Order Exempting Certain Large Traders From the Self-Identification Requirements of Rule 13h-1 Under the Securities Exchange Act of 1934, and Exempting Certain Broker-Dealers From the Recordkeeping, Reporting, and Monitoring Responsibilities Under the Rule, 68590-68595 [2015-28147]
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Federal Register / Vol. 80, No. 214 / Thursday, November 5, 2015 / Notices
Comments may be submitted by any of
the following methods:
SECURITIES AND EXCHANGE
COMMISSION
Electronic Comments
[Release No. 34–76322]
• 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–
BX–2015–060 on the subject line.
Order Exempting Certain Large
Traders From the Self-Identification
Requirements of Rule 13h–1 Under the
Securities Exchange Act of 1934, and
Exempting Certain Broker-Dealers
From the Recordkeeping, Reporting,
and Monitoring Responsibilities Under
the Rule
Paper Comments
• Send paper comments in triplicate
to Brent J. Fields, Secretary, Securities
and Exchange Commission, 100 F Street
NE., Washington, DC 20549–1090.
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All submissions should refer to File
Number SR–BX–2015–060. 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–BX–
2015–060 and should be submitted on
or before November 27, 2015.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.29
Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2015–28144 Filed 11–4–15; 8:45 am]
BILLING CODE 8011–01–P
29 17
CFR 200.30–3(a)(12).
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October 30, 2015.
On July 27, 2011, the Securities and
Exchange Commission (‘‘Commission’’)
adopted Rule 13h–1 (the ‘‘Rule’’) under
the Securities Exchange Act of 1934
(‘‘Exchange Act’’) to assist the
Commission in both identifying and
obtaining information on market
participants that conduct a substantial
amount of trading activity, as measured
by volume or market value, in U.S.
securities (such persons are referred to
as ‘‘large traders’’).1 The Rule requires
certain large traders to identify
themselves to the Commission by filing
Form 13H and separately requires
certain broker-dealers to maintain
records of large trader transaction
information and report such information
to the Commission upon request as well
as monitor customer trading to help
promote compliance with the Rule by
traders. Since December 1, 2011,
persons whose trading activity reached
or exceeded the identifying activity
level specified in the Rule have been
required to identify themselves to the
Commission by filing Form 13H through
the Commission’s EDGAR system. The
Commission implemented the brokerdealer recordkeeping, reporting, and
monitoring requirements of the Rule in
phases through a series of exemptive
orders establishing certain delayed
compliance dates,2 and currently certain
broker-dealers are required to keep
records of and report to the Commission
upon request transaction data for certain
of their customers that are either a large
trader or an Unidentified Large Trader.3
1 See Securities Exchange Act Release No. 64976
(July 27, 2011), 76 FR 46960 (Aug. 3, 2011)
(‘‘Adopting Release’’). The effective date of Rule
13h–1 was October 3, 2011.
2 See Securities Exchange Act Release Nos. 70150
(August 8, 2013), 78 FR 49556 (August 14, 2013)
(establishing Phase Two and providing for Phase
Three); 69281 (April 3, 2013), 78 FR 20960 (April
8, 2013) (extension of the compliance date); and
66839 (April 20, 2012), 77 FR 25007 (April 26,
2012) (establishing Phase One).
3 Rule 13h–1(a)(9) defines ‘‘Unidentified Large
Trader’’ as ‘‘each person who has not complied
with the identification requirements of paragraphs
(b)(1) and (b)(2) of this rule that a registered brokerdealer knows or has reason to know is a large
trader.’’ The Rule provides that, for purposes of
determining whether a registered broker-dealer has
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Most recently, the Commission
established a compliance date of
November 1, 2013 for Phase Two of the
Rule, which, among other things,
implemented the recordkeeping and
reporting responsibilities for an
additional category of traders and also
implemented the monitoring
requirements under the Rule to require
certain broker-dealers to monitor their
customers’ trading activity in order to
promote awareness of and foster
compliance with the self-identification
requirements of the Rule.4 At that time,
the Commission stated that the
compliance date for Phase Three of the
Rule would be November 1, 2015.5
The Commission has received a
request from the Financial Information
Forum (‘‘FIF’’) to exempt options traders
from the requirements of the Rule
conditioned upon such traders not
exceeding the ‘‘identifying activity
level’’ (i.e., the threshold at which a
person triggers the self-identification
requirements of the Rule) as calculated
based on the gross premium of the
options trades.6 FIF asserts that such
relief would appropriately limit the
identification requirements of the Rule
by exempting from the Rule a class of
persons whose options trading is
unlikely to have a market impact.7 In
addition, FIF requested that the
Commission permanently exempt
broker-dealers from the recordkeeping
and reporting requirements of Phase
Three of the Rule, or alternatively
postpone the compliance date of the
Phase Three requirements until
November 1, 2020.8 The Securities
Industry and Financial Markets
Association (‘‘SIFMA’’) also has
requested that the Commission
permanently exempt broker-dealers
from the recordkeeping and reporting
reason to know that a person is a large trader, ‘‘a
registered broker-dealer need take into account only
transactions in NMS securities effected by or
through such broker-dealer.’’ Rule 13h–1(a)(9).
4 See Securities Exchange Act Release No. 70150,
supra note 2 (establishing the November 1, 2013
compliance date for customer monitoring
responsibilities). See also note 27, infra, and
accompanying text.
5 Phase Three includes all of the remaining
requirements of Rule 13h–1 that were not
implemented in either Phase One or Phase Two. In
particular, Phase Three would require reporting of
execution time on trades for additional categories
of persons beyond those covered in Phases One and
Two.
6 See Letter from Mary Lou VonKaenel, Managing
Director, FIF, to Stephen Luparello, Director of the
Division of Trading and Markets, Commission,
dated March 27, 2015 (‘‘FIF Letter’’), available at:
https://www.sec.gov/comments/s7-10-10/
s71010.shtml. Currently, the fair market value of
equity options is calculated based on the value of
the underlying securities. See Rule 13h–1(c)(1)(i).
7 See FIF Letter, supra note 6, at 2–3.
8 See FIF Letter, supra note 6, at 3.
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requirements of Phase Three of the Rule,
or alternatively postpone the
compliance date of the Phase Three
requirements until November 1, 2020.9
For the reasons explained below, the
Commission believes that providing
exemptive relief for equity options
traders and deferring Phase Three are
appropriate. Accordingly, the
Commission is: (1) Conditionally
exempting equity options market
participants from the self-identification
requirements of the Rule if they have
not met or exceeded the alternative
threshold described below that is
applicable to equity options trading; 10
and (2) temporarily exempting brokerdealers until November 1, 2017 from the
remaining recordkeeping and reporting
obligations of the Rule beyond those
established in Phases One and Two.11
I. Background
A. Large Trader Status
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The Rule defines a large trader as a
person who ‘‘directly or indirectly,
including through other persons
controlled by such person, exercises
investment discretion over one or more
accounts and effects transactions for the
purchase or sale of any NMS security for
or on behalf of such accounts, by or
through one or more registered brokerdealers, in an aggregate amount equal to
or greater than the identifying activity
level’’ (emphasis added).12 The
identifying activity level contains daily
and monthly share volume and fair
market value thresholds, namely:
aggregate transactions in NMS securities
that are equal to or greater than (1)
during a calendar day, either 2 million
shares or shares with a fair market value
of $20 million; or (2) during a calendar
month, either 20 million shares or
shares with a fair market value of $200
million.13
In establishing the current identifying
activity level for equity derivative
securities, the Commission stated that
the Rule was intended to focus on the
potential impact of options transactions
9 See Letter from Theodore R. Lazo, Managing
Director and Associate General Counsel, SIFMA to
Stephen Luparello, Director of the Division of
Trading and Markets, Commission, dated April 9,
2015 (‘‘SIFMA Letter’’), available at: https://
www.sec.gov/comments/s7-10-10/s71010.shtml.
10 As discussed below, with respect to any
persons that previously registered as a large trader
on account of their equity options transactions, this
exemption relieves those persons from continued
compliance with the periodic filing obligations as
long as they do not otherwise meet or exceed the
identifying activity level in the future.
11 Phases One and Two are discussed below. See
infra text accompanying notes 53 and 54.
12 See Rule 13h–1(a)(1).
13 See Rule 13h–1(a)(7).
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on the market for the underlying
security.14
Specifically, for equity options,
• share volume is calculated by
multiplying the number of contracts by
the option contract’s specified
multiplier; and
• fair market value is calculated using
the value of the securities underlying
the option.15
At the time the Commission adopted
Rule 13h–1, the Commission stated that
this approach was consistent with
Section 13(h)(1) of the Exchange Act,
which sought to promote the
Commission’s ability to ‘‘monitor[ ] the
impact on the securities markets of
securities transactions involving a
substantial volume or a large fair market
value or exercise value . . .’’ in that the
methodology considers the equivalent
exercise value of the options on the date
of purchase.16 This approach eliminates
the need to track and separately
consider exercise and instead
preemptively identifies traders whose
options trading may be of a sufficient
magnitude to potentially affect the
underlying stock if the positions are
exercised.
B. The Requirements of Rule 13h–1
1. Large Trader Self-Identification
As noted above, the Rule requires
large traders to self-identify to the
Commission on Form 13H and
periodically update their Form 13H
submission,17 obtain a unique large
trader identification number (‘‘LTID’’)
from the Commission,18 and provide
this number to their brokers and
identify each account to which the LTID
applies.19 These large trader
responsibilities are referred to
14 See Adopting Release, supra note 1, 76 FR at
46967 (noting that this focus reflected and was
consistent with Section 13(h) of the Exchange Act).
15 Examples of how to calculate the identifying
activity for options transactions were provided in
the Adopting Release, supra note 1, 76 FR at 46967.
In contrast, for index options, share volume is not
calculated because index options do not overlie
shares and fair market value is calculated by
multiplying together the index multiplier, the
number of options, and the price per contract.
16 See Adopting Release, supra note 1, 76 FR at
46967, text accompanying n.65.
17 See Rule 13h–1(b)(1)(i)–(iii). Form 13H and all
updates to it are filed electronically through the
Commission’s EDGAR system.
18 When a large trader files its initial Form 13H
filing through EDGAR, the system sends an
automatically generated confirmation email
acknowledging acceptance of the filing. That email
also contains the unique 8-digit LTID number
assigned to the large trader.
19 See Rule 13h–1(b)(2). See also Large Trader
Adopting Release, supra note 1, 76 FR at 46971
(‘‘the requirements that a large trader provide its
LTID to all registered broker-dealers who effect
transactions on its behalf, and identify each account
to which it applies, are ongoing responsibilities that
must be discharged promptly’’).
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68591
collectively as the ‘‘Self-Identification
Requirements.’’
2. Broker-Dealers’ Recordkeeping and
Reporting Responsibilities Regarding
Unidentified Large Traders and the
Customer Monitoring Safe Harbor
Under Rules 13h–1(d) and (e),
registered broker-dealers are responsible
for, among other things, keeping records
of and reporting to the Commission
upon request data for their customers
that are large traders or Unidentified
Large Traders.20 Specifically, Rule 13h–
1 requires that every registered brokerdealer maintain records of data
specified in paragraphs (d)(2) and (d)(3)
of the Rule (‘‘Transaction Data’’),
including the applicable LTID(s) and
execution time on each component
trade, for all transactions effected
directly or indirectly by or through: (1)
An account such broker-dealer carries
for a large trader or an Unidentified
Large Trader; or (2) if the broker-dealer
is a large trader, any proprietary or other
account over which such broker-dealer
exercises investment discretion.
Additionally, where a non-broker-dealer
carries an account for a large trader or
an Unidentified Large Trader under the
Rule, the broker-dealer effecting
transactions directly or indirectly for
such large trader or Unidentified Large
Trader must maintain records of all
Transaction Data.21 These
recordkeeping obligations are referred to
collectively as the ‘‘Recordkeeping
Responsibilities.’’ The Rule also requires
that, upon Commission request, every
registered broker-dealer that is itself a
large trader or carries an account for a
large trader or an Unidentified Large
Trader must electronically report
Transaction Data to the Commission
through the Electronic Blue Sheets
(‘‘EBS’’) system for all transactions,
equal to or greater than the reporting
activity level, effected directly or
indirectly by or through accounts
carried by such broker-dealer for large
traders or Unidentified Large Traders.22
Additionally, where a non-broker-dealer
carries an account for a large trader or
an Unidentified Large Trader, the
broker-dealer effecting such transactions
directly or indirectly for a large trader
or Unidentified Large Trader must
electronically report Transaction Data to
the Commission through the EBS
system.23 The Rule requires that
reporting broker-dealers submit the
requested Transaction Data no later than
the day and time specified in the
20 See
note 3, supra.
Rule 13h–1(d)(1)(iii).
22 See Rule 13h–1(e).
23 See id.
21 See
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Commission’s request.24 These
reporting obligations are referred to
collectively as the ‘‘Reporting
Responsibilities.’’ The Commission has
implemented the Recordkeeping and
Reporting Responsibilities in phases, as
discussed in greater detail below.25
Rule 13h–1(f) provides a safe harbor
that is designed to reduce brokerdealers’ recordkeeping and reporting
burdens with respect to Unidentified
Large Traders by, among other things,
providing relief for when a brokerdealer shall be deemed to know or have
reason to know that a person is a large
trader and thus subject to reporting
obligations related to Unidentified Large
Traders under Rule 13h–1. Under the
safe harbor, a registered broker-dealer is
deemed not to know or have reason to
know that a person is a large trader if
it does not have actual knowledge that
a person is a large trader and it
establishes policies and procedures
reasonably designed to identify
customers whose transactions at the
broker-dealer equal or exceed the
identifying activity level and, if so, to
treat such persons as Unidentified Large
Traders and notify them of their
potential reporting obligations under
this Rule.26 Collectively, these brokerdealer undertakings are referred to as
the ‘‘Customer Monitoring Obligations.’’
The Customer Monitoring Obligations
are intended to promote awareness of
and foster compliance with the Rule
among persons who might not otherwise
be aware of the large trader reporting
requirements.27
As noted above, the Commission
previously granted broker-dealers
temporary exemptions from the
Customer Monitoring Obligations.28 As
of November 1, 2013, to avail
themselves of the safe harbor, brokerdealers with recordkeeping and
reporting responsibilities were required
to implement the Customer Monitoring
Obligations.
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II. Exemptive Relief
Pursuant to Section 13(h)(6) of the
Exchange Act and Rule 13h–1(g)
thereunder,29 the Commission, by order,
may exempt from the provisions of Rule
13h–1, upon specified terms and
conditions or for stated periods, any
person or class of persons or any
transaction or class of transactions from
24 See
id.
Section II.D, infra.
26 See Rule 13h–1(f).
27 See Adopting Release, supra note 1, 76 FR at
46997.
28 See Securities Exchange Act Release Nos.
66839 and 69281, supra note 2.
29 See 15 U.S.C. 78m and 17 CFR 240.13h–1(g),
respectively.
25 See
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the provisions of Rule 13h–1 to the
extent that such exemption is consistent
with the purposes of the Exchange Act.
FIF requests that the Commission
grant exemptive relief for options
traders that would be conditioned upon
such traders’ activity not exceeding the
Rule’s identifying activity threshold
based on the gross premiums paid for
the options as opposed to the value of
the underlying stock at the time of the
trade.30 FIF notes that some of its
members, particularly brokers with
retail customers, have identified
through their Customer Monitoring
Obligations a number of retail customers
that met or exceeded the threshold
based primarily on such customers’
equity options trading, particularly in
deep out-of-the-money options on high
priced underlying stocks.31 According
to FIF, customers that meet the
‘‘underlying value’’ threshold rarely
exercise their options, and many of
them would be unable to do so based on
their account balances.32 FIF argues that
exemptive relief for all options traders
conditioned upon a premium-based
threshold calculation would
appropriately focus the Rule on traders
who are more significant participants in
the U.S. securities markets and who are
more likely to trade options at levels
and in a manner that could have a
market impact.33
In addition, both FIF and SIMFA
request that the Commission
permanently exempt broker-dealers
from the additional recordkeeping and
reporting requirements of Phase Three
of the Rule, which have not yet been
implemented.34 In the alternative, FIF
requests an extension of Phase Three by
an additional five years 35 and SIFMA
requests an extension to the earlier of
full implementation of a Consolidated
Audit Trail (‘‘CAT’’) or November 1,
2020.36 Both FIF and SIFMA stated that
their request would allow firms to focus
their resources on implementing a
CAT.37
30 FIF requests that the alternative ‘‘options
premium’’ threshold be consistent with Rule 13h–
1(a)(7), which establishes the daily and monthly
market value thresholds of the identifying activity
level as $20 million and $200 million, respectively.
See FIF Letter, supra note 6, at 2.
31 See FIF Letter, supra note 6, at 1.
32 See FIF Letter, supra note 6, at 2.
33 See FIF Letter, supra note 6, at 2–3.
34 See FIF Letter, supra note 6, at 3 and SIFMA
Letter, supra note 9, at 2–3.
35 See FIF Letter, supra note 6, at 3.
36 See SIFMA Letter, supra note 9, at 2. See also
Rule 613; Securities Exchange Act Release No.
67457 (July 18, 2012), 77 FR 45722 (Aug. 1, 2012).
37 See FIF Letter, supra note 6, at 3 and SIFMA
Letter, supra note 9, at 2.
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A. Exemption From the SelfIdentification Requirements for Equity
Options Traders
As discussed above, the current
identifying activity level methodology
for equity options was designed to focus
on the potential impact of options
transactions on the market for the
underlying securities. Based on its
experience and the experience of its
member firms, however, FIF suggests
that the current methodology designates
as large traders some persons who rarely
exercise their options and whose
aggregate equity options transactions,
considering the actual premium paid for
the options, are not of a large enough
fair market value to have an impact
either on the options market or the
underlying equities markets.
In particular, FIF notes that this issue
appears to be especially pronounced for
market participants, particularly
individual non-professional investors,
who transact in deep out-of-the money
options on high-priced securities.38
While such transactions may have large
exercise values, the premium paid for
the options may be modest due to the
deep-out-of-the-money nature of the
contract, and, importantly, exercise
among these traders is very infrequent,
according to FIF. FIF’s members
reported that, among their customers
that became large traders as a result of
options transactions, such customers
very rarely exercised their options,39
and FIF asserts that many may have
lacked the resources to do so.40 In other
words, the current methodology for
calculating the fair market value of
equity options has resulted in the selfidentification as large traders of a
number of investors who trade equity
options, yet such investors’ activity is
38 See
FIF Letter, supra note 6, at 1.
reports that it surveyed its members and
found that customers that became large traders as
a result of options transactions (‘‘Equity Options LT
Customers’’) exercised their options less than 2% of
the time on average. See FIF Letter, supra note 6,
at 2.
40 FIF states that, ‘‘[g]iven the account size
associated with this class of investor it is unlikely
that they would have the ability to exercise these
out of the money options.’’ See id. To support this
conclusion, FIF provides anecdotal data: A firm
with approximately 2,000 Equity Options LT
Customers reported that the average account value
was $835,000. Another FIF member firm reported
that: The average account size for 90% of its Equity
Options LT Customers was less than $555,000; the
average value across all Equity Options LT
Customer accounts was $2.5 million; and excluding
the top 50% of its Equity Options LT Customer
accounts, the average account size was under
$56,000. See id. FIF suggests that without sufficient
assets or collateral, such customers would not be
able to outright purchase or otherwise finance their
acquisition of the underlying securities in an
amount that equals or exceeds the $20 million
threshold.
39 FIF
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unlikely to have a material impact either
on the options market or the underlying
equities markets for the purposes of
Rule 13h–1.
In order to alleviate the burdens on
these persons without undermining the
purposes of Section 13(h), the
Commission hereby is providing a
conditional exemption from the SelfIdentification Requirements for persons
that trade equity options if: (1) The
aggregate value of their equity option
transactions based on premium paid,41
combined with the aggregate value of
their transactions in all other NMS
securities (if any), does not reach or
exceed the current fair market value
thresholds of the identifying activity
level; and (2) they also do not reach or
exceed the share volume thresholds of
the identifying activity level.42
Accordingly, this exemptive relief
makes the calculation of fair market
value for equity options consistent with
how index options are valued under the
identifying activity level.43
This relief utilizes the existing fair
market value thresholds of the
identifying activity level and references
premium paid instead of the price of the
underlying at the time of the trade.44
The Commission is persuaded that
valuing equity options using premium
paid and applying the existing fair
market value thresholds appropriately
focuses the Rule on persons whose
transactions are more likely to have a
market impact and therefore warrant
triggering the Self-Identification
Requirements. In particular, as FIF has
stated, the current methodology impacts
a number of equity options traders,
many of whom reach the threshold by
purchasing options that are deep out of
the money and who do not otherwise
trade in an amount required to reach the
identifying activity level. When these
options expire out of the money and are
not exercised, the position does not
result in any trading in the underlying
securities, and thus valuing such
options with reference to the price of
41 To calculate premium paid for an options trade,
multiply together the number of options contracts
involved, the premium paid, and the applicable
multiplier. For an example, see infra Section II.A.3.
42 Neither FIF nor SIFMA have requested
exemptive relief for persons who become large
traders as a result of reaching the identifying
activity level share volume thresholds applicable to
equity options, and the Commission is not herein
granting such relief.
43 See Rule 13h–1(c)(1)(ii) (concerning the fair
market value of index options). See also Adopting
Release, supra note 1, 76 FR at 46967 (noting, in
footnote 64 and the accompanying text, how to
determine the fair market value of index (and
equity) options).
44 See Rule 13h–1(c)(1)(i) (concerning the fair
market value of equity securities underlying
transactions in stock options).
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the underlying security is unlikely to be
a useful method to identify traders with
the potential to have a market impact on
the underlying equities.45 Using
premium paid to value equity options
instead will focus the identification
requirement on options traders who
trade options in larger amounts that
thus may be more likely to have a
market impact regardless of whether the
positions are ultimately exercised. In
addition, employing the existing fair
market value thresholds to the new
premium-based methodology for equity
options allows all trading in NMS
securities to be easily aggregated for
purposes of determining large trader
status.46 For these reasons, the
Commission believes that calculating
the fair market value for equity options
by referencing the premium paid for the
options is a better overall indicator, for
purposes of Rule 13h–1, of potential
market impact and provides appropriate
relief to equity options traders.
Accordingly, the Commission finds the
exemptive relief to be consistent with
the purposes of the Exchange Act.
Applying the Threshold Permitted by
this Conditional Exemption. Equity
Option Transactions Example. For
example, during a calendar day, a
person purchases 200 call options on
ABC stock, each with a 100 multiplier,
for a premium of $15 per share, where
the underlying stock is trading at $1,000
at the time of the transaction. This
transaction reaches the identifying
activity level under the current
calculation methodology,47 pursuant to
45 Only purchases and sales of equity options and
not transactions in the underlying securities
pursuant to exercises or assignments count toward
the identifying activity level. See Rule 13h–1(a)(6).
Purchases and sales pursuant to exercises or
assignments were expressly excluded from the
identifying activity level calculation to avoid
double-counting. See Adopting Release, supra note
1, 76 FR at 46967. The Commission notes that
traders may trigger the Self-Identification
Requirements when they trade out of the position
they obtained by exercising their options.
46 Further, as noted above, for purposes of the
identifying activity level under Rule 13h–1(c) (i)
and (ii), fair market value of equity options is
calculated differently than that for index options;
the fair market value of equity options is calculated
based on the value of the underlying security, while
the fair market value of index options is calculated
based on the premium paid for the contract. As a
result, it is easier to reach the identifying activity
level by transacting in options on an exchangetraded fund overlying a securities index than it is
to transact in index options on the same securities
index. This relief harmonizes the fair market value
calculations for equity options overlying indextracking securities (such as index-based exchange
traded funds) with the calculations for index
options, thereby eliminating the Self-Identification
Requirements as a consideration for investors
choosing between options products with
comparable exposures.
47 The daily market value threshold of the
identifying activity level is $20 million.
PO 00000
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Sfmt 4703
68593
which the options are valued as follows:
200 contracts × 100 shares per contract
× $1,000 (the market price of the
underlying stock at the time of the
trade) = $20 million. Therefore, this
transaction would cause the person to
qualify as a large trader. However, under
this exemptive relief, the fair market
value of the options trade would be
calculated as follows: 200 contracts ×
100 shares per contract × $15 premium
price = $300,000. In this case, the
transaction price of $300,000 is less
than the identifying activity level of $20
million. Further, the daily share volume
would be calculated as follows: 200
contracts × 100 shares of the underlying
per contract = 20,000 shares, which also
is less than the identifying activity level
of 2 million shares. Therefore, the
person would qualify for this exemption
from the Self-Identification
Requirements and would not be
required to register as a large trader on
the basis of this particular options trade
alone.
‘‘Mixed’’ Transactions Example. By
way of another example, consider a
person that, during a calendar day, (1)
purchases: (a) 100 call options, each
with a 100 multiplier, for a premium of
$15 per share, where the underlying
stock is trading at $1,000 at the time of
the transaction; and (b) 100 contracts of
puts on an index, where each option
uses a $100 multiplier, for $50 per unit;
and (2) sells 100,000 shares of an
exchange-traded fund (‘‘ETF’’) for $100
per share. Under the current method,
the fair market value of each transaction
would be calculated as follows:
• 100 call option contracts × 100
(contract multiplier) x $1,000 (price of
the underlying stock) = $10 million
• 100 index puts × $100 (contract
multiplier) x $50 (price per unit) =
$500,000
• 100,000 ETF shares × $100 (price per
share) = $10 million
Collectively, for purposes of the
identifying activity level, the
transactions would be valued at
$20,500,000 ($10 million + $500,000 +
$10 million), which is greater than the
daily value threshold ($20 million).
Accordingly, the person would be
required to self-identify to the
Commission as a large trader.
To determine whether the large trader
qualifies for this exemptive relief, the
equity options would be valued as
follows:
• 100 call option contracts × 100
(contract multiplier) × $15 (premium
price) = $150,000
• 100 index puts × $100 (contract
multiplier) × $50 (price per unit) =
$500,000
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• 100,000 ETF shares × $100 (price per
share) = $10 million
The person qualifies for exemption
from the Self-Identification
Requirements (i.e., does not have to
identify as a large trader based on this
day’s transactions alone) because: (1)
The daily share volume threshold of the
identifying activity level (2 million
shares) is not reached; 48 and (2) the
value of the equity options under the
alternative methodology ($150,000),
when combined with the fair market
value of the index option and ETF
transactions ($500,000 and $10 million,
respectively), is less than the daily
identifying activity level threshold ($20
million).49
B. Broker-Dealers May Update Their
Monitoring Safe Harbor Policies and
Procedures To Use the New
Methodology
Paragraph (f) of Rule 13h–1 provides
a safe harbor to reduce broker-dealers’
burdens in connection with monitoring
their customers’ trading for purposes of
identifying possible large traders. To
take advantage of the safe harbor,
broker-dealers must have policies and
procedures reasonably designed to
identify persons who have reached or
exceeded the identifying activity level 50
but not identified themselves to the
broker-dealer as a large trader, treat such
persons as Unidentified Large Traders,
and inform such persons of the
obligations under Rule 13h–1. A brokerdealer that updates its policies and
procedures to reflect the terms of the
exemptive relief described above will be
able to avail itself of the monitoring safe
harbor.
jstallworth on DSK7TPTVN1PROD with NOTICES
C. Relief for Equity Options Large
Traders Who Already Self-Identified
For any person that previously
reached the identifying activity level as
a result of the fair market value of their
equity options transactions and
previously self-identified to the
Commission as a large trader, but who
otherwise does not presently meet the
identifying activity level as calculated
under the exemptive relief provided
herein, the Commission finds that it is
consistent with the purposes of the
Exchange Act to allow such person to
file for inactive status without waiting
48 The share volume calculation of the three
transactions is as follows: (100 call option contracts
x 100 contract multiplier) + 0 (index options have
no underlying shares) + 100,000 ETF shares =
110,000 shares.
49 $150,000 + $500,000 + $10 million =
$10,650,000, which is less than the daily market
threshold of the identifying activity level ($20
million).
50 See Rule 13h–1(f)(1).
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15:06 Nov 04, 2015
Jkt 238001
the required full calendar year provided
in paragraph (b)(3)(iii) of Rule 13h–1.
To take advantage of this relief, a large
trader must file for inactive status by
submitting Form 13H electronically
through EDGAR.51 After filing for
inactive status, the large trader is
relieved from the Self-Identification
Requirements, and thereafter is not
required to file any further amendments
or annual updates to Form 13H through
EDGAR, unless and until the large
trader subsequently effects transactions
that reach or exceed the identifying
activity level, accounting for the relief
granted herein for calculating equity
options activity. If a large trader that has
filed for inactive status later reaches or
exceeds the identifying activity level,
using premium paid to calculate the fair
market value of subsequent equity
options transactions, then the large
trader must promptly file Form 13H
with the Commission for reactivated
status and promptly thereafter notify its
broker-dealers of its reactivated status
and update them regarding the
applicability of the large trader’s LTID
and the accounts to which it applies.
D. Temporary Exemption From Phase
Three of the Recordkeeping and
Reporting Responsibilities
As noted above, the Commission has
implemented the Recordkeeping and
Reporting Responsibilities applicable to
clearing brokers for large traders in
phases. In Phase One, which began on
November 30, 2012, the Commission
required clearing brokers for large
traders (including the large trader itself
if it is a self-clearing broker-dealer) to
keep records and report Transaction
Data for large traders’ transactions that
were either (1) proprietary trades by a
U.S. registered broker-dealer; or (2)
effected through a ‘‘sponsored access’’
arrangement; 52 otherwise, broker51 The specific form type in EDGAR to file for
inactive status is Form 13H–I. After filing for
inactive status, the large trader also may inform the
broker-dealers through which it transacts of its
inactive status. Broker-dealers are not required to
keep records of transactions by inactive large trader
customers after receiving notice of inactive status
from such trader with respect to transactions
effected subsequent to such notification. See
Adopting Release, supra note 1, 76 FR at 46976.
52 See Securities Exchange Act Release No. 66839,
supra note 2, 77 FR at 25008–9. A sponsored access
arrangement is one where a broker-dealer permits
a customer to enter orders into a trading center
without using the broker-dealer’s trading system
(i.e., using the customer’s own technology or that
of a third party provider). At the time, FIF indicated
that broker-dealer compliance would be easier for
sponsored access customers because those
arrangements typically are distinct from all other
business lines of the broker-dealer, with
infrastructure that processes this order flow that is
separate from the platforms that handle other client
and proprietary flows. See id., 77 FR at 25008, n.16.
PO 00000
Frm 00103
Fmt 4703
Sfmt 4703
dealers were temporarily exempted from
the Recordkeeping and Reporting
Responsibilities.53 In Phase Two, which
began on November 1, 2013, the
Commission again temporarily
exempted broker-dealers, until
November 1, 2015, from the
Recordkeeping and Reporting
Responsibilities, except for: (1) The
clearing broker-dealer for a large trader,
with respect to (a) proprietary
transactions by a large trader brokerdealer; (b) transactions effected
pursuant to a ‘‘sponsored access’’
arrangement; and (c) transactions
effected pursuant to a ‘‘direct market
access’’ arrangement; and (2) a brokerdealer that carries an account for a large
trader, with respect to transactions other
than those set forth above, and for
Transaction Data other than the
execution time.54 The Commission also
established Phase Three, which requires
full compliance with the Recordkeeping
and Reporting Responsibilities for all
applicable broker-dealers starting
November 1, 2015.55
When the Commission adopted the
Rule, it characterized the large trader
reporting requirements as ‘‘relatively
modest steps’’ to ‘‘address the
Commission’s near-term need for access
to more information about large traders
and their trading activities. . . .’’ 56
After the Commission adopted the Rule,
industry commenters began to identify
specific implementation challenges and
offered more detailed estimates of the
cost of full compliance with the
Recordkeeping and Reporting
Responsibilities. Such concerns led the
Commission to implement the
Recordkeeping and Reporting
Responsibilities in phases.57
Additionally, since adopting the Rule,
the Commission adopted Rule 613,
which directed the self-regulatory
organizations (‘‘SROs’’) to jointly submit
a plan to create a comprehensive CAT
that would allow regulators to
efficiently and accurately track all
activity throughout the U.S. markets in
National Market System (NMS)
securities.58 When the Commission
adopted that rule, it stated that, while
certain aspects of Rule 13h–1 are not
addressed by Rule 613, Rule 613 may
53 See
id., 77 FR at 25010.
Securities Exchange Act Release No. 70150,
supra note 2, 78 FR at 49558–9.
55 See id., 78 FR at 49560.
56 See Adopting Release, supra note 1, 76 FR at
46963.
57 See note 2, supra.
58 Among other things, Rule 613 requires the selfregulatory organizations to jointly submit an NMS
plan to create, implement and maintain a
consolidated audit trail, and specifies the type of
data to be collected and reported to a central
repository.
54 See
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jstallworth on DSK7TPTVN1PROD with NOTICES
supersede certain of the broker-dealer
Recordkeeping and Reporting
Responsibilities of Rule 13h–1.59
Specifically, the Commission stated:
‘‘[t]o the extent that . . . data reported
to the central repository under Rule 613
obviates the need for the EBS system,
the Commission expects that the
separate [trade] reporting requirements
of Rule 13h–1 related to the EBS system
would be eliminated.’’ 60
The SROs submitted the initial CAT
NMS plan to the Commission on
September 30, 2014, and filed an
amended plan on February 27, 2015.61
As of the date of this Order, an NMS
plan for a CAT has not yet been
published for notice and comment.
Accordingly, the Commission continues
to rely on, among other things,
information available through the
Recordkeeping and Reporting
Responsibilities as implemented
through Phases One and Two. In light
of the fact that there is no approved
CAT NMS plan, the Commission is
hesitant at this time to require brokerdealers to incur the costs associated
with the remaining Phase Three Large
Trader data while the timing of a CAT
remains unclear.
However, the Commission finds that
it is consistent with the purposes of the
Exchange Act to delay Phase Three,
temporarily exempting broker-dealers
until November 1, 2017 from the
Recordkeeping and Reporting
Responsibilities, except for: (1) The
clearing broker-dealer for a large trader,
with respect to (a) proprietary
transactions by a large trader brokerdealer; (b) transactions effected
pursuant to a ‘‘sponsored access’’
arrangement; and (c) transactions
effected pursuant to a ‘‘direct market
access’’ arrangement; and (2) a brokerdealer that carries an account for a large
trader, with respect to transactions other
than those set forth above, and for
Transaction Data other than the
execution time. While FIF and SIFMA
have requested a permanent exemption,
or alternatively an additional 5-year
deferment of the compliance date for
Phase Three,62 the Commission believes
59 See Securities Exchange Act Release No. 67457
(July 18, 2012), 77 FR 45722, 45734 (August 1,
2012).
60 Id., text accompanying n.95.
61 Pursuant to Rule 613, the SROs were required
to file the CAT NMS Plan on or before April 28,
2013. At the SROs’ request, the Commission granted
exemptions to extend the deadline for filing the
CAT NMS Plan to December 6, 2013, and then to
September 30, 2014. See Securities Exchange Act
Release Nos. 69060 (Mar. 7, 2013), 78 FR 15771
(Mar. 12, 2013) and 71018 (Dec. 6, 2013), 78 FR
75669 (Dec. 12, 2013).
62 See FIF Letter, supra note 6, at 3 and SIFMA
Letter, supra note 9, at 2–3.
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15:06 Nov 04, 2015
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68595
at this time that a 2-year extension of
the Phase Three compliance date
provides sufficient time for the
Commission to consider whether to
revisit compliance with all of the
Recordkeeping and Reporting
Responsibilities. Specifically, two years
will give the Commission enough time
to evaluate future developments,
including any investment in or progress
on a CAT.63
By the Commission.
Jill M. Peterson,
Assistant Secretary.
III. Conclusion
Self-Regulatory Organizations; The
NASDAQ Stock Market LLC; Notice of
Filing and Immediate Effectiveness of
Proposed Rule Change Relating to
Risk Monitor Mechanism
It is hereby ordered, pursuant to
Section 13(h)(6) of the Exchange Act
and Rule 13h–1(g) thereunder, that:
(1) Persons transacting in equity
options are exempt from the SelfIdentification Requirements if: (1) The
aggregate value of their equity option
transactions, calculated based on
premium paid, combined with the
aggregate value of their transactions in
all other NMS securities (if any), does
not reach or exceed the fair market
value thresholds of the identifying
activity level; and (2) they also do not
reach or exceed the share volume
thresholds of the identifying activity
level.
(2) A large trader whose transactions
in NMS securities since October 3, 2011
reached the identifying activity level
one or more times because of the fair
market value of its equity options
transactions and who would have
qualified in each instance for relief
under this exemption is exempt from its
responsibilities under Rule 13h–
1(b)(1)(ii), 13h–1(b)(1)(iii), and 13h–
1(b)(2), if such trader files for inactive
status by submitting Form 13H and does
not subsequently effect transactions that
reach or exceed the identifying activity
threshold using premium paid to
calculate the fair market value of equity
options transactions.
(3) Broker-dealers are exempted
temporarily until November 1, 2017
from the recordkeeping and reporting
requirements of Rule 13h–1(d) and (e),
except for (1) clearing broker-dealers for
large traders with respect to (a)
proprietary transactions by a large trader
broker-dealer, (b) transactions effected
pursuant to a ‘‘sponsored access’’
arrangement, and (c) transactions
effected pursuant to a ‘‘direct market
access’’ arrangement; and, for other
types of transactions, (2) broker-dealers
that carry an account for a large trader
for Transaction Data other than the
execution time.
63 See
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[FR Doc. 2015–28147 Filed 11–4–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–76316; File No. SR–
NASDAQ–2015–122]
October 30, 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 October
16, 2015, The NASDAQ Stock Market
LLC (‘‘NASDAQ’’ or ‘‘Exchange’’) filed
with the Securities and Exchange
Commission (‘‘SEC’’ or ‘‘Commission’’)
the proposed rule change as described
in Items I, II, and III, below, which Items
have been prepared by NASDAQ. 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
NASDAQ proposes to amend Chapter
VI, Section 19 entitled ‘‘Risk Monitor
Mechanism’’ by reserving this rule and
relocating the rule governing the Risk
Monitor Mechanism into NOM Rule at
Chapter VII, Section 6(f)(i), entitled
‘‘Market Maker Quotations’’ which
contains similar market maker 3 risk
monitor tools. The Exchange is also
modifying the language currently
contained in Chapter VI, Section 19.
The text of the proposed rule change
is available on the Exchange’s Web site
at https://
www.nasdaq.cchwallstreet.com, at the
principal office of the Exchange, and at
the Commission’s Public Reference
Room.
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 Pursuant to NOM Rules at Chapter VII, Section
5, entitled ‘‘Obligations of Market Makers’’, in
registering as a market maker, an Options
Participant commits himself to various obligations.
Transactions of a NOM Market Maker must
constitute a course of dealings reasonably
calculated to contribute to the maintenance of a fair
and orderly market, and Market Makers should not
make bids or offers or enter into transactions that
are inconsistent with such course of dealings.
Further, all Market Makers are designated as
specialists on NOM for all purposes under the Act
or rules thereunder. See Chapter VII, Section 5.
2 17
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Agencies
[Federal Register Volume 80, Number 214 (Thursday, November 5, 2015)]
[Notices]
[Pages 68590-68595]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-28147]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-76322]
Order Exempting Certain Large Traders From the Self-
Identification Requirements of Rule 13h-1 Under the Securities Exchange
Act of 1934, and Exempting Certain Broker-Dealers From the
Recordkeeping, Reporting, and Monitoring Responsibilities Under the
Rule
October 30, 2015.
On July 27, 2011, the Securities and Exchange Commission
(``Commission'') adopted Rule 13h-1 (the ``Rule'') under the Securities
Exchange Act of 1934 (``Exchange Act'') to assist the Commission in
both identifying and obtaining information on market participants that
conduct a substantial amount of trading activity, as measured by volume
or market value, in U.S. securities (such persons are referred to as
``large traders'').\1\ The Rule requires certain large traders to
identify themselves to the Commission by filing Form 13H and separately
requires certain broker-dealers to maintain records of large trader
transaction information and report such information to the Commission
upon request as well as monitor customer trading to help promote
compliance with the Rule by traders. Since December 1, 2011, persons
whose trading activity reached or exceeded the identifying activity
level specified in the Rule have been required to identify themselves
to the Commission by filing Form 13H through the Commission's EDGAR
system. The Commission implemented the broker-dealer recordkeeping,
reporting, and monitoring requirements of the Rule in phases through a
series of exemptive orders establishing certain delayed compliance
dates,\2\ and currently certain broker-dealers are required to keep
records of and report to the Commission upon request transaction data
for certain of their customers that are either a large trader or an
Unidentified Large Trader.\3\ Most recently, the Commission established
a compliance date of November 1, 2013 for Phase Two of the Rule, which,
among other things, implemented the recordkeeping and reporting
responsibilities for an additional category of traders and also
implemented the monitoring requirements under the Rule to require
certain broker-dealers to monitor their customers' trading activity in
order to promote awareness of and foster compliance with the self-
identification requirements of the Rule.\4\ At that time, the
Commission stated that the compliance date for Phase Three of the Rule
would be November 1, 2015.\5\
---------------------------------------------------------------------------
\1\ See Securities Exchange Act Release No. 64976 (July 27,
2011), 76 FR 46960 (Aug. 3, 2011) (``Adopting Release''). The
effective date of Rule 13h-1 was October 3, 2011.
\2\ See Securities Exchange Act Release Nos. 70150 (August 8,
2013), 78 FR 49556 (August 14, 2013) (establishing Phase Two and
providing for Phase Three); 69281 (April 3, 2013), 78 FR 20960
(April 8, 2013) (extension of the compliance date); and 66839 (April
20, 2012), 77 FR 25007 (April 26, 2012) (establishing Phase One).
\3\ Rule 13h-1(a)(9) defines ``Unidentified Large Trader'' as
``each person who has not complied with the identification
requirements of paragraphs (b)(1) and (b)(2) of this rule that a
registered broker-dealer knows or has reason to know is a large
trader.'' The Rule provides that, for purposes of determining
whether a registered broker-dealer has reason to know that a person
is a large trader, ``a registered broker-dealer need take into
account only transactions in NMS securities effected by or through
such broker-dealer.'' Rule 13h-1(a)(9).
\4\ See Securities Exchange Act Release No. 70150, supra note 2
(establishing the November 1, 2013 compliance date for customer
monitoring responsibilities). See also note 27, infra, and
accompanying text.
\5\ Phase Three includes all of the remaining requirements of
Rule 13h-1 that were not implemented in either Phase One or Phase
Two. In particular, Phase Three would require reporting of execution
time on trades for additional categories of persons beyond those
covered in Phases One and Two.
---------------------------------------------------------------------------
The Commission has received a request from the Financial
Information Forum (``FIF'') to exempt options traders from the
requirements of the Rule conditioned upon such traders not exceeding
the ``identifying activity level'' (i.e., the threshold at which a
person triggers the self-identification requirements of the Rule) as
calculated based on the gross premium of the options trades.\6\ FIF
asserts that such relief would appropriately limit the identification
requirements of the Rule by exempting from the Rule a class of persons
whose options trading is unlikely to have a market impact.\7\ In
addition, FIF requested that the Commission permanently exempt broker-
dealers from the recordkeeping and reporting requirements of Phase
Three of the Rule, or alternatively postpone the compliance date of the
Phase Three requirements until November 1, 2020.\8\ The Securities
Industry and Financial Markets Association (``SIFMA'') also has
requested that the Commission permanently exempt broker-dealers from
the recordkeeping and reporting
[[Page 68591]]
requirements of Phase Three of the Rule, or alternatively postpone the
compliance date of the Phase Three requirements until November 1,
2020.\9\
---------------------------------------------------------------------------
\6\ See Letter from Mary Lou VonKaenel, Managing Director, FIF,
to Stephen Luparello, Director of the Division of Trading and
Markets, Commission, dated March 27, 2015 (``FIF Letter''),
available at: https://www.sec.gov/comments/s7-10-10/s71010.shtml.
Currently, the fair market value of equity options is calculated
based on the value of the underlying securities. See Rule 13h-
1(c)(1)(i).
\7\ See FIF Letter, supra note 6, at 2-3.
\8\ See FIF Letter, supra note 6, at 3.
\9\ See Letter from Theodore R. Lazo, Managing Director and
Associate General Counsel, SIFMA to Stephen Luparello, Director of
the Division of Trading and Markets, Commission, dated April 9, 2015
(``SIFMA Letter''), available at: https://www.sec.gov/comments/s7-10-10/s71010.shtml.
---------------------------------------------------------------------------
For the reasons explained below, the Commission believes that
providing exemptive relief for equity options traders and deferring
Phase Three are appropriate. Accordingly, the Commission is: (1)
Conditionally exempting equity options market participants from the
self-identification requirements of the Rule if they have not met or
exceeded the alternative threshold described below that is applicable
to equity options trading; \10\ and (2) temporarily exempting broker-
dealers until November 1, 2017 from the remaining recordkeeping and
reporting obligations of the Rule beyond those established in Phases
One and Two.\11\
---------------------------------------------------------------------------
\10\ As discussed below, with respect to any persons that
previously registered as a large trader on account of their equity
options transactions, this exemption relieves those persons from
continued compliance with the periodic filing obligations as long as
they do not otherwise meet or exceed the identifying activity level
in the future.
\11\ Phases One and Two are discussed below. See infra text
accompanying notes 53 and 54.
---------------------------------------------------------------------------
I. Background
A. Large Trader Status
The Rule defines a large trader as a person who ``directly or
indirectly, including through other persons controlled by such person,
exercises investment discretion over one or more accounts and effects
transactions for the purchase or sale of any NMS security for or on
behalf of such accounts, by or through one or more registered broker-
dealers, in an aggregate amount equal to or greater than the
identifying activity level'' (emphasis added).\12\ The identifying
activity level contains daily and monthly share volume and fair market
value thresholds, namely: aggregate transactions in NMS securities that
are equal to or greater than (1) during a calendar day, either 2
million shares or shares with a fair market value of $20 million; or
(2) during a calendar month, either 20 million shares or shares with a
fair market value of $200 million.\13\
---------------------------------------------------------------------------
\12\ See Rule 13h-1(a)(1).
\13\ See Rule 13h-1(a)(7).
---------------------------------------------------------------------------
In establishing the current identifying activity level for equity
derivative securities, the Commission stated that the Rule was intended
to focus on the potential impact of options transactions on the market
for the underlying security.\14\
---------------------------------------------------------------------------
\14\ See Adopting Release, supra note 1, 76 FR at 46967 (noting
that this focus reflected and was consistent with Section 13(h) of
the Exchange Act).
---------------------------------------------------------------------------
Specifically, for equity options,
share volume is calculated by multiplying the number of
contracts by the option contract's specified multiplier; and
fair market value is calculated using the value of the
securities underlying the option.\15\
---------------------------------------------------------------------------
\15\ Examples of how to calculate the identifying activity for
options transactions were provided in the Adopting Release, supra
note 1, 76 FR at 46967. In contrast, for index options, share volume
is not calculated because index options do not overlie shares and
fair market value is calculated by multiplying together the index
multiplier, the number of options, and the price per contract.
---------------------------------------------------------------------------
At the time the Commission adopted Rule 13h-1, the Commission
stated that this approach was consistent with Section 13(h)(1) of the
Exchange Act, which sought to promote the Commission's ability to
``monitor[ ] the impact on the securities markets of securities
transactions involving a substantial volume or a large fair market
value or exercise value . . .'' in that the methodology considers the
equivalent exercise value of the options on the date of purchase.\16\
This approach eliminates the need to track and separately consider
exercise and instead preemptively identifies traders whose options
trading may be of a sufficient magnitude to potentially affect the
underlying stock if the positions are exercised.
---------------------------------------------------------------------------
\16\ See Adopting Release, supra note 1, 76 FR at 46967, text
accompanying n.65.
---------------------------------------------------------------------------
B. The Requirements of Rule 13h-1
1. Large Trader Self-Identification
As noted above, the Rule requires large traders to self-identify to
the Commission on Form 13H and periodically update their Form 13H
submission,\17\ obtain a unique large trader identification number
(``LTID'') from the Commission,\18\ and provide this number to their
brokers and identify each account to which the LTID applies.\19\ These
large trader responsibilities are referred to collectively as the
``Self-Identification Requirements.''
---------------------------------------------------------------------------
\17\ See Rule 13h-1(b)(1)(i)-(iii). Form 13H and all updates to
it are filed electronically through the Commission's EDGAR system.
\18\ When a large trader files its initial Form 13H filing
through EDGAR, the system sends an automatically generated
confirmation email acknowledging acceptance of the filing. That
email also contains the unique 8-digit LTID number assigned to the
large trader.
\19\ See Rule 13h-1(b)(2). See also Large Trader Adopting
Release, supra note 1, 76 FR at 46971 (``the requirements that a
large trader provide its LTID to all registered broker-dealers who
effect transactions on its behalf, and identify each account to
which it applies, are ongoing responsibilities that must be
discharged promptly'').
---------------------------------------------------------------------------
2. Broker-Dealers' Recordkeeping and Reporting Responsibilities
Regarding Unidentified Large Traders and the Customer Monitoring Safe
Harbor
Under Rules 13h-1(d) and (e), registered broker-dealers are
responsible for, among other things, keeping records of and reporting
to the Commission upon request data for their customers that are large
traders or Unidentified Large Traders.\20\ Specifically, Rule 13h-1
requires that every registered broker-dealer maintain records of data
specified in paragraphs (d)(2) and (d)(3) of the Rule (``Transaction
Data''), including the applicable LTID(s) and execution time on each
component trade, for all transactions effected directly or indirectly
by or through: (1) An account such broker-dealer carries for a large
trader or an Unidentified Large Trader; or (2) if the broker-dealer is
a large trader, any proprietary or other account over which such
broker-dealer exercises investment discretion. Additionally, where a
non-broker-dealer carries an account for a large trader or an
Unidentified Large Trader under the Rule, the broker-dealer effecting
transactions directly or indirectly for such large trader or
Unidentified Large Trader must maintain records of all Transaction
Data.\21\ These recordkeeping obligations are referred to collectively
as the ``Recordkeeping Responsibilities.'' The Rule also requires that,
upon Commission request, every registered broker-dealer that is itself
a large trader or carries an account for a large trader or an
Unidentified Large Trader must electronically report Transaction Data
to the Commission through the Electronic Blue Sheets (``EBS'') system
for all transactions, equal to or greater than the reporting activity
level, effected directly or indirectly by or through accounts carried
by such broker-dealer for large traders or Unidentified Large
Traders.\22\ Additionally, where a non-broker-dealer carries an account
for a large trader or an Unidentified Large Trader, the broker-dealer
effecting such transactions directly or indirectly for a large trader
or Unidentified Large Trader must electronically report Transaction
Data to the Commission through the EBS system.\23\ The Rule requires
that reporting broker-dealers submit the requested Transaction Data no
later than the day and time specified in the
[[Page 68592]]
Commission's request.\24\ These reporting obligations are referred to
collectively as the ``Reporting Responsibilities.'' The Commission has
implemented the Recordkeeping and Reporting Responsibilities in phases,
as discussed in greater detail below.\25\
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\20\ See note 3, supra.
\21\ See Rule 13h-1(d)(1)(iii).
\22\ See Rule 13h-1(e).
\23\ See id.
\24\ See id.
\25\ See Section II.D, infra.
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Rule 13h-1(f) provides a safe harbor that is designed to reduce
broker-dealers' recordkeeping and reporting burdens with respect to
Unidentified Large Traders by, among other things, providing relief for
when a broker-dealer shall be deemed to know or have reason to know
that a person is a large trader and thus subject to reporting
obligations related to Unidentified Large Traders under Rule 13h-1.
Under the safe harbor, a registered broker-dealer is deemed not to know
or have reason to know that a person is a large trader if it does not
have actual knowledge that a person is a large trader and it
establishes policies and procedures reasonably designed to identify
customers whose transactions at the broker-dealer equal or exceed the
identifying activity level and, if so, to treat such persons as
Unidentified Large Traders and notify them of their potential reporting
obligations under this Rule.\26\ Collectively, these broker-dealer
undertakings are referred to as the ``Customer Monitoring
Obligations.'' The Customer Monitoring Obligations are intended to
promote awareness of and foster compliance with the Rule among persons
who might not otherwise be aware of the large trader reporting
requirements.\27\
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\26\ See Rule 13h-1(f).
\27\ See Adopting Release, supra note 1, 76 FR at 46997.
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As noted above, the Commission previously granted broker-dealers
temporary exemptions from the Customer Monitoring Obligations.\28\ As
of November 1, 2013, to avail themselves of the safe harbor, broker-
dealers with recordkeeping and reporting responsibilities were required
to implement the Customer Monitoring Obligations.
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\28\ See Securities Exchange Act Release Nos. 66839 and 69281,
supra note 2.
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II. Exemptive Relief
Pursuant to Section 13(h)(6) of the Exchange Act and Rule 13h-1(g)
thereunder,\29\ the Commission, by order, may exempt from the
provisions of Rule 13h-1, upon specified terms and conditions or for
stated periods, any person or class of persons or any transaction or
class of transactions from the provisions of Rule 13h-1 to the extent
that such exemption is consistent with the purposes of the Exchange
Act.
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\29\ See 15 U.S.C. 78m and 17 CFR 240.13h-1(g), respectively.
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FIF requests that the Commission grant exemptive relief for options
traders that would be conditioned upon such traders' activity not
exceeding the Rule's identifying activity threshold based on the gross
premiums paid for the options as opposed to the value of the underlying
stock at the time of the trade.\30\ FIF notes that some of its members,
particularly brokers with retail customers, have identified through
their Customer Monitoring Obligations a number of retail customers that
met or exceeded the threshold based primarily on such customers' equity
options trading, particularly in deep out-of-the-money options on high
priced underlying stocks.\31\ According to FIF, customers that meet the
``underlying value'' threshold rarely exercise their options, and many
of them would be unable to do so based on their account balances.\32\
FIF argues that exemptive relief for all options traders conditioned
upon a premium-based threshold calculation would appropriately focus
the Rule on traders who are more significant participants in the U.S.
securities markets and who are more likely to trade options at levels
and in a manner that could have a market impact.\33\
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\30\ FIF requests that the alternative ``options premium''
threshold be consistent with Rule 13h-1(a)(7), which establishes the
daily and monthly market value thresholds of the identifying
activity level as $20 million and $200 million, respectively. See
FIF Letter, supra note 6, at 2.
\31\ See FIF Letter, supra note 6, at 1.
\32\ See FIF Letter, supra note 6, at 2.
\33\ See FIF Letter, supra note 6, at 2-3.
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In addition, both FIF and SIMFA request that the Commission
permanently exempt broker-dealers from the additional recordkeeping and
reporting requirements of Phase Three of the Rule, which have not yet
been implemented.\34\ In the alternative, FIF requests an extension of
Phase Three by an additional five years \35\ and SIFMA requests an
extension to the earlier of full implementation of a Consolidated Audit
Trail (``CAT'') or November 1, 2020.\36\ Both FIF and SIFMA stated that
their request would allow firms to focus their resources on
implementing a CAT.\37\
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\34\ See FIF Letter, supra note 6, at 3 and SIFMA Letter, supra
note 9, at 2-3.
\35\ See FIF Letter, supra note 6, at 3.
\36\ See SIFMA Letter, supra note 9, at 2. See also Rule 613;
Securities Exchange Act Release No. 67457 (July 18, 2012), 77 FR
45722 (Aug. 1, 2012).
\37\ See FIF Letter, supra note 6, at 3 and SIFMA Letter, supra
note 9, at 2.
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A. Exemption From the Self-Identification Requirements for Equity
Options Traders
As discussed above, the current identifying activity level
methodology for equity options was designed to focus on the potential
impact of options transactions on the market for the underlying
securities. Based on its experience and the experience of its member
firms, however, FIF suggests that the current methodology designates as
large traders some persons who rarely exercise their options and whose
aggregate equity options transactions, considering the actual premium
paid for the options, are not of a large enough fair market value to
have an impact either on the options market or the underlying equities
markets.
In particular, FIF notes that this issue appears to be especially
pronounced for market participants, particularly individual non-
professional investors, who transact in deep out-of-the money options
on high-priced securities.\38\ While such transactions may have large
exercise values, the premium paid for the options may be modest due to
the deep-out-of-the-money nature of the contract, and, importantly,
exercise among these traders is very infrequent, according to FIF.
FIF's members reported that, among their customers that became large
traders as a result of options transactions, such customers very rarely
exercised their options,\39\ and FIF asserts that many may have lacked
the resources to do so.\40\ In other words, the current methodology for
calculating the fair market value of equity options has resulted in the
self-identification as large traders of a number of investors who trade
equity options, yet such investors' activity is
[[Page 68593]]
unlikely to have a material impact either on the options market or the
underlying equities markets for the purposes of Rule 13h-1.
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\38\ See FIF Letter, supra note 6, at 1.
\39\ FIF reports that it surveyed its members and found that
customers that became large traders as a result of options
transactions (``Equity Options LT Customers'') exercised their
options less than 2% of the time on average. See FIF Letter, supra
note 6, at 2.
\40\ FIF states that, ``[g]iven the account size associated with
this class of investor it is unlikely that they would have the
ability to exercise these out of the money options.'' See id. To
support this conclusion, FIF provides anecdotal data: A firm with
approximately 2,000 Equity Options LT Customers reported that the
average account value was $835,000. Another FIF member firm reported
that: The average account size for 90% of its Equity Options LT
Customers was less than $555,000; the average value across all
Equity Options LT Customer accounts was $2.5 million; and excluding
the top 50% of its Equity Options LT Customer accounts, the average
account size was under $56,000. See id. FIF suggests that without
sufficient assets or collateral, such customers would not be able to
outright purchase or otherwise finance their acquisition of the
underlying securities in an amount that equals or exceeds the $20
million threshold.
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In order to alleviate the burdens on these persons without
undermining the purposes of Section 13(h), the Commission hereby is
providing a conditional exemption from the Self-Identification
Requirements for persons that trade equity options if: (1) The
aggregate value of their equity option transactions based on premium
paid,\41\ combined with the aggregate value of their transactions in
all other NMS securities (if any), does not reach or exceed the current
fair market value thresholds of the identifying activity level; and (2)
they also do not reach or exceed the share volume thresholds of the
identifying activity level.\42\ Accordingly, this exemptive relief
makes the calculation of fair market value for equity options
consistent with how index options are valued under the identifying
activity level.\43\
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\41\ To calculate premium paid for an options trade, multiply
together the number of options contracts involved, the premium paid,
and the applicable multiplier. For an example, see infra Section
II.A.3.
\42\ Neither FIF nor SIFMA have requested exemptive relief for
persons who become large traders as a result of reaching the
identifying activity level share volume thresholds applicable to
equity options, and the Commission is not herein granting such
relief.
\43\ See Rule 13h-1(c)(1)(ii) (concerning the fair market value
of index options). See also Adopting Release, supra note 1, 76 FR at
46967 (noting, in footnote 64 and the accompanying text, how to
determine the fair market value of index (and equity) options).
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This relief utilizes the existing fair market value thresholds of
the identifying activity level and references premium paid instead of
the price of the underlying at the time of the trade.\44\ The
Commission is persuaded that valuing equity options using premium paid
and applying the existing fair market value thresholds appropriately
focuses the Rule on persons whose transactions are more likely to have
a market impact and therefore warrant triggering the Self-
Identification Requirements. In particular, as FIF has stated, the
current methodology impacts a number of equity options traders, many of
whom reach the threshold by purchasing options that are deep out of the
money and who do not otherwise trade in an amount required to reach the
identifying activity level. When these options expire out of the money
and are not exercised, the position does not result in any trading in
the underlying securities, and thus valuing such options with reference
to the price of the underlying security is unlikely to be a useful
method to identify traders with the potential to have a market impact
on the underlying equities.\45\ Using premium paid to value equity
options instead will focus the identification requirement on options
traders who trade options in larger amounts that thus may be more
likely to have a market impact regardless of whether the positions are
ultimately exercised. In addition, employing the existing fair market
value thresholds to the new premium-based methodology for equity
options allows all trading in NMS securities to be easily aggregated
for purposes of determining large trader status.\46\ For these reasons,
the Commission believes that calculating the fair market value for
equity options by referencing the premium paid for the options is a
better overall indicator, for purposes of Rule 13h-1, of potential
market impact and provides appropriate relief to equity options
traders. Accordingly, the Commission finds the exemptive relief to be
consistent with the purposes of the Exchange Act.
---------------------------------------------------------------------------
\44\ See Rule 13h-1(c)(1)(i) (concerning the fair market value
of equity securities underlying transactions in stock options).
\45\ Only purchases and sales of equity options and not
transactions in the underlying securities pursuant to exercises or
assignments count toward the identifying activity level. See Rule
13h-1(a)(6). Purchases and sales pursuant to exercises or
assignments were expressly excluded from the identifying activity
level calculation to avoid double-counting. See Adopting Release,
supra note 1, 76 FR at 46967. The Commission notes that traders may
trigger the Self-Identification Requirements when they trade out of
the position they obtained by exercising their options.
\46\ Further, as noted above, for purposes of the identifying
activity level under Rule 13h-1(c) (i) and (ii), fair market value
of equity options is calculated differently than that for index
options; the fair market value of equity options is calculated based
on the value of the underlying security, while the fair market value
of index options is calculated based on the premium paid for the
contract. As a result, it is easier to reach the identifying
activity level by transacting in options on an exchange-traded fund
overlying a securities index than it is to transact in index options
on the same securities index. This relief harmonizes the fair market
value calculations for equity options overlying index-tracking
securities (such as index-based exchange traded funds) with the
calculations for index options, thereby eliminating the Self-
Identification Requirements as a consideration for investors
choosing between options products with comparable exposures.
---------------------------------------------------------------------------
Applying the Threshold Permitted by this Conditional Exemption.
Equity Option Transactions Example. For example, during a calendar day,
a person purchases 200 call options on ABC stock, each with a 100
multiplier, for a premium of $15 per share, where the underlying stock
is trading at $1,000 at the time of the transaction. This transaction
reaches the identifying activity level under the current calculation
methodology,\47\ pursuant to which the options are valued as follows:
200 contracts x 100 shares per contract x $1,000 (the market price of
the underlying stock at the time of the trade) = $20 million.
Therefore, this transaction would cause the person to qualify as a
large trader. However, under this exemptive relief, the fair market
value of the options trade would be calculated as follows: 200
contracts x 100 shares per contract x $15 premium price = $300,000. In
this case, the transaction price of $300,000 is less than the
identifying activity level of $20 million. Further, the daily share
volume would be calculated as follows: 200 contracts x 100 shares of
the underlying per contract = 20,000 shares, which also is less than
the identifying activity level of 2 million shares. Therefore, the
person would qualify for this exemption from the Self-Identification
Requirements and would not be required to register as a large trader on
the basis of this particular options trade alone.
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\47\ The daily market value threshold of the identifying
activity level is $20 million.
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``Mixed'' Transactions Example. By way of another example, consider
a person that, during a calendar day, (1) purchases: (a) 100 call
options, each with a 100 multiplier, for a premium of $15 per share,
where the underlying stock is trading at $1,000 at the time of the
transaction; and (b) 100 contracts of puts on an index, where each
option uses a $100 multiplier, for $50 per unit; and (2) sells 100,000
shares of an exchange-traded fund (``ETF'') for $100 per share. Under
the current method, the fair market value of each transaction would be
calculated as follows:
100 call option contracts x 100 (contract multiplier) x $1,000
(price of the underlying stock) = $10 million
100 index puts x $100 (contract multiplier) x $50 (price per
unit) = $500,000
100,000 ETF shares x $100 (price per share) = $10 million
Collectively, for purposes of the identifying activity level, the
transactions would be valued at $20,500,000 ($10 million + $500,000 +
$10 million), which is greater than the daily value threshold ($20
million). Accordingly, the person would be required to self-identify to
the Commission as a large trader.
To determine whether the large trader qualifies for this exemptive
relief, the equity options would be valued as follows:
100 call option contracts x 100 (contract multiplier) x $15
(premium price) = $150,000
100 index puts x $100 (contract multiplier) x $50 (price per
unit) = $500,000
[[Page 68594]]
100,000 ETF shares x $100 (price per share) = $10 million
The person qualifies for exemption from the Self-Identification
Requirements (i.e., does not have to identify as a large trader based
on this day's transactions alone) because: (1) The daily share volume
threshold of the identifying activity level (2 million shares) is not
reached; \48\ and (2) the value of the equity options under the
alternative methodology ($150,000), when combined with the fair market
value of the index option and ETF transactions ($500,000 and $10
million, respectively), is less than the daily identifying activity
level threshold ($20 million).\49\
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\48\ The share volume calculation of the three transactions is
as follows: (100 call option contracts x 100 contract multiplier) +
0 (index options have no underlying shares) + 100,000 ETF shares =
110,000 shares.
\49\ $150,000 + $500,000 + $10 million = $10,650,000, which is
less than the daily market threshold of the identifying activity
level ($20 million).
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B. Broker-Dealers May Update Their Monitoring Safe Harbor Policies and
Procedures To Use the New Methodology
Paragraph (f) of Rule 13h-1 provides a safe harbor to reduce
broker-dealers' burdens in connection with monitoring their customers'
trading for purposes of identifying possible large traders. To take
advantage of the safe harbor, broker-dealers must have policies and
procedures reasonably designed to identify persons who have reached or
exceeded the identifying activity level \50\ but not identified
themselves to the broker-dealer as a large trader, treat such persons
as Unidentified Large Traders, and inform such persons of the
obligations under Rule 13h-1. A broker-dealer that updates its policies
and procedures to reflect the terms of the exemptive relief described
above will be able to avail itself of the monitoring safe harbor.
---------------------------------------------------------------------------
\50\ See Rule 13h-1(f)(1).
---------------------------------------------------------------------------
C. Relief for Equity Options Large Traders Who Already Self-Identified
For any person that previously reached the identifying activity
level as a result of the fair market value of their equity options
transactions and previously self-identified to the Commission as a
large trader, but who otherwise does not presently meet the identifying
activity level as calculated under the exemptive relief provided
herein, the Commission finds that it is consistent with the purposes of
the Exchange Act to allow such person to file for inactive status
without waiting the required full calendar year provided in paragraph
(b)(3)(iii) of Rule 13h-1.
To take advantage of this relief, a large trader must file for
inactive status by submitting Form 13H electronically through
EDGAR.\51\ After filing for inactive status, the large trader is
relieved from the Self-Identification Requirements, and thereafter is
not required to file any further amendments or annual updates to Form
13H through EDGAR, unless and until the large trader subsequently
effects transactions that reach or exceed the identifying activity
level, accounting for the relief granted herein for calculating equity
options activity. If a large trader that has filed for inactive status
later reaches or exceeds the identifying activity level, using premium
paid to calculate the fair market value of subsequent equity options
transactions, then the large trader must promptly file Form 13H with
the Commission for reactivated status and promptly thereafter notify
its broker-dealers of its reactivated status and update them regarding
the applicability of the large trader's LTID and the accounts to which
it applies.
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\51\ The specific form type in EDGAR to file for inactive status
is Form 13H-I. After filing for inactive status, the large trader
also may inform the broker-dealers through which it transacts of its
inactive status. Broker-dealers are not required to keep records of
transactions by inactive large trader customers after receiving
notice of inactive status from such trader with respect to
transactions effected subsequent to such notification. See Adopting
Release, supra note 1, 76 FR at 46976.
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D. Temporary Exemption From Phase Three of the Recordkeeping and
Reporting Responsibilities
As noted above, the Commission has implemented the Recordkeeping
and Reporting Responsibilities applicable to clearing brokers for large
traders in phases. In Phase One, which began on November 30, 2012, the
Commission required clearing brokers for large traders (including the
large trader itself if it is a self-clearing broker-dealer) to keep
records and report Transaction Data for large traders' transactions
that were either (1) proprietary trades by a U.S. registered broker-
dealer; or (2) effected through a ``sponsored access'' arrangement;
\52\ otherwise, broker-dealers were temporarily exempted from the
Recordkeeping and Reporting Responsibilities.\53\ In Phase Two, which
began on November 1, 2013, the Commission again temporarily exempted
broker-dealers, until November 1, 2015, from the Recordkeeping and
Reporting Responsibilities, except for: (1) The clearing broker-dealer
for a large trader, with respect to (a) proprietary transactions by a
large trader broker-dealer; (b) transactions effected pursuant to a
``sponsored access'' arrangement; and (c) transactions effected
pursuant to a ``direct market access'' arrangement; and (2) a broker-
dealer that carries an account for a large trader, with respect to
transactions other than those set forth above, and for Transaction Data
other than the execution time.\54\ The Commission also established
Phase Three, which requires full compliance with the Recordkeeping and
Reporting Responsibilities for all applicable broker-dealers starting
November 1, 2015.\55\
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\52\ See Securities Exchange Act Release No. 66839, supra note
2, 77 FR at 25008-9. A sponsored access arrangement is one where a
broker-dealer permits a customer to enter orders into a trading
center without using the broker-dealer's trading system (i.e., using
the customer's own technology or that of a third party provider). At
the time, FIF indicated that broker-dealer compliance would be
easier for sponsored access customers because those arrangements
typically are distinct from all other business lines of the broker-
dealer, with infrastructure that processes this order flow that is
separate from the platforms that handle other client and proprietary
flows. See id., 77 FR at 25008, n.16.
\53\ See id., 77 FR at 25010.
\54\ See Securities Exchange Act Release No. 70150, supra note
2, 78 FR at 49558-9.
\55\ See id., 78 FR at 49560.
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When the Commission adopted the Rule, it characterized the large
trader reporting requirements as ``relatively modest steps'' to
``address the Commission's near-term need for access to more
information about large traders and their trading activities. . . .''
\56\ After the Commission adopted the Rule, industry commenters began
to identify specific implementation challenges and offered more
detailed estimates of the cost of full compliance with the
Recordkeeping and Reporting Responsibilities. Such concerns led the
Commission to implement the Recordkeeping and Reporting
Responsibilities in phases.\57\
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\56\ See Adopting Release, supra note 1, 76 FR at 46963.
\57\ See note 2, supra.
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Additionally, since adopting the Rule, the Commission adopted Rule
613, which directed the self-regulatory organizations (``SROs'') to
jointly submit a plan to create a comprehensive CAT that would allow
regulators to efficiently and accurately track all activity throughout
the U.S. markets in National Market System (NMS) securities.\58\ When
the Commission adopted that rule, it stated that, while certain aspects
of Rule 13h-1 are not addressed by Rule 613, Rule 613 may
[[Page 68595]]
supersede certain of the broker-dealer Recordkeeping and Reporting
Responsibilities of Rule 13h-1.\59\ Specifically, the Commission
stated: ``[t]o the extent that . . . data reported to the central
repository under Rule 613 obviates the need for the EBS system, the
Commission expects that the separate [trade] reporting requirements of
Rule 13h-1 related to the EBS system would be eliminated.'' \60\
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\58\ Among other things, Rule 613 requires the self-regulatory
organizations to jointly submit an NMS plan to create, implement and
maintain a consolidated audit trail, and specifies the type of data
to be collected and reported to a central repository.
\59\ See Securities Exchange Act Release No. 67457 (July 18,
2012), 77 FR 45722, 45734 (August 1, 2012).
\60\ Id., text accompanying n.95.
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The SROs submitted the initial CAT NMS plan to the Commission on
September 30, 2014, and filed an amended plan on February 27, 2015.\61\
As of the date of this Order, an NMS plan for a CAT has not yet been
published for notice and comment. Accordingly, the Commission continues
to rely on, among other things, information available through the
Recordkeeping and Reporting Responsibilities as implemented through
Phases One and Two. In light of the fact that there is no approved CAT
NMS plan, the Commission is hesitant at this time to require broker-
dealers to incur the costs associated with the remaining Phase Three
Large Trader data while the timing of a CAT remains unclear.
---------------------------------------------------------------------------
\61\ Pursuant to Rule 613, the SROs were required to file the
CAT NMS Plan on or before April 28, 2013. At the SROs' request, the
Commission granted exemptions to extend the deadline for filing the
CAT NMS Plan to December 6, 2013, and then to September 30, 2014.
See Securities Exchange Act Release Nos. 69060 (Mar. 7, 2013), 78 FR
15771 (Mar. 12, 2013) and 71018 (Dec. 6, 2013), 78 FR 75669 (Dec.
12, 2013).
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However, the Commission finds that it is consistent with the
purposes of the Exchange Act to delay Phase Three, temporarily
exempting broker-dealers until November 1, 2017 from the Recordkeeping
and Reporting Responsibilities, except for: (1) The clearing broker-
dealer for a large trader, with respect to (a) proprietary transactions
by a large trader broker-dealer; (b) transactions effected pursuant to
a ``sponsored access'' arrangement; and (c) transactions effected
pursuant to a ``direct market access'' arrangement; and (2) a broker-
dealer that carries an account for a large trader, with respect to
transactions other than those set forth above, and for Transaction Data
other than the execution time. While FIF and SIFMA have requested a
permanent exemption, or alternatively an additional 5-year deferment of
the compliance date for Phase Three,\62\ the Commission believes at
this time that a 2-year extension of the Phase Three compliance date
provides sufficient time for the Commission to consider whether to
revisit compliance with all of the Recordkeeping and Reporting
Responsibilities. Specifically, two years will give the Commission
enough time to evaluate future developments, including any investment
in or progress on a CAT.\63\
---------------------------------------------------------------------------
\62\ See FIF Letter, supra note 6, at 3 and SIFMA Letter, supra
note 9, at 2-3.
\63\ See note 60, supra, and accompanying text.
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III. Conclusion
It is hereby ordered, pursuant to Section 13(h)(6) of the Exchange
Act and Rule 13h-1(g) thereunder, that:
(1) Persons transacting in equity options are exempt from the Self-
Identification Requirements if: (1) The aggregate value of their equity
option transactions, calculated based on premium paid, combined with
the aggregate value of their transactions in all other NMS securities
(if any), does not reach or exceed the fair market value thresholds of
the identifying activity level; and (2) they also do not reach or
exceed the share volume thresholds of the identifying activity level.
(2) A large trader whose transactions in NMS securities since
October 3, 2011 reached the identifying activity level one or more
times because of the fair market value of its equity options
transactions and who would have qualified in each instance for relief
under this exemption is exempt from its responsibilities under Rule
13h-1(b)(1)(ii), 13h-1(b)(1)(iii), and 13h-1(b)(2), if such trader
files for inactive status by submitting Form 13H and does not
subsequently effect transactions that reach or exceed the identifying
activity threshold using premium paid to calculate the fair market
value of equity options transactions.
(3) Broker-dealers are exempted temporarily until November 1, 2017
from the recordkeeping and reporting requirements of Rule 13h-1(d) and
(e), except for (1) clearing broker-dealers for large traders with
respect to (a) proprietary transactions by a large trader broker-
dealer, (b) transactions effected pursuant to a ``sponsored access''
arrangement, and (c) transactions effected pursuant to a ``direct
market access'' arrangement; and, for other types of transactions, (2)
broker-dealers that carry an account for a large trader for Transaction
Data other than the execution time.
By the Commission.
Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2015-28147 Filed 11-4-15; 8:45 am]
BILLING CODE 8011-01-P