OCC, the MRA Program will take the
form of OCC entering into a committed
master repurchase agreement and
related confirmations (together, the
‘‘Master Repurchase Agreement’’) with
one or more non-bank, non-clearing
1 12 U.S.C. 5465(e)(1). The Financial Stability
Oversight Council designated OCC 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, OCC is
required to comply with the Clearing Supervision
Act and file advance notices with the Commission.
See 12 U.S.C. 5465(e).
2 17 CFR 240.19b–4(n)(1)(i).
3 Securities Exchange Act Release No. 73726
(December 3, 2014), 79 FR 73116 (December 9,
2014) (SR–OCC–2014–809).
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member institutional investors.4 The
program will be part of OCC’s overall
liquidity plan that is meant to provide
OCC with access to diverse sources of
liquidity, which includes committed
credit facilities, securities lending and
securities repurchase arrangements, and
clearing member funding requirements
that, under certain conditions, allow
OCC to obtain funds from clearing
members.5
Although the Master Repurchase
Agreement would be based on the
standard form of master repurchase
agreement 6 so that it will be more
familiar to potential institutional
investors, OCC would require the
Master Repurchase Agreement to
contain certain additional provisions
tailored to ensure a reduction in
concentration risk, certainty of funding,
and operational effectiveness.
b. The Proposed MRA Program
i. Standard Repurchase Agreement
Terms
According to OCC, the Master
Repurchase Agreement generally will be
structured like a typical repurchase
arrangement, in order to help OCC
attract interest from potential
institutional investors willing to be
counterparties to OCC. Under the
Master Repurchase Agreement, the
buyer (i.e., the institutional investor) on
occasion would purchase from OCC
United States government securities
(‘‘Eligible Securities’’).7 OCC, as the
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4 OCC
states that it will conduct a due diligence
review with respect to each counterparty before
entering into a master repurchase arrangement with
it. Because the appropriate due diligence activities
and financial criteria will vary for each type of
counterparty, OCC will determine on a case-by-case
basis the specific due diligence criteria it would
implement. However, as the principal purpose of
due diligence will be to obtain assurance that each
counterparty has the financial ability to satisfy its
obligations under the program, the review will
encompass an assessment of the counterparty’s
financial statements (including external auditor
reports thereon) and, as applicable, ratings and/or
investment reports. Furthermore, OCC will identify
key criteria relative to monitoring the financial
stability of the counterparty on a going forward
basis.
5 See, e.g., Securities Exchange Act Release No.
72752 (August 4, 2014), 79 FR 46490 (August 8,
2014) (SR–OCC–2014–17), Securities Exchange Act
Release No. 71549 (February 12, 2014), 79 FR 03574
(February 19, 2014) (SR–OCC–2014–801) and
Securities Exchange Act Release No. 73257
(September 30, 2014), 79 FR 23698 (October 3,
2014) (SR–OCC–2014–806).
6 The standard form master repurchase agreement
is published by the Securities Industry and
Financial Markets Association and is commonly
used in the repurchase market by institutional
investors.
7 OCC would use U.S. government securities that
are included in clearing fund contributions by
clearing members and margin deposits of any
clearing member that has been suspended by OCC
for the repurchase arrangements. Article VIII,
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seller, will transfer Eligible Securities to
the buyer in exchange for a payment by
the buyer to OCC in immediately
available funds (‘‘Purchase Price’’). The
buyer will simultaneously agree to
transfer the purchased securities back to
OCC at a specified later date or on
OCC’s demand (‘‘Repurchase Date’’)
against the transfer of funds by OCC to
the buyer in an amount equal to the
outstanding Purchase Price plus the
accrued and unpaid price differential
(together, the ‘‘Repurchase Price’’),
which is the interest component of the
Repurchase Price.
At all times while a transaction is
outstanding, OCC will be required to
maintain a specified amount of
securities or cash margin with the
buyer.8 The market value of the
securities supporting each transaction
will be determined daily, typically
based on a price obtained from a
generally recognized pricing source. If
the market value of the purchased
securities is determined to have fallen
below OCC’s required margin, OCC will
be required to transfer to the buyer
sufficient cash or additional securities
reasonably acceptable to the buyer so
that OCC’s margin requirement is
satisfied.9 If the market value of the
purchased securities is determined to
have risen to above OCC’s required
margin, OCC will be permitted to
require the return of excess purchased
securities from the buyer.
As in a typical master repurchase
agreement, an event of default will
occur with respect to the buyer if the
buyer fails to purchase securities on a
purchase date, fails to transfer
purchased securities on any applicable
Repurchase Date, or fails to transfer any
interest, dividends or distributions on
purchased securities to OCC within a
specified period after receiving notice of
such failure. An event of default will
occur with respect to OCC if OCC fails
to transfer purchased securities on a
purchase date or fails to repurchase
purchased securities on an applicable
Repurchase Date. The Master
Repurchase Agreement also will provide
for standard events of default for either
party, including a party’s failure to
Section 5(e) of OCC’s By-Laws and OCC Rule
1104(b) authorize OCC to obtain funds from third
parties through securities repurchases using these
sources. The officers who may exercise this
authority include the Executive Chairman and the
President.
8 OCC expects that it would be required to
maintain margin equal to 102% of the Repurchase
Price which, according to OCC, is a standard rate
for arrangements involving U.S. government
securities.
9 OCC expects that it would use clearing fund
securities and securities posted as margin by
defaulting clearing members.
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maintain required margin or an
insolvency event with respect to one of
the parties.
Upon the occurrence of an event of
default, the non-defaulting party, at its
option, will have the right, among
others, to accelerate the Repurchase
Date of all outstanding transactions
between the defaulting party and the
non-defaulting party. For example, if
OCC were the defaulting party with
respect to a transaction and the buyer
chose to terminate the transaction, OCC
will be required to immediately transfer
the Repurchase Price to the buyer. If the
buyer were the defaulting party with
respect to a transaction and OCC chose
to terminate the transaction, the buyer
will be required to deliver all purchased
securities to OCC. If OCC or the buyer
does not perform in a timely manner,
the non-defaulting party will be
permitted to buy or sell, or deem itself
to have bought or sold, securities as
needed to be made whole and the
defaulting party will be required to pay
the costs related to any covering
transactions. Additionally, if OCC is
required to obtain replacement
securities as a result of an event of
default, the buyer will be required to
pay the excess of the price paid by OCC
to obtain replacement securities over the
Repurchase Price.
ii. Customized Features
As part of the Master Repurchase
Agreement, OCC will enter into an
individualized master confirmation
with each buyer and its agent which
will set forth certain terms and
conditions applicable to all transactions
entered into under the Master
Repurchase Agreement by that buyer.
According to OCC, these required terms
and conditions will be designed to
promote OCC’s goals of reduced
concentration risk, certainty of funding
and operational effectiveness. The terms
of the master confirmations under each
Master Repurchase Agreement may vary
from one another, because a separate
master confirmation will be negotiated
for a given buyer at the time that buyer
becomes a party to the Master
Repurchase Agreement. OCC has
identified the following as key
standards that will need to be
incorporated into each repurchase
arrangement entered into under the
program.10
10 OCC expects that the Master Repurchase
Agreement also will include other, more routine,
provisions such as the method for giving notices
and basic due authorization representations by the
parties.
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Counterparties
OCC only will enter into repurchase
arrangements with non-bank
institutional investors, such as pension
funds or insurance companies that are
not OCC clearing members or banks
affiliated with any OCC clearing
member. OCC believes this requirement
will allow OCC to access stable, reliable
sources of funding, without increasing
the concentration of its exposure to
counterparties that are affiliated banks,
broker/dealers and futures commission
merchants. OCC believes that this
reduction in concentration risk is a key
advantage of this proposed program.
Commitment to Fund and Funding
Accounts
OCC will seek funding commitments
from one or more potential
counterparties that will equal $1 billion
in the aggregate,11 with each
commitment extending for 364 days or
more. Each counterparty will be
obligated to enter into transactions
under the Master Repurchase
Agreement up to its committed amount
so long as no default had occurred and
OCC transferred sufficient Eligible
Securities. Each counterparty will be
obligated to enter into transactions even
if OCC had experienced a material
adverse change, such as the failure of a
clearing member. According to OCC,
this commitment to provide funding
will be a key departure from ordinary
repurchase arrangements and a key
requirement for OCC. Each commitment
will be supported by an agreement by
the counterparty to maintain cash and
investments acceptable to OCC that
must be readily converted into cash in
a designated account into which OCC
has visibility. OCC believes that the
creation of a funding account is
important because it will help OCC
ensure that the committed funds will be
available each day. OCC also believes
that it will facilitate prompt funding by
counterparties that are not commercial
banks and therefore are not in the
business of daily funding.
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Funding Mechanics
According to OCC, funding mechanics
will be targeted so that OCC will receive
the Purchase Price in immediately
available funds within 60 minutes of its
request for funds and delivery of
Eligible Securities and, if needed, prior
to OCC’s regular daily settlement time.12
11 The $1 billion in commitments could be spread
across multiple counterparties, but $1 billion
represents the proposed aggregate size of the
program.
12 According to OCC, this would include OCC’s
regular daily settlement time and any extended
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OCC believes that these targeted funding
mechanics will allow OCC to receive
needed liquidity in time to satisfy
settlement obligations, even in the event
of a default by a clearing member or a
market disruption. The funding
mechanism may be, for example,
delivery versus payment/receive versus
payment or another method acceptable
to OCC that both satisfies the objectives
of the MRA Program and presents
limited operational risks.
a specified time, so long as the Eligible
Securities satisfy any applicable criteria
contained in the Master Repurchase
Agreement and the transfer of the
Eligible Securities would not create a
margin deficit, as described above.14
OCC believes that this substitution right
is important because it must be able to
manage clearing member requests to
return excess or substitute Eligible
Securities in accordance with
established operational procedures.
No Rehypothecation
Under the terms of each master
confirmation, the buyer would not be
permitted to grant any third party an
interest in purchased securities, the
custody account at the custodian where
purchased securities are held, or any
cash held in OCC’s account. As a result,
OCC states that the buyer would be
prohibited from rehypothecating
purchased securities, the purchased
securities should never leave the
account, and there should be no thirdparty claims against the purchased
securities. OCC believes that the
prohibition on rehypothecation also
would reduce the risk that a third party
could interfere with the buyer’s transfer
of the purchased securities on the
Repurchase Date. Further, according to
OCC, the custodian would agree to
provide OCC with daily information
about each buyer’s account. OCC
believes that this visibility would allow
OCC to act quickly in the event a buyer
violates any requirements.
Events of Default
Early Termination Rights
Under the Master Repurchase
Agreement, OCC would have the ability
to terminate any transaction upon
written notice to the buyer, but a buyer
only would be able to terminate a
transaction upon the occurrence of an
event of default with respect to OCC.13
OCC has stated that this optional early
termination right is important because
its liquidity needs may change
unexpectedly over time and as a result
OCC may not want to keep a transaction
outstanding as long as originally
planned.
Substitution
Under the Master Repurchase
Agreement, OCC would have the ability
to substitute any Eligible Securities for
purchased securities in its discretion by
settlement time implemented by OCC in an
emergency situation under OCC Rule 505.
13 According to OCC, a notice of termination by
OCC would specify a new Repurchase Date prior to
the originally agreed upon Repurchase Date. Upon
the early termination of a transaction, the buyer
would be required to return all purchased securities
to OCC, and OCC would be required to pay the
Repurchase Price.
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In addition to the standard events of
default for a failure to purchase or
transfer securities on the applicable
Purchase Date or Repurchase Date, OCC
would require that the Master
Repurchase Agreement not contain any
additional events of default that would
restrict OCC’s access to funding and that
it contain an additional default remedy.
OCC would require that it would not be
an event of default if OCC suffers a
‘‘material adverse change.’’ 15 According
to OCC, this provision provides it with
certainty of funding, even in difficult
market conditions.
Upon the occurrence of an event of
default, in addition to the nondefaulting party’s right to accelerate the
Repurchase Date of all outstanding
transactions or to buy or sell securities
as needed to be made whole, the nondefaulting party may elect to take the
actions specified in the ‘‘mini close-out’’
provision of the Master Repurchase
Agreement, rather than declaring an
event of default.16 Therefore, if the
buyer fails to deliver purchased
securities on any Repurchase Date, OCC
believes that it would have remedies
that allow it to mitigate risk with respect
to a particular transaction, without
declaring an event of default with
14 In addition to its substitution rights, OCC could
cause the return of purchased securities by
exercising its optional early termination rights
under the Master Repurchase Agreement. If OCC
were to terminate part or all of a transaction, the
buyer would be required to return purchased
securities to OCC against payment of the
corresponding Repurchase Price.
15 According to OCC, a ‘‘material adverse change’’
is typically defined as a change that would have a
materially adverse effect on the business or
financial condition of a company.
16 For example, if the buyer fails to transfer
purchased securities on the applicable Repurchase
Date, rather than declaring an event of default, OCC
may (1) if OCC has already paid the Repurchase
Price, require the buyer to repay the Repurchase
Price, (2) if there is a margin excess, require the
buyer to pay cash or delivered purchased securities
in an amount equal to the margin excess, or (3)
declare that the applicable transaction, and only
that transaction, will be immediately terminated,
and apply default remedies under the Master
Repurchase Agreement to only that transaction.
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respect to all transactions under the
Master Repurchase Agreement.
II. Discussion and Commission
Findings
Although Title VIII does not specify a
standard of review for an advance
notice, the Commission believes that the
stated purpose of Title VIII is
instructive.17 The stated purpose of
Title VIII is to mitigate systemic risk in
the financial system and promote
financial stability by, among other
things, promoting uniform risk
management standards for systemicallyimportant financial market utilities
(‘‘FMUs’’) and strengthening the
liquidity of systemically important
FMUs.18
Section 805(a)(2) of the Clearing
Supervision Act 19 authorizes the
Commission to prescribe risk
management standards for the payment,
clearing, and settlement activities of
designated clearing entities and
financial institutions engaged in
designated activities for which it is the
supervisory agency or the appropriate
financial regulator. Section 805(b) of the
Clearing Supervision Act 20 states that
the objectives and principles for the risk
management standards prescribed under
Section 805(a) shall be to:
• Promote robust risk management;
• promote safety and soundness;
• reduce systemic risks; and
• support the stability of the broader
financial system.
The Commission has adopted risk
management standards under Section
805(a)(2) of the Clearing Supervision
Act (‘‘Clearing Agency Standards’’).21
The Clearing Agency Standards became
effective on January 2, 2013, and require
registered clearing agencies that perform
central counterparty (‘‘CCP’’) services to
establish, implement, maintain, and
enforce written policies and procedures
that are reasonably designed to meet
certain minimum requirements for their
operations and risk management
practices on an ongoing basis.22 As
such, it is appropriate for the
Commission to review advance notices
against these Clearing Agency
Standards, and the objectives and
principles of these risk management
standards as described in Section 805(b)
of the Clearing Supervision Act.23
The Commission believes that the
proposal in this Advance Notice is
designed to further the objectives and
principles of Section 805(b) of the
Clearing Supervision Act.24 As a
systemically-important FMU, it is
imperative that OCC have adequate
resources to be able to satisfy its
counterparty settlement obligations. The
MRA Program provides OCC with a
committed liquidity resource that does
not increase the concentration of OCC’s
counterparty exposure because the
counterparties will not include OCC’s
clearing members nor affiliated
commercial banking institutions.
Accordingly, the Commission believes
that the proposal should promote robust
risk management, promote safety and
soundness in the marketplace, reduce
systemic risks, and support the stability
of the broader financial system by giving
OCC access to additional committed
liquidity that will help OCC meet its
settlement obligations in a timely
manner, while also limiting the
exposure that OCC has to its
counterparties.
Exchange Act Rule 17Ad–22(b)(3),25
adopted as part of the Clearing Agency
Standards, requires that a non-securitybased swap registered clearing agency
that performs CCP services establish,
implement, maintain, and enforce
written policies and procedures
reasonably designed to withstand, at a
minimum, a default by the participant
family to which it has the largest
exposure in extreme but plausible
market conditions. As a part of OCC’s
overall liquidity plan, the Commission
believes that the MRA Program will
contribute additional liquid financial
resources that should enhance OCC’s
ability to meet any potential settlement
demands arising out of a default of a
clearing member or clearing member
family, including one to which it has
the largest exposure.
III. Conclusion
17 See
12 U.S.C. 5461(b).
18 Id.
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19 12
U.S.C. 5464(a)(2).
20 12 U.S.C. 5464(b).
21 17 CFR 240.17Ad–22.
22 The Clearing Agency Standards are
substantially similar to the risk management
standards established by the Board of Governors of
the Federal Reserve System governing the
operations of designated FMUs that are not clearing
entities and financial institutions engaged in
designated activities for which the Commission or
the Commodity Futures Trading Commission is the
Supervisory Agency. See Financial Market Utilities,
77 FR 45907 (August 2, 2012).
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It is therefore noticed, pursuant to
Section 806(e)(1)(I) of the Clearing
Supervision Act,26 that the Commission
does not object to advance notice
proposal (SR–OCC–2014–809) and that
OCC is authorized to implement the
proposal as of the date of this notice.
U.S.C. 5464(b).
U.S.C 5464(b).
25 17 CFR 240.17Ad–22(b)(3).
26 12 U.S.C. 5465(e)(1)(I).
By the Commission.
Brent J. Fields,
Secretary.
[FR Doc. 2015–00052 Filed 1–7–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–73977; File No. SR–
NYSEARCA–2014–152]
Self-Regulatory Organizations; NYSE
Arca, Inc.; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change Extending Its Program
That Allows Transactions To Take
Place at a Price That Is Below $1 Per
Option Contract Until January 5, 2016
January 2, 2015.
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 December
30, 2014, NYSE Arca, Inc. (the
‘‘Exchange’’ or ‘‘NYSE Arca’’) 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 extend its
program that allows transactions to take
place at a price that is below $1 per
option contract until January 5, 2016.
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.
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,
23 12
24 12
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1 15
U.S.C. 78s(b)(1).
U.S.C. 78a.
3 17 CFR 240.19b–4.
2 15
E:\FR\FM\08JAN1.SGM
08JAN1
Agencies
[Federal Register Volume 80, Number 5 (Thursday, January 8, 2015)]
[Notices]
[Pages 1062-1065]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2015-00052]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-73979; File No. SR-OCC-2014-809]
Self-Regulatory Organizations; The Options Clearing Corporation;
Notice of No Objection to Advance Notice Concerning the Implementation
of a Committed Master Repurchase Agreement Program as Part of OCC's
Overall Liquidity Plan
January 2, 2015.
On November 6, 2014, The Options Clearing Corporation (``OCC'')
filed with the Securities and Exchange Commission (``Commission'')
advance notice SR-OCC-2014-809 (``Advance Notice'') pursuant to Section
806(e)(1) of the Payment, Clearing, and Settlement Supervision Act of
2010 (``Clearing Supervision Act'' or ``Title VIII'') \1\ and Rule 19b-
4(n)(1)(i) under the Securities Exchange Act of 1934 (``Exchange
Act'').\2\ The Advance Notice was published for comment in the Federal
Register on December 9, 2014.\3\ The Commission did not receive any
comments on the Advance Notice publication. This publication serves as
a notice of no objection to the Advance Notice.
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\1\ 12 U.S.C. 5465(e)(1). The Financial Stability Oversight
Council designated OCC 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, OCC is
required to comply with the Clearing Supervision Act and file
advance notices with the Commission. See 12 U.S.C. 5465(e).
\2\ 17 CFR 240.19b-4(n)(1)(i).
\3\ Securities Exchange Act Release No. 73726 (December 3,
2014), 79 FR 73116 (December 9, 2014) (SR-OCC-2014-809).
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I. Description of the Advance Notice
a. Background
The purpose of the proposed change is to allow OCC to implement a
committed master repurchase agreement program (``MRA Program'') in
order to access an additional committed source of liquidity to meet its
settlement obligations in a manner that does not increase the
concentration of OCC's counterparty exposure, given OCC's existing
affiliations between a number of commercial banking institutions and
OCC's clearing members. According to OCC, the MRA Program will take the
form of OCC entering into a committed master repurchase agreement and
related confirmations (together, the ``Master Repurchase Agreement'')
with one or more non-bank, non-clearing
[[Page 1063]]
member institutional investors.\4\ The program will be part of OCC's
overall liquidity plan that is meant to provide OCC with access to
diverse sources of liquidity, which includes committed credit
facilities, securities lending and securities repurchase arrangements,
and clearing member funding requirements that, under certain
conditions, allow OCC to obtain funds from clearing members.\5\
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\4\ OCC states that it will conduct a due diligence review with
respect to each counterparty before entering into a master
repurchase arrangement with it. Because the appropriate due
diligence activities and financial criteria will vary for each type
of counterparty, OCC will determine on a case-by-case basis the
specific due diligence criteria it would implement. However, as the
principal purpose of due diligence will be to obtain assurance that
each counterparty has the financial ability to satisfy its
obligations under the program, the review will encompass an
assessment of the counterparty's financial statements (including
external auditor reports thereon) and, as applicable, ratings and/or
investment reports. Furthermore, OCC will identify key criteria
relative to monitoring the financial stability of the counterparty
on a going forward basis.
\5\ See, e.g., Securities Exchange Act Release No. 72752 (August
4, 2014), 79 FR 46490 (August 8, 2014) (SR-OCC-2014-17), Securities
Exchange Act Release No. 71549 (February 12, 2014), 79 FR 03574
(February 19, 2014) (SR-OCC-2014-801) and Securities Exchange Act
Release No. 73257 (September 30, 2014), 79 FR 23698 (October 3,
2014) (SR-OCC-2014-806).
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Although the Master Repurchase Agreement would be based on the
standard form of master repurchase agreement \6\ so that it will be
more familiar to potential institutional investors, OCC would require
the Master Repurchase Agreement to contain certain additional
provisions tailored to ensure a reduction in concentration risk,
certainty of funding, and operational effectiveness.
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\6\ The standard form master repurchase agreement is published
by the Securities Industry and Financial Markets Association and is
commonly used in the repurchase market by institutional investors.
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b. The Proposed MRA Program
i. Standard Repurchase Agreement Terms
According to OCC, the Master Repurchase Agreement generally will be
structured like a typical repurchase arrangement, in order to help OCC
attract interest from potential institutional investors willing to be
counterparties to OCC. Under the Master Repurchase Agreement, the buyer
(i.e., the institutional investor) on occasion would purchase from OCC
United States government securities (``Eligible Securities'').\7\ OCC,
as the seller, will transfer Eligible Securities to the buyer in
exchange for a payment by the buyer to OCC in immediately available
funds (``Purchase Price''). The buyer will simultaneously agree to
transfer the purchased securities back to OCC at a specified later date
or on OCC's demand (``Repurchase Date'') against the transfer of funds
by OCC to the buyer in an amount equal to the outstanding Purchase
Price plus the accrued and unpaid price differential (together, the
``Repurchase Price''), which is the interest component of the
Repurchase Price.
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\7\ OCC would use U.S. government securities that are included
in clearing fund contributions by clearing members and margin
deposits of any clearing member that has been suspended by OCC for
the repurchase arrangements. Article VIII, Section 5(e) of OCC's By-
Laws and OCC Rule 1104(b) authorize OCC to obtain funds from third
parties through securities repurchases using these sources. The
officers who may exercise this authority include the Executive
Chairman and the President.
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At all times while a transaction is outstanding, OCC will be
required to maintain a specified amount of securities or cash margin
with the buyer.\8\ The market value of the securities supporting each
transaction will be determined daily, typically based on a price
obtained from a generally recognized pricing source. If the market
value of the purchased securities is determined to have fallen below
OCC's required margin, OCC will be required to transfer to the buyer
sufficient cash or additional securities reasonably acceptable to the
buyer so that OCC's margin requirement is satisfied.\9\ If the market
value of the purchased securities is determined to have risen to above
OCC's required margin, OCC will be permitted to require the return of
excess purchased securities from the buyer.
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\8\ OCC expects that it would be required to maintain margin
equal to 102% of the Repurchase Price which, according to OCC, is a
standard rate for arrangements involving U.S. government securities.
\9\ OCC expects that it would use clearing fund securities and
securities posted as margin by defaulting clearing members.
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As in a typical master repurchase agreement, an event of default
will occur with respect to the buyer if the buyer fails to purchase
securities on a purchase date, fails to transfer purchased securities
on any applicable Repurchase Date, or fails to transfer any interest,
dividends or distributions on purchased securities to OCC within a
specified period after receiving notice of such failure. An event of
default will occur with respect to OCC if OCC fails to transfer
purchased securities on a purchase date or fails to repurchase
purchased securities on an applicable Repurchase Date. The Master
Repurchase Agreement also will provide for standard events of default
for either party, including a party's failure to maintain required
margin or an insolvency event with respect to one of the parties.
Upon the occurrence of an event of default, the non-defaulting
party, at its option, will have the right, among others, to accelerate
the Repurchase Date of all outstanding transactions between the
defaulting party and the non-defaulting party. For example, if OCC were
the defaulting party with respect to a transaction and the buyer chose
to terminate the transaction, OCC will be required to immediately
transfer the Repurchase Price to the buyer. If the buyer were the
defaulting party with respect to a transaction and OCC chose to
terminate the transaction, the buyer will be required to deliver all
purchased securities to OCC. If OCC or the buyer does not perform in a
timely manner, the non-defaulting party will be permitted to buy or
sell, or deem itself to have bought or sold, securities as needed to be
made whole and the defaulting party will be required to pay the costs
related to any covering transactions. Additionally, if OCC is required
to obtain replacement securities as a result of an event of default,
the buyer will be required to pay the excess of the price paid by OCC
to obtain replacement securities over the Repurchase Price.
ii. Customized Features
As part of the Master Repurchase Agreement, OCC will enter into an
individualized master confirmation with each buyer and its agent which
will set forth certain terms and conditions applicable to all
transactions entered into under the Master Repurchase Agreement by that
buyer. According to OCC, these required terms and conditions will be
designed to promote OCC's goals of reduced concentration risk,
certainty of funding and operational effectiveness. The terms of the
master confirmations under each Master Repurchase Agreement may vary
from one another, because a separate master confirmation will be
negotiated for a given buyer at the time that buyer becomes a party to
the Master Repurchase Agreement. OCC has identified the following as
key standards that will need to be incorporated into each repurchase
arrangement entered into under the program.\10\
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\10\ OCC expects that the Master Repurchase Agreement also will
include other, more routine, provisions such as the method for
giving notices and basic due authorization representations by the
parties.
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[[Page 1064]]
Counterparties
OCC only will enter into repurchase arrangements with non-bank
institutional investors, such as pension funds or insurance companies
that are not OCC clearing members or banks affiliated with any OCC
clearing member. OCC believes this requirement will allow OCC to access
stable, reliable sources of funding, without increasing the
concentration of its exposure to counterparties that are affiliated
banks, broker/dealers and futures commission merchants. OCC believes
that this reduction in concentration risk is a key advantage of this
proposed program.
Commitment to Fund and Funding Accounts
OCC will seek funding commitments from one or more potential
counterparties that will equal $1 billion in the aggregate,\11\ with
each commitment extending for 364 days or more. Each counterparty will
be obligated to enter into transactions under the Master Repurchase
Agreement up to its committed amount so long as no default had occurred
and OCC transferred sufficient Eligible Securities. Each counterparty
will be obligated to enter into transactions even if OCC had
experienced a material adverse change, such as the failure of a
clearing member. According to OCC, this commitment to provide funding
will be a key departure from ordinary repurchase arrangements and a key
requirement for OCC. Each commitment will be supported by an agreement
by the counterparty to maintain cash and investments acceptable to OCC
that must be readily converted into cash in a designated account into
which OCC has visibility. OCC believes that the creation of a funding
account is important because it will help OCC ensure that the committed
funds will be available each day. OCC also believes that it will
facilitate prompt funding by counterparties that are not commercial
banks and therefore are not in the business of daily funding.
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\11\ The $1 billion in commitments could be spread across
multiple counterparties, but $1 billion represents the proposed
aggregate size of the program.
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Funding Mechanics
According to OCC, funding mechanics will be targeted so that OCC
will receive the Purchase Price in immediately available funds within
60 minutes of its request for funds and delivery of Eligible Securities
and, if needed, prior to OCC's regular daily settlement time.\12\ OCC
believes that these targeted funding mechanics will allow OCC to
receive needed liquidity in time to satisfy settlement obligations,
even in the event of a default by a clearing member or a market
disruption. The funding mechanism may be, for example, delivery versus
payment/receive versus payment or another method acceptable to OCC that
both satisfies the objectives of the MRA Program and presents limited
operational risks.
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\12\ According to OCC, this would include OCC's regular daily
settlement time and any extended settlement time implemented by OCC
in an emergency situation under OCC Rule 505.
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No Rehypothecation
Under the terms of each master confirmation, the buyer would not be
permitted to grant any third party an interest in purchased securities,
the custody account at the custodian where purchased securities are
held, or any cash held in OCC's account. As a result, OCC states that
the buyer would be prohibited from rehypothecating purchased
securities, the purchased securities should never leave the account,
and there should be no third-party claims against the purchased
securities. OCC believes that the prohibition on rehypothecation also
would reduce the risk that a third party could interfere with the
buyer's transfer of the purchased securities on the Repurchase Date.
Further, according to OCC, the custodian would agree to provide OCC
with daily information about each buyer's account. OCC believes that
this visibility would allow OCC to act quickly in the event a buyer
violates any requirements.
Early Termination Rights
Under the Master Repurchase Agreement, OCC would have the ability
to terminate any transaction upon written notice to the buyer, but a
buyer only would be able to terminate a transaction upon the occurrence
of an event of default with respect to OCC.\13\ OCC has stated that
this optional early termination right is important because its
liquidity needs may change unexpectedly over time and as a result OCC
may not want to keep a transaction outstanding as long as originally
planned.
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\13\ According to OCC, a notice of termination by OCC would
specify a new Repurchase Date prior to the originally agreed upon
Repurchase Date. Upon the early termination of a transaction, the
buyer would be required to return all purchased securities to OCC,
and OCC would be required to pay the Repurchase Price.
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Substitution
Under the Master Repurchase Agreement, OCC would have the ability
to substitute any Eligible Securities for purchased securities in its
discretion by a specified time, so long as the Eligible Securities
satisfy any applicable criteria contained in the Master Repurchase
Agreement and the transfer of the Eligible Securities would not create
a margin deficit, as described above.\14\ OCC believes that this
substitution right is important because it must be able to manage
clearing member requests to return excess or substitute Eligible
Securities in accordance with established operational procedures.
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\14\ In addition to its substitution rights, OCC could cause the
return of purchased securities by exercising its optional early
termination rights under the Master Repurchase Agreement. If OCC
were to terminate part or all of a transaction, the buyer would be
required to return purchased securities to OCC against payment of
the corresponding Repurchase Price.
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Events of Default
In addition to the standard events of default for a failure to
purchase or transfer securities on the applicable Purchase Date or
Repurchase Date, OCC would require that the Master Repurchase Agreement
not contain any additional events of default that would restrict OCC's
access to funding and that it contain an additional default remedy. OCC
would require that it would not be an event of default if OCC suffers a
``material adverse change.'' \15\ According to OCC, this provision
provides it with certainty of funding, even in difficult market
conditions.
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\15\ According to OCC, a ``material adverse change'' is
typically defined as a change that would have a materially adverse
effect on the business or financial condition of a company.
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Upon the occurrence of an event of default, in addition to the non-
defaulting party's right to accelerate the Repurchase Date of all
outstanding transactions or to buy or sell securities as needed to be
made whole, the non-defaulting party may elect to take the actions
specified in the ``mini close-out'' provision of the Master Repurchase
Agreement, rather than declaring an event of default.\16\ Therefore, if
the buyer fails to deliver purchased securities on any Repurchase Date,
OCC believes that it would have remedies that allow it to mitigate risk
with respect to a particular transaction, without declaring an event of
default with
[[Page 1065]]
respect to all transactions under the Master Repurchase Agreement.
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\16\ For example, if the buyer fails to transfer purchased
securities on the applicable Repurchase Date, rather than declaring
an event of default, OCC may (1) if OCC has already paid the
Repurchase Price, require the buyer to repay the Repurchase Price,
(2) if there is a margin excess, require the buyer to pay cash or
delivered purchased securities in an amount equal to the margin
excess, or (3) declare that the applicable transaction, and only
that transaction, will be immediately terminated, and apply default
remedies under the Master Repurchase Agreement to only that
transaction.
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II. Discussion and Commission Findings
Although Title VIII does not specify a standard of review for an
advance notice, the Commission believes that the stated purpose of
Title VIII is instructive.\17\ The stated purpose of Title VIII is to
mitigate systemic risk in the financial system and promote financial
stability by, among other things, promoting uniform risk management
standards for systemically-important financial market utilities
(``FMUs'') and strengthening the liquidity of systemically important
FMUs.\18\
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\17\ See 12 U.S.C. 5461(b).
\18\ Id.
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Section 805(a)(2) of the Clearing Supervision Act \19\ authorizes
the Commission to prescribe risk management standards for the payment,
clearing, and settlement activities of designated clearing entities and
financial institutions engaged in designated activities for which it is
the supervisory agency or the appropriate financial regulator. Section
805(b) of the Clearing Supervision Act \20\ states that the objectives
and principles for the risk management standards prescribed under
Section 805(a) shall be to:
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\19\ 12 U.S.C. 5464(a)(2).
\20\ 12 U.S.C. 5464(b).
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Promote robust risk management;
promote safety and soundness;
reduce systemic risks; and
support the stability of the broader financial system.
The Commission has adopted risk management standards under Section
805(a)(2) of the Clearing Supervision Act (``Clearing Agency
Standards'').\21\ The Clearing Agency Standards became effective on
January 2, 2013, and require registered clearing agencies that perform
central counterparty (``CCP'') services to establish, implement,
maintain, and enforce written policies and procedures that are
reasonably designed to meet certain minimum requirements for their
operations and risk management practices on an ongoing basis.\22\ As
such, it is appropriate for the Commission to review advance notices
against these Clearing Agency Standards, and the objectives and
principles of these risk management standards as described in Section
805(b) of the Clearing Supervision Act.\23\
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\21\ 17 CFR 240.17Ad-22.
\22\ The Clearing Agency Standards are substantially similar to
the risk management standards established by the Board of Governors
of the Federal Reserve System governing the operations of designated
FMUs that are not clearing entities and financial institutions
engaged in designated activities for which the Commission or the
Commodity Futures Trading Commission is the Supervisory Agency. See
Financial Market Utilities, 77 FR 45907 (August 2, 2012).
\23\ 12 U.S.C. 5464(b).
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The Commission believes that the proposal in this Advance Notice is
designed to further the objectives and principles of Section 805(b) of
the Clearing Supervision Act.\24\ As a systemically-important FMU, it
is imperative that OCC have adequate resources to be able to satisfy
its counterparty settlement obligations. The MRA Program provides OCC
with a committed liquidity resource that does not increase the
concentration of OCC's counterparty exposure because the counterparties
will not include OCC's clearing members nor affiliated commercial
banking institutions. Accordingly, the Commission believes that the
proposal should promote robust risk management, promote safety and
soundness in the marketplace, reduce systemic risks, and support the
stability of the broader financial system by giving OCC access to
additional committed liquidity that will help OCC meet its settlement
obligations in a timely manner, while also limiting the exposure that
OCC has to its counterparties.
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\24\ 12 U.S.C 5464(b).
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Exchange Act Rule 17Ad-22(b)(3),\25\ adopted as part of the
Clearing Agency Standards, requires that a non-security-based swap
registered clearing agency that performs CCP services establish,
implement, maintain, and enforce written policies and procedures
reasonably designed to withstand, at a minimum, a default by the
participant family to which it has the largest exposure in extreme but
plausible market conditions. As a part of OCC's overall liquidity plan,
the Commission believes that the MRA Program will contribute additional
liquid financial resources that should enhance OCC's ability to meet
any potential settlement demands arising out of a default of a clearing
member or clearing member family, including one to which it has the
largest exposure.
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\25\ 17 CFR 240.17Ad-22(b)(3).
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III. Conclusion
It is therefore noticed, pursuant to Section 806(e)(1)(I) of the
Clearing Supervision Act,\26\ that the Commission does not object to
advance notice proposal (SR-OCC-2014-809) and that OCC is authorized to
implement the proposal as of the date of this notice.
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\26\ 12 U.S.C. 5465(e)(1)(I).
By the Commission.
Brent J. Fields,
Secretary.
[FR Doc. 2015-00052 Filed 1-7-15; 8:45 am]
BILLING CODE 8011-01-P