Self-Regulatory Organizations; ICE Clear Europe Limited; Notice of Filing of Proposed Rule Change Relating to Collateral and Haircut Policy, 17132-17135 [2015-07259]
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17132
Federal Register / Vol. 80, No. 61 / Tuesday, March 31, 2015 / Notices
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investors and the purposes fairly
intended by the policy and provisions of
the Act.
Applicants’ Conditions
Applicants agree that any order
granting the requested relief will be
subject to the following conditions: 9
1. Before a Subadvised Fund may rely
on the order requested in the
application, the operation of the
Subadvised Fund in the manner
described in the application, including
the hiring of Wholly-Owned SubAdvisers, will be approved by a majority
of the Subadvised Fund’s outstanding
voting securities as defined in the Act,
which in the case of a Master Fund will
include voting instructions provided by
shareholders of the Feeder Funds
investing in such Master Fund or other
voting arrangements that comply with
section 12(d)(1)(E)(iii)(aa) of the Act or,
in the case of a new Subadvised Fund
whose public shareholders purchase
shares on the basis of a prospectus
containing the disclosure contemplated
by condition 2 below, by the initial
shareholder(s) before offering the
Subadvised Fund’s shares to the public.
2. The prospectus for each
Subadvised Fund, and in the case of a
Master Fund relying on the requested
relief, the prospectus for each Feeder
Fund investing in such Master Fund,
will disclose the existence, substance
and effect of any order granted pursuant
to the application. Each Subadvised
Fund (and any such Feeder Fund) will
hold itself out to the public as
employing the multi-manager structure
described in the application. Each
prospectus will prominently disclose
that the Adviser has the ultimate
responsibility, subject to oversight by
the Board, to oversee the Sub-Advisers
and recommend their hiring,
termination, and replacement.
3. The Adviser will provide general
management services to a Subadvised
Fund, including overall supervisory
responsibility for the general
management and investment of the
Subadvised Fund’s assets. Subject to
review and approval of the Board, the
Adviser will (a) set a Subadvised Fund’s
overall investment strategies, (b)
evaluate, select, and recommend SubAdvisers to manage all or a portion of
a Subadvised Fund’s assets, and (c)
implement procedures reasonably
designed to ensure that Sub-Advisers
comply with a Subadvised Fund’s
investment objective, policies and
restrictions. Subject to review by the
9 Applicants will only comply with conditions 7,
8, 9, and 12 if they rely on the relief that would
allow them to provide Aggregate Fee Disclosure.
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Board, the Adviser will (a) when
appropriate, allocate and reallocate a
Subadvised Fund’s assets among SubAdvisers; and (b) monitor and evaluate
the performance of Sub-Advisers.
4. A Subadvised Fund will not make
any Ineligible Sub-Adviser Changes
without such agreement, including the
compensation to be paid thereunder,
being approved by the shareholders of
the applicable Subadvised Fund, which
in the case of a Master Fund will
include voting instructions provided by
shareholders of the Feeder Fund
investing in such Master Fund or other
voting arrangements that comply with
section 12(d)(1)(E)(iii)(aa) of the Act.
5. Subadvised Funds will inform
shareholders, and if the Subadvised
Fund is a Master Fund, shareholders of
any Feeder Funds, of the hiring of a new
Sub-Adviser within 90 days after the
hiring of the new Sub-Adviser pursuant
to the Modified Notice and Access
Procedures.
6. At all times, at least a majority of
the Board will be Independent Trustees,
and the selection and nomination of
new or additional Independent Trustees
will be placed within the discretion of
the then-existing Independent Trustees.
7. Independent Legal Counsel, as
defined in rule 0–1(a)(16) under the Act,
will be engaged to represent the
Independent Trustees. The selection of
such counsel will be within the
discretion of the then-existing
Independent Trustees.
8. The Adviser will provide the
Board, no less frequently than quarterly,
with information about the profitability
of the Adviser on a per Subadvised
Fund basis. The information will reflect
the impact on profitability of the hiring
or termination of any sub-adviser during
the applicable quarter.
9. Whenever a sub-adviser is hired or
terminated, the Adviser will provide the
Board with information showing the
expected impact on the profitability of
the Adviser.
10. Whenever a sub-adviser change is
proposed for a Subadvised Fund with
an Affiliated Sub-Adviser or a WhollyOwned Sub-Adviser, the Board,
including a majority of the Independent
Trustees, will make a separate finding,
reflected in the Board minutes, that
such change is in the best interests of
the Subadvised Fund and its
shareholders, and if the Subadvised
Fund is a Master Fund, the best interests
of any applicable Feeder Funds and
their respective shareholders, and does
not involve a conflict of interest from
which the Adviser or the Affiliated SubAdviser or Wholly-Owned Sub-Adviser
derives an inappropriate advantage.
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11. No Trustee or officer of the Trust,
a Fund or a Feeder Fund, or partner,
director, manager or officer of the
Adviser, will own directly or indirectly
(other than through a pooled investment
vehicle that is not controlled by such
person) any interest in a Sub-Adviser
except for (a) ownership of interests in
the Adviser or any entity, except a
Wholly-Owned Sub-Adviser, that
controls, is controlled by, or is under
common control with the Adviser, or (b)
ownership of less than 1% of the
outstanding securities of any class of
equity or debt of any publicly traded
company that is either a Sub-Adviser or
an entity that controls, is controlled by,
or under common control with a SubAdviser.
12. Each Subadvised Fund and any
Feeder Fund that invests in a
Subadvised Fund that is a Master Fund
will disclose the Aggregate Fee
Disclosure in its registration statement.
13. Any new Sub-Advisory
Agreement or any amendment to a
Subadvised Fund’s existing Investment
Management Agreement or SubAdvisory Agreement that directly or
indirectly results in an increase in the
aggregate advisory fee rate payable by
the Subadvised Fund will be submitted
to the Subadvised Fund’s shareholders
for approval.
14. In the event the Commission
adopts a rule under the Act providing
substantially similar relief to that
requested in the application, the
requested order will expire on the
effective date of that rule.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Brent J. Fields,
Secretary.
[FR Doc. 2015–07252 Filed 3–30–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–74579; File No. SR–ICEEU–
2015–007]
Self-Regulatory Organizations; ICE
Clear Europe Limited; Notice of Filing
of Proposed Rule Change Relating to
Collateral and Haircut Policy
March 25, 2015.
Pursuant to section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder 2
notice is hereby given that on March 13,
2015, ICE Clear Europe Limited (‘‘ICE
Clear Europe’’ or ‘‘Clearing House’’)
1 15
2 17
U.S.C. 78s(b)(1).
CFR 240.19b–4.
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Federal Register / Vol. 80, No. 61 / Tuesday, March 31, 2015 / Notices
filed with the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change as described in
Items I, II, and III below, which Items
have been prepared primarily by ICE
Clear Europe. 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 principal purpose of the
proposed rule change is to implement a
new collateral and haircut policy (the
‘‘Haircut Policy’’), which is applicable
to Permitted Cover posted by Clearing
Members to meet the Clearing House’s
Margin and Guaranty Fund
requirements.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, ICE
Clear Europe included statements
concerning the purpose of and basis for
the proposed rule change. The text of
these statements may be examined at
the places specified in Item IV below.
ICE Clear Europe has prepared
summaries, set forth in sections A, B,
and C below, of the most significant
aspects of such statements.
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A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Haircut Policy codifies and
consolidates certain existing practices of
the Clearing House with respect to
Permitted Cover. Specifically, the policy
is designed (i) to set out overall
principles with respect to the assets
accepted by the Clearing House as
Permitted Cover; (ii) to establish a
framework for determining absolute and
relative limits, as applicable, on the
value of the collateral that may be
posted by a Clearing Member as
Permitted Cover; (iii) to establish a
value-at-risk (‘‘VaR’’) based
methodology for determining haircuts
for all Permitted Cover; (iv) to mitigate
wrong-way risk from Permitted Cover;
(v) to address sources for pricing
Permitted Cover; and (vi) to set out
certain related monitoring, reviewing
and reporting procedures. The Haircut
Policy applies to Permitted Cover
provided for all product classes (F&O,
CDS and FX).3 Following
3 Although the Haircut Policy generally also
applies to Permitted Cover posted with respect to
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implementation, the Clearing House
will from time to time adjust the
haircuts applicable to Permitted Cover
under the methodology set forth in the
policy.
The general aims of the Haircut Policy
are to ensure that the Clearing House
can efficiently liquidate all forms of
Permitted Cover, that appropriate prices
are used for valuation of Permitted
Cover and that appropriate haircuts
(including, as applicable, cross-currency
haircuts) are used. The Haircut Policy
also codifies certain general principles
considered by the Clearing House in
accepting assets as Permitted Cover,
including availability of pricing
information, the existence of liquid and
active markets for buyers and sellers of
those assets, the existence of sufficient
price history, the ability to liquidate
Permitted Cover without causing a
market disruption, compliance with
legal and regulatory requirements and
sufficient operational and technological
framework to handle deposit,
liquidation and return of such assets as
Permitted Cover. Cash collateral must be
in one of several specified currencies
underlying contracts cleared by the
Clearing House. Additional general
requirements apply to financial
instruments, including prohibitions on
acceptance of instruments that have
non-‘‘vanilla’’ features such as
embedded options, instruments issued
by a Clearing Member or its affiliate,
instruments issued by a CCP or by
entities that provide critical services to
the Clearing House (other than central
banks) and certain credit-based limits.
Such limits require that the issuer is
rated at least ‘‘BBB¥’’ by S&P (or its
equivalent), the average yield on the
asset over the previous three months is
not greater than 8%, and the 5-year CDS
spread of the issuer has not exceeded
500 basis points over the previous three
months. The Haircut Policy provides
that where market conditions warrant,
or where the Clearing House’s sovereign
risk model indicates deteriorating credit
below a certain threshold (i.e., ‘‘BBB¥’’
by S&P), the Clearing House may
remove securities from the list of
Permitted Cover and/or vary applicable
haircuts. The Clearing House will notify
Clearing Members and other market
participants of such actions by Circular.
The Clearing House maintains the
current List of Permitted Cover (along
with haircut rates, limits and
restrictions) on its Web site, https://
Guaranty Fund requirements, certain additional
requirements apply to Guaranty Fund contributions
under the Rules and Finance Procedures. Those
additional requirements are not proposed to be
changed in connection with the Haircut Policy.
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www.theice.com/publicdocs/clear_
europe/list-of-permitted-covers.pdf.
The Haircut Policy contains a
methodology for setting absolute limits
on the value of non-cash Permitted
Cover that can be posted by a Clearing
Member. (The Clearing House does not,
however, impose absolute or relative
limits on the use of US Treasury
securities as Permitted Cover.) Absolute
collateral limits apply across a group of
affiliated Clearing Members and apply
across all product categories cleared by
that group. Collateral provided by
Sponsored Principals with the same
sponsoring member will be included in
all collateral limit calculations as part of
the sponsoring member’s client account.
The policy also sets out relative, or
concentration, limits for Permitted
Cover provided by a Clearing Member.
The Clearing House publishes on its
Web site the current absolute and
relative limits on government bonds
provided as Permitted Cover. For
government bonds, the absolute limit
generally is calculated pursuant to a
formula based on data from the repo
market for the relevant government
bond, taking into account both the
overall size of that market and the
percentage of that market consisting of
repos with a one day maturity. The
policy also specifies relevant sources of
repo market data for particular types of
government securities (including most
European government bonds and
Japanese government bonds accepted by
the Clearing House) and gold market
data for gold Permitted Cover. The
policy also sets out alternative
approaches for determining the limit for
certain government bonds, including for
UK, Swiss and Canadian government
bonds. The policy sets out procedures
for monitoring of limits on a daily basis
and for remediation of breach of a limit
by a Clearing Member. The risk
management department monitors all
collateral limits on a daily basis using
a collateral breakdown report which
flags limit breaches. Breaches will be
reviewed internally and the relevant
Clearing Member will be contacted.
Breaches can be remediated by posting
additional collateral, removal of
collateral that is in breach of a limit, or
both of the above.
The policy also provides for a riskbased reduction in absolute limits for
government bonds based on the credit
default swap (CDS) spread for the
relevant issuer. Once the spread exceeds
a specified level for a particular issuer,
the absolute limit for Permitted
Collateral of that issuer is reduced
pursuant to a defined formula. If the
spread exceeds a second level, the
absolute limit is reduced to 5% of the
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otherwise applicable original limit.
Spread levels are determined using a
five-day average to avoid excessive
volatility. This reduction is intended to
mitigate wrong-way risk from
government bond Permitted Cover. The
specified parameters will be reviewed
on a quarterly basis.
Specific wrong-way risk arising in
connection with clearing of Western
European sovereign CDS is addressed
through a requirement that US dollar
denominated collateral be provided for
initial margin and that a portion of the
CDS Guaranty Fund be US dollar-based
(determined based on the ratio between
the dollar-denominated and Eurodenominated initial margin
requirements for CDS). In addition,
where the member’s aggregate short
position in sovereign CDS with respect
to a sovereign exceeds a specified
threshold, the Clearing House may
decline to accept government bonds of
that sovereign or any other sovereign
bonds that exhibit certain correlations
with such government bonds.
The Haircut Policy also addresses
potential wrong-way risk arising from
Permitted Cover more generally. The
Clearing House monitors collateral on a
daily basis. Where the Clearing House
considers there to be strong general
wrong-way risk between a Clearing
Member and the asset it is posting, the
Clearing House will ask the member to
change the composition of collateral to
mitigate that risk.
The Haircut Policy establishes a VaRbased methodology for determining
haircuts for Permitted Cover. The
Clearing House calculates six different
estimations of VaR for each applicable
risk factor. Two estimations are based
on a historical simulation approach
(using a 1,000-business day
(approximately 4 year) lookback period),
and a one-day or two-day liquidation
period assumption. Four estimations are
based on a parametric methodology:
Two using a 1,000-business day
lookback period and a one-day or twoday liquidation period assumption, and
two using a 60-business day
(approximately 3 month) lookback
period and a one-day or two-day
liquidation period assumption. Each
estimation is calculated using a 99.9%
confidence interval (applicable to
Permitted Cover posted with respect to
all product categories). The proposed
haircut will be based on the largest VaR
of the 6 estimations. Fixed income
assets are divided into separate maturity
buckets for each issuer, with a separate
haircut established for each bucket. The
policy specifies relevant price sources
that will be used for the calculation of
haircuts for each type of Permitted
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Cover. Haircuts are determined using
the bid prices of Permitted Cover assets,
in order to account for higher
liquidation costs in stressed markets.
The model output is rounded up to the
nearest 0.25%, in order to limit
unnecessary variation in haircut levels.
The applicable haircuts will be
reviewed on a monthly basis, or more
frequently where the risk management
department deems it necessary.
The risk management department may
further adjust the haircut determined
under the model as it determines
prudent in light of additional qualitative
and quantitative factors. These include
the Clearing House’s credit assessment
of the issuer, current market conditions
and volatility, expected future volatility,
the liquidity of the underlying market
for the asset, including bid/ask spread,
wrong way risk considerations, VaR
estimates determined for a period of
stressed market conditions, and other
factors that might affect the liquidity or
value of an asset in stressed market
conditions. The Clearing House
anticipates that such adjustments to the
value calculated under the model would
be used only in exceptional
circumstances and would expect to use
such adjustments to increase haircuts in
stressed market circumstances. The
Clearing House will make judicious use
of current market information to
override the model but anticipates
exercising this ability in less than 5% of
haircut rates.
The Haircut Policy also sets a
minimum haircut level of 3%, in order
to avoid pro-cyclical variation in
haircuts. (The minimum level will be
reviewed annually under the Haircut
Policy.) In addition, a haircut add-on of
up to 1% will be applied during the
period until the next monthly review to
issuers presenting increased credit risk.
The add-on is applied once the issuer’s
CDS spread exceeds a specified level,
and increases in steps of 0.25% up to a
maximum of 1% where the CDS spread
exceeds higher thresholds. The add-on
is generally designed to anticipate
potential haircut increases as part of the
next monthly review cycle.
The Clearing House also imposes
cross-currency haircuts, which address
the exchange rate risk faced by the
Clearing House where the Permitted
Cover is denominated in a different
currency from the currency of the
applicable margin requirement. Under
the Haircut Policy, cross-currency
haircuts are determined using the same
methodology described above for other
haircuts, but are subject to a minimum
haircut of 4.5%. Cross-currency haircuts
are applied in addition to any
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applicable haircut for the relevant form
of Permitted Cover.
Haircuts are reviewed under the
policy on at least a monthly basis,
although the risk department may do so
more frequently in exceptional
circumstances. The Clearing House
monitors Permitted Cover on a daily and
intraday basis. The Clearing House may,
under its existing Rules and the Haircut
Policy, take action to mitigate any
change in risk, including by increasing
haircuts, calling for additional
collateral, reducing concentration limits
and removing an asset from eligibility as
Permitted Cover. The Clearing House
monitors the value of Permitted Cover
deposited with it on a real time basis.
Any change in a member’s intra-day
cover value that is greater than 3% is
flagged immediately by the Risk
Management intraday monitoring
system that is monitored by the Risk
Management team throughout the
business day. Any breach is investigated
and appropriate action taken where
necessary. The Clearing House also will
backtest haircuts based on price moves
observed in the markets on a daily basis,
and review haircut levels if a price
move breaches an existing haircut. The
Clearing House prepares daily reports
with respect to Permitted Cover for
purposes of internal monitoring and
provides monthly reports to the relevant
Risk Committees and Board Risk
Committee. The Clearing House will
review the Haircut Policy on an annual
basis (which will include review by the
Board Risk Committee) or where there is
a material change to the risk exposure
of the Clearing House. The Haircut
Policy will also be independently
reviewed annually under the Clearing
House’s model governance framework.
2. Statutory Basis
ICE Clear Europe believes that the
proposed rule change is consistent with
the requirements of section 17A of the
Act 4 and the regulations thereunder
applicable to it.5 Section 17A(b)(3)(F) of
the Act 6 requires, among other things,
that the rules of a clearing agency be
designed to promote the prompt and
accurate clearance and settlement of
securities transactions and, to the extent
applicable, derivative agreements,
contracts, and transactions, the
safeguarding of securities and funds in
the custody or control of the clearing
agency, and the protection of investors
and the public interest. ICE Clear
Europe is adopting the Haircut Policy to
codify and consolidate its procedures
4 15
U.S.C. 78q–1.
CFR 240.17Ad–22.
6 15 U.S.C. 78q–1(b)(3)(F).
5 17
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and practices concerning the
determination of haircuts and certain
other limitations applicable to Permitted
Cover provided in respect of initial and
original margin requirements. These
limitations include establishment of
general principles for the assets
accepted as Permitted Cover, valuation
of Permitted Cover, absolute and
relative concentration limits on the
amount of a particular bond a Clearing
Member (including any affiliated
Clearing Members) may provide as
Permitted Cover as well as further
measures designed to mitigate wrongway-risk. ICE Clear Europe believes that
the policy provides a conservative set of
haircuts intended to protect the Clearing
House from a decline in collateral value
or a change in exchange rates in
circumstances where it is required to
liquidate Permitted Cover following a
Clearing Member default. In addition,
the policy permits the Clearing House to
respond promptly and appropriately to
changes in market conditions by
modifying haircuts or other limits on
Permitted Cover. ICE Clear Europe thus
believes that the Haircut Policy will
enhance the stability of the clearing
system and the Clearing House’s ability
to manage a Clearing Member default
and to continue to fulfill its obligations
in a Clearing Member default scenario.
As a result, in ICE Clear Europe’s view,
the proposed changes will facilitate the
prompt and accurate settlement of such
transactions, assure the safeguarding of
securities and funds which are in the
custody or control of ICE Clear Europe
or for which it is responsible, and
promote the public interest and the
protection of investors, within the
meaning of section 17A(b)(3)(F).7
B. Self-Regulatory Organization’s
Statement on Burden on Competition
ICE Clear Europe does not believe the
amendments would have any impact, or
impose any burden, on competition not
necessary or appropriate in furtherance
of the purposes of the Act. The Haircut
Policy will be applicable to all Clearing
Members with respect to assets
provided by those members as
Permitted Cover. ICE Clear Europe does
not believe the adoption of the policy
will adversely affect competition among
Clearing Members. Furthermore, ICE
Clear Europe does not anticipate that
the changes will adversely affect the
ability of market participants to clear
contracts generally, reduce access to
clearing generally, or limit market
participants’ choices for clearing such
contracts. Although it is possible that
the application of the Haircut Policy
7 15
U.S.C. 78q–1(b)(3)(F).
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will result in higher haircuts or lower
limitations for certain categories of
Permitted Cover, ICE Clear Europe
believes that the policy appropriately
tailors the haircuts and limitations to
the particular market, liquidity and
credit risks presented by particular
assets as Permitted Cover. As a result, in
ICE Clear Europe’s view, any
incremental increase in cost of using
certain types of Permitted Cover is
warranted in light of the risks presented
to the Clearing House. ICE Clear Europe
thus believes that any impact on
competition from the new model is
appropriate in furtherance of the
purposes of the Act.
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants or Others
Written comments relating to the
proposed rule change have not been
solicited or received. ICE Clear Europe
will notify the Commission of any
written comments received by ICE Clear
Europe.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
Within 45 days of the date of
publication of this notice in the Federal
Register or within such longer period
up to 90 days (i) as the Commission may
designate if it finds such longer period
to be appropriate and publishes its
reasons for so finding or (ii) as to which
the self-regulatory organization
consents, the Commission will:
(A) By order approve or disapprove
the proposed rule change or
(B) institute proceedings to determine
whether the proposed rule change
should be disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
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–
ICEEU–2015–007 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.
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17135
All submissions should refer to File
Number SR–ICEEU–2015–007. 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 such
filings will also be available for
inspection and copying at the principal
office of ICE Clear Europe and on ICE
Clear Europe’s Web site at https://
www.theice.com/clear-europe/
regulation.
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–ICEEU–2015–007 and
should be submitted on or before April
21, 2015.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.8
Brent J. Fields,
Secretary.
[FR Doc. 2015–07259 Filed 3–30–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
Submission for OMB Review;
Comment Request
Upon Written Request Copies Available
From: Securities and Exchange
Commission, Office of FOIA Services,
100 F Street NE., Washington, DC
20549–2736.
Extension:
Regulation G.; SEC File No. 270–518; OMB
Control No. 3235–0576.
8 17
CFR 200.30–3(a)(12).
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[Federal Register Volume 80, Number 61 (Tuesday, March 31, 2015)]
[Notices]
[Pages 17132-17135]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2015-07259]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-74579; File No. SR-ICEEU-2015-007]
Self-Regulatory Organizations; ICE Clear Europe Limited; Notice
of Filing of Proposed Rule Change Relating to Collateral and Haircut
Policy
March 25, 2015.
Pursuant to section 19(b)(1) of the Securities Exchange Act of 1934
(``Act'') \1\ and Rule 19b-4 thereunder \2\ notice is hereby given that
on March 13, 2015, ICE Clear Europe Limited (``ICE Clear Europe'' or
``Clearing House'')
[[Page 17133]]
filed with the Securities and Exchange Commission (``Commission'') the
proposed rule change as described in Items I, II, and III below, which
Items have been prepared primarily by ICE Clear Europe. The Commission
is publishing this notice to solicit comments on the proposed rule
change from interested persons.
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
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I. Self-Regulatory Organization's Statement of the Terms of Substance
of the Proposed Rule Change
The principal purpose of the proposed rule change is to implement a
new collateral and haircut policy (the ``Haircut Policy''), which is
applicable to Permitted Cover posted by Clearing Members to meet the
Clearing House's Margin and Guaranty Fund requirements.
II. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
In its filing with the Commission, ICE Clear Europe included
statements concerning the purpose of and basis for the proposed rule
change. The text of these statements may be examined at the places
specified in Item IV below. ICE Clear Europe has prepared summaries,
set forth in sections A, B, and C below, of the most significant
aspects of such statements.
A. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
1. Purpose
The Haircut Policy codifies and consolidates certain existing
practices of the Clearing House with respect to Permitted Cover.
Specifically, the policy is designed (i) to set out overall principles
with respect to the assets accepted by the Clearing House as Permitted
Cover; (ii) to establish a framework for determining absolute and
relative limits, as applicable, on the value of the collateral that may
be posted by a Clearing Member as Permitted Cover; (iii) to establish a
value-at-risk (``VaR'') based methodology for determining haircuts for
all Permitted Cover; (iv) to mitigate wrong-way risk from Permitted
Cover; (v) to address sources for pricing Permitted Cover; and (vi) to
set out certain related monitoring, reviewing and reporting procedures.
The Haircut Policy applies to Permitted Cover provided for all product
classes (F&O, CDS and FX).\3\ Following implementation, the Clearing
House will from time to time adjust the haircuts applicable to
Permitted Cover under the methodology set forth in the policy.
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\3\ Although the Haircut Policy generally also applies to
Permitted Cover posted with respect to Guaranty Fund requirements,
certain additional requirements apply to Guaranty Fund contributions
under the Rules and Finance Procedures. Those additional
requirements are not proposed to be changed in connection with the
Haircut Policy.
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The general aims of the Haircut Policy are to ensure that the
Clearing House can efficiently liquidate all forms of Permitted Cover,
that appropriate prices are used for valuation of Permitted Cover and
that appropriate haircuts (including, as applicable, cross-currency
haircuts) are used. The Haircut Policy also codifies certain general
principles considered by the Clearing House in accepting assets as
Permitted Cover, including availability of pricing information, the
existence of liquid and active markets for buyers and sellers of those
assets, the existence of sufficient price history, the ability to
liquidate Permitted Cover without causing a market disruption,
compliance with legal and regulatory requirements and sufficient
operational and technological framework to handle deposit, liquidation
and return of such assets as Permitted Cover. Cash collateral must be
in one of several specified currencies underlying contracts cleared by
the Clearing House. Additional general requirements apply to financial
instruments, including prohibitions on acceptance of instruments that
have non-``vanilla'' features such as embedded options, instruments
issued by a Clearing Member or its affiliate, instruments issued by a
CCP or by entities that provide critical services to the Clearing House
(other than central banks) and certain credit-based limits. Such limits
require that the issuer is rated at least ``BBB-'' by S&P (or its
equivalent), the average yield on the asset over the previous three
months is not greater than 8%, and the 5-year CDS spread of the issuer
has not exceeded 500 basis points over the previous three months. The
Haircut Policy provides that where market conditions warrant, or where
the Clearing House's sovereign risk model indicates deteriorating
credit below a certain threshold (i.e., ``BBB-'' by S&P), the Clearing
House may remove securities from the list of Permitted Cover and/or
vary applicable haircuts. The Clearing House will notify Clearing
Members and other market participants of such actions by Circular. The
Clearing House maintains the current List of Permitted Cover (along
with haircut rates, limits and restrictions) on its Web site, https://www.theice.com/publicdocs/clear_europe/list-of-permitted-covers.pdf.
The Haircut Policy contains a methodology for setting absolute
limits on the value of non-cash Permitted Cover that can be posted by a
Clearing Member. (The Clearing House does not, however, impose absolute
or relative limits on the use of US Treasury securities as Permitted
Cover.) Absolute collateral limits apply across a group of affiliated
Clearing Members and apply across all product categories cleared by
that group. Collateral provided by Sponsored Principals with the same
sponsoring member will be included in all collateral limit calculations
as part of the sponsoring member's client account. The policy also sets
out relative, or concentration, limits for Permitted Cover provided by
a Clearing Member. The Clearing House publishes on its Web site the
current absolute and relative limits on government bonds provided as
Permitted Cover. For government bonds, the absolute limit generally is
calculated pursuant to a formula based on data from the repo market for
the relevant government bond, taking into account both the overall size
of that market and the percentage of that market consisting of repos
with a one day maturity. The policy also specifies relevant sources of
repo market data for particular types of government securities
(including most European government bonds and Japanese government bonds
accepted by the Clearing House) and gold market data for gold Permitted
Cover. The policy also sets out alternative approaches for determining
the limit for certain government bonds, including for UK, Swiss and
Canadian government bonds. The policy sets out procedures for
monitoring of limits on a daily basis and for remediation of breach of
a limit by a Clearing Member. The risk management department monitors
all collateral limits on a daily basis using a collateral breakdown
report which flags limit breaches. Breaches will be reviewed internally
and the relevant Clearing Member will be contacted. Breaches can be
remediated by posting additional collateral, removal of collateral that
is in breach of a limit, or both of the above.
The policy also provides for a risk-based reduction in absolute
limits for government bonds based on the credit default swap (CDS)
spread for the relevant issuer. Once the spread exceeds a specified
level for a particular issuer, the absolute limit for Permitted
Collateral of that issuer is reduced pursuant to a defined formula. If
the spread exceeds a second level, the absolute limit is reduced to 5%
of the
[[Page 17134]]
otherwise applicable original limit. Spread levels are determined using
a five-day average to avoid excessive volatility. This reduction is
intended to mitigate wrong-way risk from government bond Permitted
Cover. The specified parameters will be reviewed on a quarterly basis.
Specific wrong-way risk arising in connection with clearing of
Western European sovereign CDS is addressed through a requirement that
US dollar denominated collateral be provided for initial margin and
that a portion of the CDS Guaranty Fund be US dollar-based (determined
based on the ratio between the dollar-denominated and Euro-denominated
initial margin requirements for CDS). In addition, where the member's
aggregate short position in sovereign CDS with respect to a sovereign
exceeds a specified threshold, the Clearing House may decline to accept
government bonds of that sovereign or any other sovereign bonds that
exhibit certain correlations with such government bonds.
The Haircut Policy also addresses potential wrong-way risk arising
from Permitted Cover more generally. The Clearing House monitors
collateral on a daily basis. Where the Clearing House considers there
to be strong general wrong-way risk between a Clearing Member and the
asset it is posting, the Clearing House will ask the member to change
the composition of collateral to mitigate that risk.
The Haircut Policy establishes a VaR-based methodology for
determining haircuts for Permitted Cover. The Clearing House calculates
six different estimations of VaR for each applicable risk factor. Two
estimations are based on a historical simulation approach (using a
1,000-business day (approximately 4 year) lookback period), and a one-
day or two-day liquidation period assumption. Four estimations are
based on a parametric methodology: Two using a 1,000-business day
lookback period and a one-day or two-day liquidation period assumption,
and two using a 60-business day (approximately 3 month) lookback period
and a one-day or two-day liquidation period assumption. Each estimation
is calculated using a 99.9% confidence interval (applicable to
Permitted Cover posted with respect to all product categories). The
proposed haircut will be based on the largest VaR of the 6 estimations.
Fixed income assets are divided into separate maturity buckets for each
issuer, with a separate haircut established for each bucket. The policy
specifies relevant price sources that will be used for the calculation
of haircuts for each type of Permitted Cover. Haircuts are determined
using the bid prices of Permitted Cover assets, in order to account for
higher liquidation costs in stressed markets. The model output is
rounded up to the nearest 0.25%, in order to limit unnecessary
variation in haircut levels. The applicable haircuts will be reviewed
on a monthly basis, or more frequently where the risk management
department deems it necessary.
The risk management department may further adjust the haircut
determined under the model as it determines prudent in light of
additional qualitative and quantitative factors. These include the
Clearing House's credit assessment of the issuer, current market
conditions and volatility, expected future volatility, the liquidity of
the underlying market for the asset, including bid/ask spread, wrong
way risk considerations, VaR estimates determined for a period of
stressed market conditions, and other factors that might affect the
liquidity or value of an asset in stressed market conditions. The
Clearing House anticipates that such adjustments to the value
calculated under the model would be used only in exceptional
circumstances and would expect to use such adjustments to increase
haircuts in stressed market circumstances. The Clearing House will make
judicious use of current market information to override the model but
anticipates exercising this ability in less than 5% of haircut rates.
The Haircut Policy also sets a minimum haircut level of 3%, in
order to avoid pro-cyclical variation in haircuts. (The minimum level
will be reviewed annually under the Haircut Policy.) In addition, a
haircut add-on of up to 1% will be applied during the period until the
next monthly review to issuers presenting increased credit risk. The
add-on is applied once the issuer's CDS spread exceeds a specified
level, and increases in steps of 0.25% up to a maximum of 1% where the
CDS spread exceeds higher thresholds. The add-on is generally designed
to anticipate potential haircut increases as part of the next monthly
review cycle.
The Clearing House also imposes cross-currency haircuts, which
address the exchange rate risk faced by the Clearing House where the
Permitted Cover is denominated in a different currency from the
currency of the applicable margin requirement. Under the Haircut
Policy, cross-currency haircuts are determined using the same
methodology described above for other haircuts, but are subject to a
minimum haircut of 4.5%. Cross-currency haircuts are applied in
addition to any applicable haircut for the relevant form of Permitted
Cover.
Haircuts are reviewed under the policy on at least a monthly basis,
although the risk department may do so more frequently in exceptional
circumstances. The Clearing House monitors Permitted Cover on a daily
and intraday basis. The Clearing House may, under its existing Rules
and the Haircut Policy, take action to mitigate any change in risk,
including by increasing haircuts, calling for additional collateral,
reducing concentration limits and removing an asset from eligibility as
Permitted Cover. The Clearing House monitors the value of Permitted
Cover deposited with it on a real time basis. Any change in a member's
intra-day cover value that is greater than 3% is flagged immediately by
the Risk Management intraday monitoring system that is monitored by the
Risk Management team throughout the business day. Any breach is
investigated and appropriate action taken where necessary. The Clearing
House also will backtest haircuts based on price moves observed in the
markets on a daily basis, and review haircut levels if a price move
breaches an existing haircut. The Clearing House prepares daily reports
with respect to Permitted Cover for purposes of internal monitoring and
provides monthly reports to the relevant Risk Committees and Board Risk
Committee. The Clearing House will review the Haircut Policy on an
annual basis (which will include review by the Board Risk Committee) or
where there is a material change to the risk exposure of the Clearing
House. The Haircut Policy will also be independently reviewed annually
under the Clearing House's model governance framework.
2. Statutory Basis
ICE Clear Europe believes that the proposed rule change is
consistent with the requirements of section 17A of the Act \4\ and the
regulations thereunder applicable to it.\5\ Section 17A(b)(3)(F) of the
Act \6\ requires, among other things, that the rules of a clearing
agency be designed to promote the prompt and accurate clearance and
settlement of securities transactions and, to the extent applicable,
derivative agreements, contracts, and transactions, the safeguarding of
securities and funds in the custody or control of the clearing agency,
and the protection of investors and the public interest. ICE Clear
Europe is adopting the Haircut Policy to codify and consolidate its
procedures
[[Page 17135]]
and practices concerning the determination of haircuts and certain
other limitations applicable to Permitted Cover provided in respect of
initial and original margin requirements. These limitations include
establishment of general principles for the assets accepted as
Permitted Cover, valuation of Permitted Cover, absolute and relative
concentration limits on the amount of a particular bond a Clearing
Member (including any affiliated Clearing Members) may provide as
Permitted Cover as well as further measures designed to mitigate wrong-
way-risk. ICE Clear Europe believes that the policy provides a
conservative set of haircuts intended to protect the Clearing House
from a decline in collateral value or a change in exchange rates in
circumstances where it is required to liquidate Permitted Cover
following a Clearing Member default. In addition, the policy permits
the Clearing House to respond promptly and appropriately to changes in
market conditions by modifying haircuts or other limits on Permitted
Cover. ICE Clear Europe thus believes that the Haircut Policy will
enhance the stability of the clearing system and the Clearing House's
ability to manage a Clearing Member default and to continue to fulfill
its obligations in a Clearing Member default scenario. As a result, in
ICE Clear Europe's view, the proposed changes will facilitate the
prompt and accurate settlement of such transactions, assure the
safeguarding of securities and funds which are in the custody or
control of ICE Clear Europe or for which it is responsible, and promote
the public interest and the protection of investors, within the meaning
of section 17A(b)(3)(F).\7\
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\4\ 15 U.S.C. 78q-1.
\5\ 17 CFR 240.17Ad-22.
\6\ 15 U.S.C. 78q-1(b)(3)(F).
\7\ 15 U.S.C. 78q-1(b)(3)(F).
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B. Self-Regulatory Organization's Statement on Burden on Competition
ICE Clear Europe does not believe the amendments would have any
impact, or impose any burden, on competition not necessary or
appropriate in furtherance of the purposes of the Act. The Haircut
Policy will be applicable to all Clearing Members with respect to
assets provided by those members as Permitted Cover. ICE Clear Europe
does not believe the adoption of the policy will adversely affect
competition among Clearing Members. Furthermore, ICE Clear Europe does
not anticipate that the changes will adversely affect the ability of
market participants to clear contracts generally, reduce access to
clearing generally, or limit market participants' choices for clearing
such contracts. Although it is possible that the application of the
Haircut Policy will result in higher haircuts or lower limitations for
certain categories of Permitted Cover, ICE Clear Europe believes that
the policy appropriately tailors the haircuts and limitations to the
particular market, liquidity and credit risks presented by particular
assets as Permitted Cover. As a result, in ICE Clear Europe's view, any
incremental increase in cost of using certain types of Permitted Cover
is warranted in light of the risks presented to the Clearing House. ICE
Clear Europe thus believes that any impact on competition from the new
model is appropriate in furtherance of the purposes of the Act.
C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants or Others
Written comments relating to the proposed rule change have not been
solicited or received. ICE Clear Europe will notify the Commission of
any written comments received by ICE Clear Europe.
III. Date of Effectiveness of the Proposed Rule Change and Timing for
Commission Action
Within 45 days of the date of publication of this notice in the
Federal Register or within such longer period up to 90 days (i) as the
Commission may designate if it finds such longer period to be
appropriate and publishes its reasons for so finding or (ii) as to
which the self-regulatory organization consents, the Commission will:
(A) By order approve or disapprove the proposed rule change or
(B) institute proceedings to determine whether the proposed rule
change should be disapproved.
IV. Solicitation of Comments
Interested persons are invited to submit written data, views, and
arguments concerning the foregoing, including whether the proposed rule
change is consistent with the Act. Comments may be submitted by any of
the following methods:
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-ICEEU-2015-007 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-ICEEU-2015-007. 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 such filings will also be available
for inspection and copying at the principal office of ICE Clear Europe
and on ICE Clear Europe's Web site at https://www.theice.com/clear-europe/regulation.
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-ICEEU-2015-007
and should be submitted on or before April 21, 2015.
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\8\ 17 CFR 200.30-3(a)(12).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\8\
Brent J. Fields,
Secretary.
[FR Doc. 2015-07259 Filed 3-30-15; 8:45 am]
BILLING CODE 8011-01-P