Self-Regulatory Organizations; ICE Clear Credit LLC; Notice of Filing of Proposed Rule Change To Revise the ICC Risk Management Framework and ICC Treasury Operations Policies and Procedures, and Adopt the ICC Risk Management Model Description Document, 69261-69264 [2015-28402]
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Federal Register / Vol. 80, No. 216 / Monday, November 9, 2015 / Notices
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.13
Brent J. Fields,
Secretary.
[FR Doc. 2015–28400 Filed 11–6–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–76331; File No. SR–ICC–
2015–017]
Self-Regulatory Organizations; ICE
Clear Credit LLC; Notice of Filing of
Proposed Rule Change To Revise the
ICC Risk Management Framework and
ICC Treasury Operations Policies and
Procedures, and Adopt the ICC Risk
Management Model Description
Document
November 3, 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
20, 2015, ICE Clear Credit LLC (‘‘ICC’’)
filed with the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change as described in
Items I, II, and III below, which Items
have been prepared primarily by ICC.
The Commission is publishing this
notice to solicit comments on the
proposed rule change from interested
persons.
srobinson on DSK5SPTVN1PROD with NOTICES
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
ICC proposes reorganizing the ICC
Risk Management Framework (‘‘RMF’’)
in response to a recommendation from
the Commodity Futures Trading
Commission (‘‘CFTC’’) regarding
improvements related to the governance
of ICC’s risk management
documentation. Specifically, ICC
proposes organizational and clarifying
edits to the RMF and the Treasury
Operations Policies and Procedures, and
proposes adopting a new Risk
Management Model Description
Document. These revisions do not
require any changes to the ICC Clearing
Rules (‘‘Rules’’). Additionally, the edits
are not substantive and do not affect the
nature of ICC’s risk management
program.
13 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
1 15
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II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, ICC
included statements concerning the
purpose of and basis for the proposed
rule change and discussed any
comments it received on the proposed
rule change. The text of these statements
may be examined at the places specified
in Item IV below. ICC has prepared
summaries, set forth in sections A, B
and C below, of the most significant
aspects of these statements.
A. Self-Regulatory Organization's
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
ICC proposes reorganizing the ICC
RMF in response to a CFTC
recommendation regarding
improvements related to the governance
of ICC’s risk management
documentation. Specifically, ICC
proposes organizational and clarifying
edits to the RMF and the Treasury
Operations Policies and Procedures, and
proposes adopting a new Risk
Management Model Description
Document. ICC believes such revisions
will facilitate the prompt and accurate
clearance and settlement of securities
transactions and derivative agreements,
contracts, and transactions for which it
is responsible. The proposed revisions
are described in detail as follows.
ICC moved the Collateral Assets Risk
Management Framework appendix from
the RMF to the Treasury Operations
Policies and Procedures. Accordingly,
references throughout the RMF to the
Collateral Assets Risk Management
Framework appendix were updated to
refer instead to the Treasury Operations
Policies and Procedures. ICC moved
appendices containing technical risk
management information (formerly,
RMF Appendices 3–5) to the new ICC
Risk Management Model Description
Document. Accordingly, references
throughout the RMF to these appendices
were updated to refer to the Risk
Management Model Description
Document.
ICC also made general updates and
edits throughout the RMF for clarity and
consistency. Such edits include
correcting verb tenses, adopting
consistent abbreviations, and adjusting
sentence order to assure logical
presentation and word flow, and to use
more concise, succinct language. ICC
also made additional clarifying edits, as
described below. The edits are not
substantive and do not affect the nature
of ICC’s risk management program.
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Within the Overview section of the
RMF, ICC refined the Business
Overview details to more accurately
describe the business operations of
Intercontinental Exchange, Inc. and ICC.
ICC made edits to the Governance and
Organization section of the RMF to more
fully describe which topics the Risk
Committee is responsible to advise the
Board. The list of documents reviewed
by the Risk Committee on at least an
annual basis was revised to include the
ICC Risk Management Model
Description Document, the ICC Treasury
Operations Policies and Procedures, and
the ICC Liquidity Risk Management
Framework. The Risk Working Group
(‘‘RWG’’) description was updated to
note that the group consists of risk
personnel from ICC Clearing
Participants (‘‘CPs’’), and to clarify that
the RWG is responsible for reviewing
ICC’s risk philosophy and
recommending changes to ICC’s RMF.
The validation function of the risk
philosophy and tolerance was removed
from the list of RWG responsibilities, as
such functions are the ultimate
responsibility of the Board. The
Advisory Committee description was
updated to note that the committee is
comprised of representatives of up to
twelve clients/customers of ICC CPs
(currently there are twelve client/
customer members). The CDS Default
Committee description was updated to
note that the committee is comprised of
representatives from ICC CPs on a
rotating basis and to remove reference to
a duty to provide feedback on ICC’s
RMF and parameters because the CDS
Default Committee is only convened
upon the declaration of a default. The
committee description was enhanced to
note that, as the CDS Default Committee
assists ICC in determining and
managing Minimum Target Prices for
auctioned portfolios related to a default,
the committee oversees necessary
auction(s) as well as the process to reestablish a matched book. The Risk
Management Organization section was
updated to remove outdated language
stating that the Risk Management
Department conducts an annual review
of ICC’s Risk Management Framework
Policy Statement and submits proposed
changes to the RWG, Risk Committee,
and Board. Further, the section was
updated to remove reference to the Risk
Management Department being
responsible for ICC’s intellectual capital
and personnel, while creating,
implementing and maintaining ICC’s
risk management policies.
ICC made edits to the Product
Summary section of the RMF. ICC
clarified language to refer to Index CDS
Instruments (as opposed to Index
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Products), Single Name CDS
Instruments (as opposed to Single Name
CDS), and reference entities (as opposed
to companies). The Index CDS
instruments section was revised to
remove reference to the International
Index Company. The Single Name CDS
Instruments section was modified to
refine language concerning what
constitutes a credit event. The list of
attributes defining a CDS contract was
enhanced to include Maturity, as well as
reference Notional Amount, as opposed
to Notional Principal. Reference to the
terms of the contracts being prescribed
by the ICC Rules and Participant
Agreement was removed. The Risk
Factors, Risk Sub-Factors and
Instruments section was revised to
enhance the definition of Risk SubFactor to refer to a specific single name
reference obligation seniority and doc
clause combination.
ICC made edits to the Systemic Risk
Management Approach section of the
RMF, which includes Waterfall Levels 1
through 5. ICC revised Waterfall Level 1:
Membership Criteria to remove
reference, within the Operational
Criteria, to employee participation on
industry committees (e.g. ISDA, DTCC,
etc.). Furthermore, the ongoing
monitoring of participants section was
enhanced to state: (i) Intraday
monitoring includes intraday CDS
market levels and potential equity price
movements, as well as news from
Bloomberg and other information
sources; and (ii) daily monitoring and
analysis includes prior day’s final pays
by CP, daily change in Initial Margin
(‘‘IM’’), margin deficits, unrealized
intraday profits/losses for cleared
portfolios, risk impact of new intraday
trades on cleared portfolios, daily endof-day (‘‘EOD’’) levels, CPs’ Guaranty
Fund (‘‘GF’’) obligations, CPs’ day-overday change in GF requirements relative
to each firms prior day levels, and CPs’
day-over-day change in GF requirements
relative to the total GF balance. ICC has
removed from the ongoing monitoring of
participants section review of the
following components: Daily prices and
spreads (including missed EOD
submissions), daily EOD prices
(including missed prices), prior day’s
and intraday total IM as a percentage of
CP’s or CP’s guarantor’s capital,
collateral pricing report for missing
prices, and collateral deposits no longer
in compliance with ICC’s acceptable
collateral policy. Such elements are
included in the enhanced daily
monitoring and analysis section or have
been deemed no longer to relevant to
the monitoring process. Further, ICC
clarified that the Risk Management
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Department reviews weekly stress test
results for extreme risk event scenarios
to ensure sufficient margin cover under
market conditions, as opposed to drastic
market conditions. The Participant
Withdrawal subsection was revised to
remove reference to ICC’s right of One
Time Assessment and instead refer more
generally to ICC’s power of assessment.
ICC revised the Waterfall Level 2:
Initial Margin description to clarify that
ICC’s IM requirements consist of a set of
individual components that account for
various risks and that the methodology
includes consideration of hypothetical
scenarios for those components. ICC
added language to the Spread Response
requirements section to note that the
hypothetical prices used in calculating
the instrument spread response risk IM
requirement reflect the time-to-maturity
horizon reduced by one day. ICC revised
the distributions and related parameters
subsection to refer to the more specific
feature Mean Absolute Deviation
(‘‘MAD’’) as opposed to the more
general term ‘‘scale.’’ ICC removed
reference to a set EWMA decay factor,
as the factor is dynamic and subject to
review and changes by the Risk
Department in consultation with the
Risk Committee. ICC also removed
outdated language regarding the initial
setting of Auto Regressive process for
first order parameters.
ICC revised the description of the
considered scenarios to provide a
mathematical description of how the
considered scenarios are constructed
based on statistical analysis of historical
time series. The term structure scenario
construction is now clearly defined in
terms of 99% Value-at-Risk equivalent
risk measures for different tenors and
the cross-tenor correlation structure is
estimated from time series analysis. ICC
revised the term ‘‘contracting’’ to
‘‘tightening’’ in the context of spread
behavior to provide conformity to more
commonly used credit market
terminology.
Within the Recovery Rate (‘‘RR’’)
Sensitivity Requirements subsection,
ICC clarified that two additional single
name-specific stress-test RRs are
considered in determining the
requirements.
ICC revised Waterfall Level 3: Markto-Market Margin description.
Specifically, ICC revised the
methodology section to remove specific
calculations regarding the methodology
and instead refer to the ICC EOD Price
Discovery Policies and Procedures,
which contain a more fulsome
methodology description.
ICC revised Waterfall Level 4: Intraday Risk Monitoring/Special Margin
Call Execution to clarify language
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describing the calculation of prices to
determine the adequacy of collected IM
intraday. Specifically, as part of the
calculation, ICC utilizes bid-offer quotes
which are automatically fed into the ICC
risk management intraday monitoring
system.
ICC revised Waterfall Level 5:
Guaranty Fund description. The ICC GF
is designed to provide adequate funds to
cover losses associated with the default
of the two CPs, as well as any affiliated
CPs (i.e. any other CP that owns, is
owned by, or is under common
ownership with such a CP) with the
greatest potential uncollateralized
losses. ICC added language to note that
the set of all affiliated CPs is considered
as a CP affiliate group. Within the
Waterfall Level 5 description, ICC
revised language to reinforce this CP
affiliate group concept. Within the
Guaranty Fund Calculation for Clearing
Participants subsection, ICC removed
reference to summary concepts of
uncollateralized loss given default,
uncollateralized spread response losses,
uncollateralized basis risk losses, and
uncollateralized interest rate losses,
previously used in describing the
computations of the stress scenario
losses. ICC more precisely defined the
factors considered within the GF
calculation and related stress test
scenarios as the following: Occurrence
of multiple credit events,
uncollateralized loss-given-default from
self-referencing positions, adverse
spread scenarios, adverse index-singlename basis widening, adverse interest
rate scenarios, and anti procyclicality.
ICC added language to the Guaranty
Fund Allocation subsection of the RMF
to state that the CP’s total
uncollateralized GF stress loss is the
difference between the sum of the stress
loss given default, GF stress spread
response, GF stress basis risk and
interest rate losses and the sum of the
IM idiosyncratic jump-to-default
requirements, IM spread response
requirement, IM basis and interest risk
requirement.
ICC revised the General Wrong Way
Risk and Contagion Measures
subsection to remove technical
information that was moved to the Risk
Management Model Description
Document.
ICC revised the Position
Concentration Limits subsection of the
Risk Limits and Controls section to
clarify that ICC’s concentration charge is
designed to increase a CP’s IM
requirement toward the risk of
maximum loss and ultimately, at the
extreme, toward the full expected
notional amount of liability of the sold
protection or the present value of the
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amount of coupon payments for bought
protection. ICC summarized language
referring to the notional liability of the
protection sold or the full value of
coupon payments to refer more
generally to loss associated with the
portfolio. ICC revised the Model Time
Horizon subsection to note that the
standard risk horizon can be increased
by the ICC Risk Management
Department during banking holiday
periods to reflect ICC’s limited ability to
execute margin calls without Risk
Committee consultation. ICC further
revised the Position Concentration
Thresholds subsection to clarify that, if
at any point, either the margin
requirements or concentration charges
grow to be a concern, ICC has the
authority to execute special or intraday
margin calls, and/or to increase the rate
at which the concentration charges
grow.
ICC revised the Stress Testing
subsection of the Back Testing and
Stress Testing section to remove specific
assumptions associated with the various
stress scenarios used in the daily risk
management process. For proprietary
reasons, these specific assumptions are
now included in ICC’s Stress Testing
Framework. ICC also clarified that the
Risk Management Department presents
stress results at the monthly Risk
Committee meetings, as well as
recommendations about next steps and
recommendations to add or retire stress
tests.
ICC made edits to the Default
Treatment section to remove outdated
language stating that ICC seconds
traders eligible to serve on the ICE Clear
Europe Default Management Committee.
ICC removed language regarding the
auctioning of multi-currency portfolios
for stylistic reasons, as the following
sentences provide the information in a
more accessible format.
ICC revised the Cash Settlement
subsection of the Settlement section to
remove outdated language stating that
ICC will evaluate a transition to a
Central bank model for US cash if
available.
ICC made edits to the Market
Investment Risk Management section of
the RMF. Specifically, ICC deleted
redundant language regarding ICC’s
investment policy that can be found in
the ICC Treasury Operations Policies
and Procedures.
ICC enhanced the ICC Clearing
Participant Risk Management
Questionnaire appendix to add more
specific details that better capture the
intent of the questions contained
within.
ICC revised the Overview section of
the Clearing Participant Default
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Management Procedures appendix to
refer more generally to ICC’s default
management procedures, as opposed to
offering specific details provided
elsewhere within the appendix. ICC also
revised the CDS Default Committee
subsection to remove language stating
that the CDS Default Committee
Members are responsible for
determining and adjusting minimum
target prices for auctions. ICC added
language to the Hedging and
Liquidation subsection to note that the
CDS Default Committee is responsible
for assisting ICC with respect to
liquidating and hedging positions with
the Non-Defaulting CPs, in consultation
with the Chief Risk Officer. ICC clarified
the Auction Procedures/Competitive
Bidding section to state that the auction
bidding process will be open for an ICC
specified minute window, as opposed to
a specific 15-minute window.
ICC removed the Collateral Assets
Risk Management Framework Appendix
7 from the RMF and added it as an
appendix to the ICC Treasury
Operations Policies and Procedures.
Accordingly, references within the
Treasury Operations Policies and
Procedures to the RMF were updated.
Additionally, ICC updated its list of
banking relationships contained within
the document. ICC also made
conforming, non-material edits to the
document.
Finally, ICC has created the Risk
Management Model Description
Document, which includes the technical
risk information previously included in
Appendices 3 to 5 of the RMF as well
as information previously included in
explanatory risk documents. Technical
risk information, previously included in
explanatory risk documents, is
incorporated consistently throughout
the new Risk Management Model
Description Document. The inclusion of
such information does not constitute a
substantive change to the RMF, as it
serves to enhance the transparency of
the technical details of the current
implementation described in the
previous RMF. In the Risk Management
Model Description Document, ICC
provides additional technical
information to improve the
understanding and/or replication of the
models. ICC also provides improved
logical connections among all model
components, which should contribute to
developing a general intuition for ICC’s
risk approach.
Material changes to the Risk
Management Model Description
Document will be approved by ICC’s
Board of Managers and submitted, in the
appropriate form to regulators
consistent with other documents
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69263
constituting ICC’s RMF. The Risk
Management Model Description
Document includes a technical
description of ICC’s Initial Margin
methodology (Recovery Rate Sensitivity
Risk Analysis; Loss Given Default Risk
Analysis; Liquidity Risk Analysis; Large
Position Risk Analysis; Jump-To-Default
Risk Analysis; Interest Rate Sensitivity
Risk Analysis; Basic Risk Analysis;
Spread Risk Analysis; Multi-Currency
Portfolio Treatment; and Portfolio Loss
Boundary Condition) and ICC’s
Guaranty Fund methodology (Guaranty
Fund Size Estimation; Guaranty Fund
Requirements and Periodic
Adjustments; and General Wrong Way
Risk and Contagion Stress Tests).
Within the Spread Risk Analysis
section, where ICC previously had listed
explicit risk factors within the RMF, ICC
replaced such explicit risk factors with
the underlying formulas used in
deriving such factors.
Section 17A(b)(3)(F) of the Act 3
requires, among other things, that the
rules of a clearing agency be designed to
promote the prompt and accurate
clearance and settlement of securities
transactions, and to the extent
applicable, derivative agreements,
contracts and transactions and to
comply with the provisions of the Act
and the rules and regulations
thereunder. ICC believes that the
proposed rule changes are consistent
with the requirements of the Act and the
rules and regulations thereunder
applicable to ICC, in particular, to
Section 17(A)(b)(3)(F),4 because ICC
believes that the proposed rule changes
will promote the prompt and accurate
clearance and settlement of securities
transactions, derivatives agreements,
contracts, and transactions. The revised
RMF, the revised Treasury Operations
Policies and Procedures, and the Risk
Management Model Description
Document provide additional clarity
regarding ICC’s RMF. ICC believes the
proposed revisions provide further
clarity in terms of ICC’s risk
management policies and procedures,
through the consolidation of technical
risk documents into one singular
document. ICC believes the revisions to
ICC’s RMF will continue to ensure
proper governance of the RMF. Further,
by revising the RMF and the Treasury
Operations Policies and Procedures, and
establishing the Risk Management
Model Description document, ICC is
complying with a directive from the
CFTC regarding clarity and transparency
of its RMF. As such, the proposed rule
changes are designed to promote the
3 15
U.S.C. 78q–1(b)(3)(F).
4 Id.
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Federal Register / Vol. 80, No. 216 / Monday, November 9, 2015 / Notices
Commission, 100 F Street NE.,
Washington, DC 20549–1090.
prompt and accurate clearance and
settlement of securities transactions,
derivatives agreements, contracts, and
transactions within the meaning of
Section 17A(b)(3)(F) of the Act.5
B. Self-Regulatory Organization's
Statement on Burden on Competition
ICC does not believe the proposed
rule changes would have any impact, or
impose any burden, on competition. ICC
is reorganizing its risk management
policies and not making any substantive
changes to its overall RMF. Therefore,
ICC does not believe the proposed rule
changes impose any burden on
competition that is inappropriate in
furtherance of the purposes of the Act.
C. Self-Regulatory Organization's
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants or Others
Written comments relating to the
proposed rule change have not been
solicited or received. ICC will notify the
Commission of any written comments
received by ICC.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
Within 45 days of the date of
publication of this notice in the Federal
Register or within such longer period
up to 90 days (i) as the Commission may
designate if it finds such longer period
to be appropriate and publishes its
reasons for so finding or (ii) as to which
the self-regulatory organization
consents, the Commission will:
(A) By order approve or disapprove
such proposed rule change, or
(B) institute proceedings to determine
whether the proposed rule change
should be disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
SECURITIES AND EXCHANGE
COMMISSION
All submissions should refer to File
Number SR–ICC–2015–017. This file
number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of such
filings will also be available for
inspection and copying at the principal
office of ICE Clear Credit and on ICE
Clear Credit’s Web site at https://
www.theice.com/clear-credit/regulation.
All comments received will be posted
without change; the Commission does
not edit personal identifying
information from submissions. You
should submit only information that
you wish to make available publicly. All
submissions should refer to File
Number SR–ICC–2015–017 and should
be submitted on or before November 30,
20155.
[Release No. 34–76330; File No. SR–EDGA–
2015–41]
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.6
Brent J. Fields,
Secretary.
[FR Doc. 2015–28402 Filed 11–6–15; 8:45 am]
BILLING CODE 8011–01–P
srobinson on DSK5SPTVN1PROD with NOTICES
• 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–
ICC–2015–017 on the subject line.
Paper Comments
VerDate Sep<11>2014
19:52 Nov 06, 2015
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange filed a proposal to
restructure and amend Rules 3.22, Proxy
Voting, and 13.3, Forwarding or [sic]
Proxy and other Issuer Materials, to
conform to the rules of BATS Exchange,
Inc. (‘‘BZX’’) and BATS Y-Exchange,
Inc. (‘‘BYX’’).5
The text of the proposed rule change
is available at the Exchange’s Web site
at www.batstrading.com, at the
principal office of the Exchange, and at
the Commission’s Public Reference
Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 15 U.S.C. 78s(b)(3)(A).
4 17 CFR 240.19b–4(f)(6)(iii).
5 See BYX and BZX Rule 13.3.
2 17
6 17
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Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (the
‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that on October
23, 2015, EDGA Exchange, Inc. (the
‘‘Exchange’’ or ‘‘EDGA’’) filed with the
Securities and Exchange Commission
(‘‘Commission’’) the proposed rule
change as described in Items I and II
below, which Items have been prepared
by the Exchange. The Exchange has
designated this proposal as a ‘‘non–
controversial’’ proposed rule change
pursuant to Section 19(b)(3)(A) of the
Act 3 and Rule 19b–4(f)(6)(iii)
thereunder,4 which renders it effective
upon filing with the Commission. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
1 15
• Send paper comments in triplicate
to Secretary, Securities and Exchange
U.S.C. 78q–1(b)(3)(F).
November 3, 2015.
In its filing with the Commission, the
Exchange included statements
concerning the purpose of and basis for
the proposed rule change and discussed
any comments it received on the
proposed rule change. The text of these
statements may be examined at the
places specified in Item IV below. The
Electronic Comments
5 15
Self-Regulatory Organizations; EDGA
Exchange, Inc.; Notice of Filing and
Immediate Effectiveness of a Proposed
Rule Change To Amend Rules 3.22,
Proxy Voting, and 13.3, Forwarding of
Proxy and Other Issuer Materials
PO 00000
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Agencies
[Federal Register Volume 80, Number 216 (Monday, November 9, 2015)]
[Notices]
[Pages 69261-69264]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-28402]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-76331; File No. SR-ICC-2015-017]
Self-Regulatory Organizations; ICE Clear Credit LLC; Notice of
Filing of Proposed Rule Change To Revise the ICC Risk Management
Framework and ICC Treasury Operations Policies and Procedures, and
Adopt the ICC Risk Management Model Description Document
November 3, 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 20, 2015, ICE Clear Credit LLC (``ICC'') filed with the
Securities and Exchange Commission (``Commission'') the proposed rule
change as described in Items I, II, and III below, which Items have
been prepared primarily by ICC. The Commission is publishing this
notice to solicit comments on the proposed rule change from interested
persons.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
---------------------------------------------------------------------------
I. Self-Regulatory Organization's Statement of the Terms of Substance
of the Proposed Rule Change
ICC proposes reorganizing the ICC Risk Management Framework
(``RMF'') in response to a recommendation from the Commodity Futures
Trading Commission (``CFTC'') regarding improvements related to the
governance of ICC's risk management documentation. Specifically, ICC
proposes organizational and clarifying edits to the RMF and the
Treasury Operations Policies and Procedures, and proposes adopting a
new Risk Management Model Description Document. These revisions do not
require any changes to the ICC Clearing Rules (``Rules'').
Additionally, the edits are not substantive and do not affect the
nature of ICC's risk management program.
II. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
In its filing with the Commission, ICC included statements
concerning the purpose of and basis for the proposed rule change and
discussed any comments it received on the proposed rule change. The
text of these statements may be examined at the places specified in
Item IV below. ICC has prepared summaries, set forth in sections A, B
and C below, of the most significant aspects of these statements.
A. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
ICC proposes reorganizing the ICC RMF in response to a CFTC
recommendation regarding improvements related to the governance of
ICC's risk management documentation. Specifically, ICC proposes
organizational and clarifying edits to the RMF and the Treasury
Operations Policies and Procedures, and proposes adopting a new Risk
Management Model Description Document. ICC believes such revisions will
facilitate the prompt and accurate clearance and settlement of
securities transactions and derivative agreements, contracts, and
transactions for which it is responsible. The proposed revisions are
described in detail as follows.
ICC moved the Collateral Assets Risk Management Framework appendix
from the RMF to the Treasury Operations Policies and Procedures.
Accordingly, references throughout the RMF to the Collateral Assets
Risk Management Framework appendix were updated to refer instead to the
Treasury Operations Policies and Procedures. ICC moved appendices
containing technical risk management information (formerly, RMF
Appendices 3-5) to the new ICC Risk Management Model Description
Document. Accordingly, references throughout the RMF to these
appendices were updated to refer to the Risk Management Model
Description Document.
ICC also made general updates and edits throughout the RMF for
clarity and consistency. Such edits include correcting verb tenses,
adopting consistent abbreviations, and adjusting sentence order to
assure logical presentation and word flow, and to use more concise,
succinct language. ICC also made additional clarifying edits, as
described below. The edits are not substantive and do not affect the
nature of ICC's risk management program.
Within the Overview section of the RMF, ICC refined the Business
Overview details to more accurately describe the business operations of
Intercontinental Exchange, Inc. and ICC.
ICC made edits to the Governance and Organization section of the
RMF to more fully describe which topics the Risk Committee is
responsible to advise the Board. The list of documents reviewed by the
Risk Committee on at least an annual basis was revised to include the
ICC Risk Management Model Description Document, the ICC Treasury
Operations Policies and Procedures, and the ICC Liquidity Risk
Management Framework. The Risk Working Group (``RWG'') description was
updated to note that the group consists of risk personnel from ICC
Clearing Participants (``CPs''), and to clarify that the RWG is
responsible for reviewing ICC's risk philosophy and recommending
changes to ICC's RMF. The validation function of the risk philosophy
and tolerance was removed from the list of RWG responsibilities, as
such functions are the ultimate responsibility of the Board. The
Advisory Committee description was updated to note that the committee
is comprised of representatives of up to twelve clients/customers of
ICC CPs (currently there are twelve client/customer members). The CDS
Default Committee description was updated to note that the committee is
comprised of representatives from ICC CPs on a rotating basis and to
remove reference to a duty to provide feedback on ICC's RMF and
parameters because the CDS Default Committee is only convened upon the
declaration of a default. The committee description was enhanced to
note that, as the CDS Default Committee assists ICC in determining and
managing Minimum Target Prices for auctioned portfolios related to a
default, the committee oversees necessary auction(s) as well as the
process to re-establish a matched book. The Risk Management
Organization section was updated to remove outdated language stating
that the Risk Management Department conducts an annual review of ICC's
Risk Management Framework Policy Statement and submits proposed changes
to the RWG, Risk Committee, and Board. Further, the section was updated
to remove reference to the Risk Management Department being responsible
for ICC's intellectual capital and personnel, while creating,
implementing and maintaining ICC's risk management policies.
ICC made edits to the Product Summary section of the RMF. ICC
clarified language to refer to Index CDS Instruments (as opposed to
Index
[[Page 69262]]
Products), Single Name CDS Instruments (as opposed to Single Name CDS),
and reference entities (as opposed to companies). The Index CDS
instruments section was revised to remove reference to the
International Index Company. The Single Name CDS Instruments section
was modified to refine language concerning what constitutes a credit
event. The list of attributes defining a CDS contract was enhanced to
include Maturity, as well as reference Notional Amount, as opposed to
Notional Principal. Reference to the terms of the contracts being
prescribed by the ICC Rules and Participant Agreement was removed. The
Risk Factors, Risk Sub-Factors and Instruments section was revised to
enhance the definition of Risk Sub-Factor to refer to a specific single
name reference obligation seniority and doc clause combination.
ICC made edits to the Systemic Risk Management Approach section of
the RMF, which includes Waterfall Levels 1 through 5. ICC revised
Waterfall Level 1: Membership Criteria to remove reference, within the
Operational Criteria, to employee participation on industry committees
(e.g. ISDA, DTCC, etc.). Furthermore, the ongoing monitoring of
participants section was enhanced to state: (i) Intraday monitoring
includes intraday CDS market levels and potential equity price
movements, as well as news from Bloomberg and other information
sources; and (ii) daily monitoring and analysis includes prior day's
final pays by CP, daily change in Initial Margin (``IM''), margin
deficits, unrealized intraday profits/losses for cleared portfolios,
risk impact of new intraday trades on cleared portfolios, daily end-of-
day (``EOD'') levels, CPs' Guaranty Fund (``GF'') obligations, CPs'
day-over-day change in GF requirements relative to each firms prior day
levels, and CPs' day-over-day change in GF requirements relative to the
total GF balance. ICC has removed from the ongoing monitoring of
participants section review of the following components: Daily prices
and spreads (including missed EOD submissions), daily EOD prices
(including missed prices), prior day's and intraday total IM as a
percentage of CP's or CP's guarantor's capital, collateral pricing
report for missing prices, and collateral deposits no longer in
compliance with ICC's acceptable collateral policy. Such elements are
included in the enhanced daily monitoring and analysis section or have
been deemed no longer to relevant to the monitoring process. Further,
ICC clarified that the Risk Management Department reviews weekly stress
test results for extreme risk event scenarios to ensure sufficient
margin cover under market conditions, as opposed to drastic market
conditions. The Participant Withdrawal subsection was revised to remove
reference to ICC's right of One Time Assessment and instead refer more
generally to ICC's power of assessment.
ICC revised the Waterfall Level 2: Initial Margin description to
clarify that ICC's IM requirements consist of a set of individual
components that account for various risks and that the methodology
includes consideration of hypothetical scenarios for those components.
ICC added language to the Spread Response requirements section to note
that the hypothetical prices used in calculating the instrument spread
response risk IM requirement reflect the time-to-maturity horizon
reduced by one day. ICC revised the distributions and related
parameters subsection to refer to the more specific feature Mean
Absolute Deviation (``MAD'') as opposed to the more general term
``scale.'' ICC removed reference to a set EWMA decay factor, as the
factor is dynamic and subject to review and changes by the Risk
Department in consultation with the Risk Committee. ICC also removed
outdated language regarding the initial setting of Auto Regressive
process for first order parameters.
ICC revised the description of the considered scenarios to provide
a mathematical description of how the considered scenarios are
constructed based on statistical analysis of historical time series.
The term structure scenario construction is now clearly defined in
terms of 99% Value-at-Risk equivalent risk measures for different
tenors and the cross-tenor correlation structure is estimated from time
series analysis. ICC revised the term ``contracting'' to ``tightening''
in the context of spread behavior to provide conformity to more
commonly used credit market terminology.
Within the Recovery Rate (``RR'') Sensitivity Requirements
subsection, ICC clarified that two additional single name-specific
stress-test RRs are considered in determining the requirements.
ICC revised Waterfall Level 3: Mark-to-Market Margin description.
Specifically, ICC revised the methodology section to remove specific
calculations regarding the methodology and instead refer to the ICC EOD
Price Discovery Policies and Procedures, which contain a more fulsome
methodology description.
ICC revised Waterfall Level 4: Intra-day Risk Monitoring/Special
Margin Call Execution to clarify language describing the calculation of
prices to determine the adequacy of collected IM intraday.
Specifically, as part of the calculation, ICC utilizes bid-offer quotes
which are automatically fed into the ICC risk management intraday
monitoring system.
ICC revised Waterfall Level 5: Guaranty Fund description. The ICC
GF is designed to provide adequate funds to cover losses associated
with the default of the two CPs, as well as any affiliated CPs (i.e.
any other CP that owns, is owned by, or is under common ownership with
such a CP) with the greatest potential uncollateralized losses. ICC
added language to note that the set of all affiliated CPs is considered
as a CP affiliate group. Within the Waterfall Level 5 description, ICC
revised language to reinforce this CP affiliate group concept. Within
the Guaranty Fund Calculation for Clearing Participants subsection, ICC
removed reference to summary concepts of uncollateralized loss given
default, uncollateralized spread response losses, uncollateralized
basis risk losses, and uncollateralized interest rate losses,
previously used in describing the computations of the stress scenario
losses. ICC more precisely defined the factors considered within the GF
calculation and related stress test scenarios as the following:
Occurrence of multiple credit events, uncollateralized loss-given-
default from self-referencing positions, adverse spread scenarios,
adverse index-single-name basis widening, adverse interest rate
scenarios, and anti procyclicality.
ICC added language to the Guaranty Fund Allocation subsection of
the RMF to state that the CP's total uncollateralized GF stress loss is
the difference between the sum of the stress loss given default, GF
stress spread response, GF stress basis risk and interest rate losses
and the sum of the IM idiosyncratic jump-to-default requirements, IM
spread response requirement, IM basis and interest risk requirement.
ICC revised the General Wrong Way Risk and Contagion Measures
subsection to remove technical information that was moved to the Risk
Management Model Description Document.
ICC revised the Position Concentration Limits subsection of the
Risk Limits and Controls section to clarify that ICC's concentration
charge is designed to increase a CP's IM requirement toward the risk of
maximum loss and ultimately, at the extreme, toward the full expected
notional amount of liability of the sold protection or the present
value of the
[[Page 69263]]
amount of coupon payments for bought protection. ICC summarized
language referring to the notional liability of the protection sold or
the full value of coupon payments to refer more generally to loss
associated with the portfolio. ICC revised the Model Time Horizon
subsection to note that the standard risk horizon can be increased by
the ICC Risk Management Department during banking holiday periods to
reflect ICC's limited ability to execute margin calls without Risk
Committee consultation. ICC further revised the Position Concentration
Thresholds subsection to clarify that, if at any point, either the
margin requirements or concentration charges grow to be a concern, ICC
has the authority to execute special or intraday margin calls, and/or
to increase the rate at which the concentration charges grow.
ICC revised the Stress Testing subsection of the Back Testing and
Stress Testing section to remove specific assumptions associated with
the various stress scenarios used in the daily risk management process.
For proprietary reasons, these specific assumptions are now included in
ICC's Stress Testing Framework. ICC also clarified that the Risk
Management Department presents stress results at the monthly Risk
Committee meetings, as well as recommendations about next steps and
recommendations to add or retire stress tests.
ICC made edits to the Default Treatment section to remove outdated
language stating that ICC seconds traders eligible to serve on the ICE
Clear Europe Default Management Committee. ICC removed language
regarding the auctioning of multi-currency portfolios for stylistic
reasons, as the following sentences provide the information in a more
accessible format.
ICC revised the Cash Settlement subsection of the Settlement
section to remove outdated language stating that ICC will evaluate a
transition to a Central bank model for US cash if available.
ICC made edits to the Market Investment Risk Management section of
the RMF. Specifically, ICC deleted redundant language regarding ICC's
investment policy that can be found in the ICC Treasury Operations
Policies and Procedures.
ICC enhanced the ICC Clearing Participant Risk Management
Questionnaire appendix to add more specific details that better capture
the intent of the questions contained within.
ICC revised the Overview section of the Clearing Participant
Default Management Procedures appendix to refer more generally to ICC's
default management procedures, as opposed to offering specific details
provided elsewhere within the appendix. ICC also revised the CDS
Default Committee subsection to remove language stating that the CDS
Default Committee Members are responsible for determining and adjusting
minimum target prices for auctions. ICC added language to the Hedging
and Liquidation subsection to note that the CDS Default Committee is
responsible for assisting ICC with respect to liquidating and hedging
positions with the Non-Defaulting CPs, in consultation with the Chief
Risk Officer. ICC clarified the Auction Procedures/Competitive Bidding
section to state that the auction bidding process will be open for an
ICC specified minute window, as opposed to a specific 15-minute window.
ICC removed the Collateral Assets Risk Management Framework
Appendix 7 from the RMF and added it as an appendix to the ICC Treasury
Operations Policies and Procedures. Accordingly, references within the
Treasury Operations Policies and Procedures to the RMF were updated.
Additionally, ICC updated its list of banking relationships contained
within the document. ICC also made conforming, non-material edits to
the document.
Finally, ICC has created the Risk Management Model Description
Document, which includes the technical risk information previously
included in Appendices 3 to 5 of the RMF as well as information
previously included in explanatory risk documents. Technical risk
information, previously included in explanatory risk documents, is
incorporated consistently throughout the new Risk Management Model
Description Document. The inclusion of such information does not
constitute a substantive change to the RMF, as it serves to enhance the
transparency of the technical details of the current implementation
described in the previous RMF. In the Risk Management Model Description
Document, ICC provides additional technical information to improve the
understanding and/or replication of the models. ICC also provides
improved logical connections among all model components, which should
contribute to developing a general intuition for ICC's risk approach.
Material changes to the Risk Management Model Description Document
will be approved by ICC's Board of Managers and submitted, in the
appropriate form to regulators consistent with other documents
constituting ICC's RMF. The Risk Management Model Description Document
includes a technical description of ICC's Initial Margin methodology
(Recovery Rate Sensitivity Risk Analysis; Loss Given Default Risk
Analysis; Liquidity Risk Analysis; Large Position Risk Analysis; Jump-
To-Default Risk Analysis; Interest Rate Sensitivity Risk Analysis;
Basic Risk Analysis; Spread Risk Analysis; Multi-Currency Portfolio
Treatment; and Portfolio Loss Boundary Condition) and ICC's Guaranty
Fund methodology (Guaranty Fund Size Estimation; Guaranty Fund
Requirements and Periodic Adjustments; and General Wrong Way Risk and
Contagion Stress Tests). Within the Spread Risk Analysis section, where
ICC previously had listed explicit risk factors within the RMF, ICC
replaced such explicit risk factors with the underlying formulas used
in deriving such factors.
Section 17A(b)(3)(F) of the Act \3\ requires, among other things,
that the rules of a clearing agency be designed to promote the prompt
and accurate clearance and settlement of securities transactions, and
to the extent applicable, derivative agreements, contracts and
transactions and to comply with the provisions of the Act and the rules
and regulations thereunder. ICC believes that the proposed rule changes
are consistent with the requirements of the Act and the rules and
regulations thereunder applicable to ICC, in particular, to Section
17(A)(b)(3)(F),\4\ because ICC believes that the proposed rule changes
will promote the prompt and accurate clearance and settlement of
securities transactions, derivatives agreements, contracts, and
transactions. The revised RMF, the revised Treasury Operations Policies
and Procedures, and the Risk Management Model Description Document
provide additional clarity regarding ICC's RMF. ICC believes the
proposed revisions provide further clarity in terms of ICC's risk
management policies and procedures, through the consolidation of
technical risk documents into one singular document. ICC believes the
revisions to ICC's RMF will continue to ensure proper governance of the
RMF. Further, by revising the RMF and the Treasury Operations Policies
and Procedures, and establishing the Risk Management Model Description
document, ICC is complying with a directive from the CFTC regarding
clarity and transparency of its RMF. As such, the proposed rule changes
are designed to promote the
[[Page 69264]]
prompt and accurate clearance and settlement of securities
transactions, derivatives agreements, contracts, and transactions
within the meaning of Section 17A(b)(3)(F) of the Act.\5\
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\3\ 15 U.S.C. 78q-1(b)(3)(F).
\4\ Id.
\5\ 15 U.S.C. 78q-1(b)(3)(F).
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B. Self-Regulatory Organization's Statement on Burden on Competition
ICC does not believe the proposed rule changes would have any
impact, or impose any burden, on competition. ICC is reorganizing its
risk management policies and not making any substantive changes to its
overall RMF. Therefore, ICC does not believe the proposed rule changes
impose any burden on competition that is inappropriate in furtherance
of the purposes of the Act.
C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants or Others
Written comments relating to the proposed rule change have not been
solicited or received. ICC will notify the Commission of any written
comments received by ICC.
III. Date of Effectiveness of the Proposed Rule Change and Timing for
Commission Action
Within 45 days of the date of publication of this notice in the
Federal Register or within such longer period up to 90 days (i) as the
Commission may designate if it finds such longer period to be
appropriate and publishes its reasons for so finding or (ii) as to
which the self-regulatory organization consents, the Commission will:
(A) By order approve or disapprove such proposed rule change, or
(B) institute proceedings to determine whether the proposed rule
change should be disapproved.
IV. Solicitation of Comments
Interested persons are invited to submit written data, views, and
arguments concerning the foregoing, including whether the proposed rule
change is consistent with the Act. Comments may be submitted by any of
the following methods:
Electronic Comments
Use the Commission's Internet comment form (https://www.sec.gov/rules/sro.shtml); or
Send an email to rule-comments@sec.gov. Please include
File Number SR-ICC-2015-017 on the subject line.
Paper Comments
Send paper comments in triplicate to Secretary, Securities
and Exchange Commission, 100 F Street NE., Washington, DC 20549-1090.
All submissions should refer to File Number SR-ICC-2015-017. This file
number should be included on the subject line if email is used. To help
the Commission process and review your comments more efficiently,
please use only one method. The Commission will post all comments on
the Commission's Internet Web site (https://www.sec.gov/rules/sro.shtml). Copies of the submission, all subsequent amendments, all
written statements with respect to the proposed rule change that are
filed with the Commission, and all written communications relating to
the proposed rule change between the Commission and any person, other
than those that may be withheld from the public in accordance with the
provisions of 5 U.S.C. 552, will be available for Web site viewing and
printing in the Commission's Public Reference Room, 100 F Street NE.,
Washington, DC 20549, on official business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of such filings will also be available
for inspection and copying at the principal office of ICE Clear Credit
and on ICE Clear Credit's Web site at https://www.theice.com/clear-credit/regulation.
All comments received will be posted without change; the Commission
does not edit personal identifying information from submissions. You
should submit only information that you wish to make available
publicly. All submissions should refer to File Number SR-ICC-2015-017
and should be submitted on or before November 30, 20155.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\6\
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\6\ 17 CFR 200.30-3(a)(12).
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Brent J. Fields,
Secretary.
[FR Doc. 2015-28402 Filed 11-6-15; 8:45 am]
BILLING CODE 8011-01-P