Self-Regulatory Organizations; The Options Clearing Corporation; Notice of Filing of an Advance Notice To Modify the Options Clearing Corporation's Margin Methodology by Incorporating Variations in Implied Volatility, 71900-71903 [2015-29227]
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71900
Federal Register / Vol. 80, No. 221 / Tuesday, November 17, 2015 / Notices
banks having the qualifications
prescribed in Section 26(a)(1) of the Act,
and the account will earn a competitive
rate of interest that will also be divided
pro rata among the participating
Regulated Funds and Affiliated Funds
based on the amounts they invest in
such Co-Investment Transaction. None
of the Affiliated Funds, the Advisers,
the other Regulated Funds or any
affiliated person of the Regulated Funds
or Affiliated Funds will receive
additional compensation or
remuneration of any kind as a result of
or in connection with a Co-Investment
Transaction (other than (a) in the case
of the Regulated Funds and the
Affiliated Funds, the pro rata
transaction fees described above and
fees or other compensation described in
condition 2(c)(iii)(C); and (b) in the case
of an Adviser, investment advisory fees
paid in accordance with the agreement
between the Adviser and the Regulated
Fund or Affiliated Fund.
14. If the Holders own in the aggregate
more than 25 percent of the shares of a
Regulated Fund, then the Holders will
vote such shares as directed by an
independent third party (such as the
trustee of a voting trust or a proxy
adviser) when voting on (1) the election
of directors; (2) the removal of one or
more directors; or (3) any matters
requiring approval by the vote of a
majority of the outstanding voting
securities, as defined in section 2(a)(42)
of the Act.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Robert W. Errett,
Deputy Secretary.
Supervision Act’’) 1 and Rule 19b–
4(n)(1)(i) under the Securities Exchange
Act of 1934,2 notice is hereby given that
on October 5, 2015, The Options
Clearing Corporation (‘‘OCC’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’) the
advance notice as described in Items I
and II below, which Items have been
prepared by OCC.3 The Commission is
publishing this notice to solicit
comments on the advance notice from
interested persons.
I. Clearing Agency’s Statement of the
Terms of Substance of the Advance
Notice
This advance notice is filed by The
Options Clearing Corporation (‘‘OCC’’)
in connection with a proposed change
that would modify OCC’s margin
methodology by incorporating
variations in implied volatility for
‘‘shorter tenor’’ options within the
System for Theoretical Analysis and
Numerical Simulations (‘‘STANS’’).
II. Clearing Agency’s Statement of the
Purpose of, and Statutory Basis for, the
Advance Notice
In its filing with the Commission,
OCC included statements concerning
the purpose of and basis for the advance
notice and discussed any comments it
received on the advance notice. The text
of these statements may be examined at
the places specified in Item IV below.
OCC has prepared summaries, set forth
in sections (A) and (B) below, of the
most significant aspects of these
statements.
SECURITIES AND EXCHANGE
COMMISSION
(A) Clearing Agency’s Statement on
Comments on the Advance Notice
Received From Members, Participants or
Others
Written comments were not and are
not intended to be solicited with respect
to the proposed change and none have
been received.
[Release No. 34–76421; File No. SR–OCC–
2015–804]
(B) Advance Notices Filed Pursuant to
Section 806(e) of the Payment, Clearing
and Settlement Supervision Act
Self-Regulatory Organizations; The
Options Clearing Corporation; Notice
of Filing of an Advance Notice To
Modify the Options Clearing
Corporation’s Margin Methodology by
Incorporating Variations in Implied
Volatility
Description of the Proposed Change
The proposed change would modify
OCC’s margin methodology by more
broadly incorporating variations in
implied volatility within STANS. As
explained below, OCC believes that
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BILLING CODE 8011–01–P
1 12
November 10, 2015.
Pursuant to Section 806(e)(1) of Title
VIII of the Dodd-Frank Wall Street
Reform and Consumer Protection Act
entitled the Payment, Clearing, and
Settlement Supervision Act of 2010
(‘‘Payment, Clearing and Settlement
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U.S.C. 5465(e)(1).
CFR 240.19b–4(n)(1)(i).
3 OCC also filed a proposed rule change with the
Commission pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 and Rule 19b–4
thereunder, seeking approval of changes to its rules
necessary to implement the proposal. 15 U.S.C.
78s(b)(1) and 17 CFR 240.19b–4, respectively. See
SR–OCC–2015–016.
2 17
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expanding the use of variations in
implied volatility within STANS for
substantially all 4 option contracts
available to be cleared by OCC that have
a residual tenor 5 of less than three years
(‘‘Shorter Tenor Options’’) would
enhance OCC’s ability to ensure that
option prices and the margin coverage
related to such positions more
appropriately reflect possible future
market value fluctuations and better
protect OCC in the event it must
liquidate the portfolio of a suspended
Clearing Member.
Implied Volatility in STANS Generally
STANS is OCC’s proprietary risk
management system that calculates
Clearing Members’ margin requirements
in accordance with OCC’s Rules.6 The
STANS methodology uses Monte Carlo
simulations to forecast price movement
and correlations in determining a
Clearing Member’s margin requirement.
Under STANS, the daily margin
calculation for each Clearing Member
account is constructed to comply with
Commission Rule 17Ad–22(b)(2),7
ensuring OCC maintains sufficient
financial resources to liquidate a
defaulting member’s positions, without
loss, within the liquidation horizon of
two business days.
The STANS margin requirement for
an account is composed of two primary
components: 8 a base component and a
4 OCC is proposing to exclude: (i) Binary options,
(ii) options on energy futures, and (iii) options on
U.S. Treasury securities. These relatively new
products were introduced as the implied volatility
margin methodology changes were in the process of
being completed by OCC. Subsequent to the
implementation of the revised implied volatility
margin methodology discussed in this filing, OCC
would plan to modify the margin methodology to
accommodate the above new products. In addition,
due to de minimus open interest in those options,
OCC does not believe there is a substantive risk if
the products would be excluded from the implied
volatility margin methodology modifications at this
time.
5 The ‘‘tenor’’ of an option is the amount of time
remaining to its expiration.
6 Pursuant to OCC Rule 601(e)(1), however, OCC
uses the Standard Portfolio Analysis of Risk Margin
Calculation System (‘‘SPAN’’) to calculate initial
margin requirements for segregated futures
accounts. No changes are proposed to OCC’s use of
SPAN because the proposed changes do not
concern futures. See Securities Exchange Act
Release No. 72331 (June 5, 2014), 79 FR 33607 (June
11, 2014) (SR–OCC–2014–13).
7 17 CFR 240.17Ad–22(b)(2). As a registered
clearing agency that performs central counterparty
services, OCC is required to ‘‘use margin
requirements to limit its credit exposures to
participants under normal market conditions and
use risk-based models and parameters to set margin
requirements and review such margin requirements
and the related risk-based models and parameters
at least monthly.’’
8 The two primary components referenced relate
to the risk calculation and are associated with the
99% two-day expected shortfall (i.e., ES) and the
concentration/dependence margin add-on (i.e.,
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stress test component. The base
component is obtained from a risk
measure of the expected margin
shortfall for an account that results
under Monte Carlo price movement
simulations. For the exposures that are
observed regarding the account, the base
component is established as the
estimated average of potential losses
higher than the 99% VaR 9 threshold to
help ensure that OCC continuously
meets the requirements of Rule 17Ad–
22(b)(2).10 In addition, OCC augments
the base component using the stress test
component. The stress test component
is obtained by considering increases in
the expected margin shortfall for an
account that would occur due to (i)
market movements that are especially
large and/or in which certain risk
factors would exhibit perfect or zero
correlations rather than correlations
otherwise estimated using historical
data or (ii) extreme and adverse
idiosyncratic movements for individual
risk factors to which the account is
particularly exposed.
Including variations in implied
volatility within STANS is intended to
ensure that the anticipated cost of
liquidating each Shorter Tenor Option
position in an account recognizes the
possibility that implied volatility could
change during the two business day
liquidation time horizon in STANS and
lead to corresponding changes in the
market prices of the options. Generally
speaking, the implied volatility of an
option is a measure of the expected
future volatility of the value of the
option’s annualized standard deviation
of the price of the underlying security,
index, or future at exercise, which is
reflected in the current option premium
in the market. The volatility is
‘‘implied’’ from the premium for an
option 11 at any given time by
calculating the option premium under
certain assumptions used in the BlackScholes options pricing model and then
determining what value must be added
to the known values for all of the other
variables in the Black-Scholes model to
Add-on Charge). When computing the ES or Addon Charges, STANS computes the theoretical value
of an option for a given simulated underlying price
change using the implied volatility reflected in the
prior day closing price. Under the proposed change,
STANS would use a modeled implied volatility
intended to simulate the estimated change in
implied volatilities given the simulated underlying
price change in STANS.
9 The term ‘‘value at risk’’ or ‘‘VaR’’ refers to a
statistical technique that, generally speaking, is
used in risk management to measure the potential
risk of loss for a given set of assets over a particular
time horizon.
10 17 CFR 240.17Ad–22(b)(2).
11 The premium is the price that the holder of an
option pays and the writer of an option receives for
the rights conveyed by the option.
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equal the premium. In effect, the
implied volatility is responsible for that
portion of the premium that cannot be
explained by the then-current intrinsic
value 12 of the option, discounted to
reflect its time value. OCC currently
incorporates variations in implied
volatility as risk factors for certain
options with residual tenors of at least
three years (‘‘Longer Tenor Options’’).13
Implied Volatility for Shorter Tenor
Options
OCC is proposing certain
modifications to STANS to more
broadly incorporate variations in
implied volatility for Shorter Tenor
Options. Consistent with its approach
for Longer Tenor Options, OCC would
model a volatility surface 14 for Shorter
Tenor Options by incorporating into the
econometric models underlying STANS
certain risk factors regarding a time
series of proportional changes in
implied volatilities for a range of tenors
and absolute deltas. Shorter Tenor
Option volatility points would be
defined by three different tenors and
three different absolute deltas, which
produce nine ‘‘pivot points.’’ In
calculating the implied volatility values
for each pivot point, OCC would use the
same type of series-level pricing data set
to create the nine pivot points that it
does to create the larger number of pivot
points used for Longer Tenor Options,
so that the nine pivot points would be
the result of a consolidation of the entire
series-level dataset into a smaller and
more manageable set of pivot points
before modeling the volatility surface.
OCC partnered with an experienced
vendor in this area to study implied
volatility surfaces and to use backtesting of OCC’s margin requirements to
build a model that would be
appropriately sophisticated and operate
conservatively to minimize margin
exceedances. The back-testing results
support that, over a look-back period
from January 2008 to May 2013,15 using
12 Generally speaking, the intrinsic value is the
difference between the price of the underlying and
the exercise price of the option.
13 See Securities Exchange Act Release Nos.
68434 (December 14, 2012), 77 FR 57602 [sic]
(December 19, 2012) (SR–OCC–2012–14); 70709
[sic] (October 18, 2013), 78 FR 63267 [sic] (October
23, 2013) [sic] (SR–OCC–2013–16).
14 The term ‘‘volatility surface’’ refers to a threedimensional graphed surface that represents the
implied volatility for possible tenors of the option
and the implied volatility of the option over those
tenors for the possible levels of ‘‘moneyness’’ of the
option. The term ‘‘moneyness’’ refers to the
relationship between the current market price of the
underlying interest and the exercise price.
15 The look-back period was determined based on
the availability of relevant data at the time of the
back-testing. Relevant data in this case means data
obtained from OCC’s consultants, Finance
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nine pivot points to define the volatility
surface would have resulted in a
comparable number of instances in
which an account containing certain
hypothetical positions would have been
under-margined compared to using a
larger number of pivot points to define
the volatility surface. Therefore,
although OCC could create a more
detailed volatility surface by increasing
the number of pivot points, OCC has
determined that doing so for Shorter
Tenor Options would not be
appropriate. Moreover, due to the
significantly larger volume of Shorter
Tenor Options, OCC also believes that
relying on a greater number of pivot
points could potentially lead to
increases in the time necessary to
compute margin requirements that
would impair OCC’s capacity to make
timely calculations.
Under OCC’s model for Shorter Tenor
Options, the volatility surfaces would be
defined using tenors of one month, three
months, and one year with absolute
deltas, in each case, of 0.25, 0.5, and
0.75. This results in the nine implied
volatility pivot points. Given that
premiums of deep-in-the-money options
(those with absolute deltas closer to 1.0)
and deep-out-of-the-money options
(those with absolute deltas closer to 0)
are insensitive to changes in implied
volatility, in each case notwithstanding
increases or decreases in implied
volatility over the two business day
liquidation time horizon, those higher
and lower absolute deltas have not been
selected as pivot points. OCC believes
that it is appropriate to focus on pivot
points representing at- and near-themoney options because prices for those
options are more sensitive to variations
in implied volatility over the liquidation
time horizon of two business days.
Specifically, for SPX index options, four
factors explain 99% variance of implied
volatility movements: (i) A parallel shift
of the entire surface, (ii) a slope or
skewness with respect to Delta, (iii) a
slope with respect to time to maturity;
and, (iv) a convexity with respect to the
time to maturity. The nine correlated
pivot points, arranged by delta and
tenor, give OCC the flexibility to capture
these factors.
In the proposed approach to
computing margin for Shorter Tenor
Options under STANS, OCC would first
use its econometric models to simulate
implied volatility changes at the nine
pivot points that would correspond to
Concepts. The back-testing was performed by
Finance Concepts using data from their
OptionMetrics Ivy source. The Ivy source maintains
data from prior to 2008, but it is not clear that data
from before the market dislocation in early August
2007 is as relevant to today’s options markets.
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underlying price simulations used by
STANS.16 For each Shorter Tenor
Option in the account of a Clearing
Member, changes in its implied
volatility would then be simulated
according to the corresponding pivot
point and the price of the option would
be computed to determine the amount
of profit or loss in the account under the
particular STANS price simulation.
Additionally, as OCC does today, it
would continue to use simulated closing
prices for the assets underlying options
in the account of a Clearing Member
that are scheduled to expire within the
liquidation time horizon of two business
days to compute the options’ intrinsic
value 17 and use those values to help
calculate the profit or loss in the
account.18
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Effects of the Proposed Change and
Implementation
OCC believes that the proposed
change would enhance OCC’s ability to
ensure that in determining margin
requirements STANS appropriately
takes into account normal market
conditions that OCC may encounter in
the event that, pursuant to OCC Rule
1102, it suspends a defaulted Clearing
Member and liquidates its accounts.19
Accordingly, the change would promote
OCC’s ability to ensure that margin
assets are sufficient to liquidate the
accounts of a defaulted Clearing
Member without incurring a loss.
OCC estimates that Clearing Member
accounts generally would experience
increased margin requirements as
compared to those calculated for the
same options positions in an account
today. OCC estimates the proposed
change would most significantly affect
customer accounts and least
significantly affect firm accounts, with
the effect on Market Maker accounts
falling in between.
OCC expects customer accounts to
experience the largest margin increases
because positions considered under
STANS for customer accounts typically
consist of more short than long options
positions, and therefore reflect a greater
16 STANS relies on 10,000 price simulation
scenarios that are based generally on a historical
data period of 500 business days, which is updated
monthly to keep model results from becoming stale.
17 Generally speaking, the intrinsic value is the
difference between the price of the underlying and
the exercise price of the option.
18 For such Shorter Tenor Options that are
scheduled to expire on the open of the market
rather than the close, OCC would use the relevant
opening price for the underlying assets.
19 Under authority in OCC Rules 1104 and 1106,
OCC has authority to promptly liquidate margin
assets and options positions of a suspended
Clearing Member in the most orderly manner
practicable, which might include, but would not be
limited to, a private auction.
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magnitude of direction risk than other
account types. Positions considered
under STANS for customer accounts
typically consist of more short than long
options positions because, to facilitate
Clearing Members’ compliance with
Commission requirements for the
protection of certain customer property
under Rule 15c3–3(b),20 OCC segregates
long option positions in the securities
customers’ account of each Clearing
Member and does not assign them any
value in determining the expected
liquidating value of the account.21
While overall OCC expects an
increase in aggregate margins by about
$1.5 billion (9% of expected shortfall
and stress-test add-on), OCC does
anticipate a decrease in margins in
certain clearing member accounts’
requirements. OCC anticipates that such
a decrease would occur in accounts
with underlying exposure and implied
volatility exposure in the same
direction, such as concentrated call
positions, due to the negative
correlation typically observed between
these two factors. Over the back-testing
period, about 28% of the observations
for accounts on the days studied had
lower margins under the proposed
methodology and the average reduction
was about 2.7%. Parallel results will be
made available to the membership in
the weeks ahead of implementation.
To help Clearing Members prepare for
the proposed change, OCC has provided
Clearing Members with an Information
Memo explaining the proposal,
including the planned timeline for its
implementation,22 and discussed with
certain other clearinghouses the likely
effects of the change on OCC’s crossmargin agreements with them. OCC is
also publishing an Information Memo to
notify Clearing Members of the
submission of this filing to the
20 17
CFR 240.15c3–3(b).
OCC Rule 601(d)(1). Pursuant to OCC Rule
611, however, a Clearing Member, subject to certain
conditions, may instruct OCC to release segregated
long option positions from segregation. Long
positions may be released, for example, if they are
part of a spread position. Once released from
segregation, OCC receives a lien on each
unsegregated long securities option carried in a
customers’ account and therefore OCC permits the
unsegregated long to offset corresponding short
option positions in the account.
22 In addition to the proposal to introduce
variations in implied volatility for Shorter Tenor
Options, OCC is also contemporaneously proposing
an additional change to its margin methodology that
would use liquidity charges to account for certain
costs associated with hedging in which OCC would
engage during a Clearing Member liquidation and
the reasonably expected effect that OCC’s
management of the liquidation would have on
related bid-ask spreads in the marketplace. The
Information Memo explained both of these
proposed changes and their expected effects on
margin requirements.
21 See
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Commission. Subject to all necessary
regulatory approvals regarding the
proposed change, for a period of at least
two months beginning in October 2015,
OCC intends to begin making parallel
margin calculations with and without
the changes in the margin methodology.
The commencement of the calculations
would be announced by an Information
Memo, and OCC would provide the
calculations to Clearing Members each
business day. OCC believes that
Clearing Members will have sufficient
time and data to plan for the potential
increases in their respective margin
requirements. OCC would also provide
at least thirty days prior notice to
Clearing Members before implementing
the change.
Consistency With the Payment, Clearing
and Settlement Supervision Act
OCC believes that the proposed
change regarding the incorporation of
variations in implied volatility within
STANS is consistent with Section
805(b)(1) of the Payment, Clearing and
Settlement Supervision Act 23 because
the proposed procedures would
promote robust risk management by
more robustly computing Clearing
Member margin requirements in order
to ensure that OCC maintains adequate
financial resources in the event of a
Clearing Member default. As described
above, OCC believes that the proposed
change would enhance OCC’s ability to
ensure that margin requirements
determined through STANS
appropriately take into account normal
market conditions that OCC may
encounter in the event that, pursuant to
OCC Rule 1102, it suspends a defaulted
Clearing Member and liquidates its
accounts. As a result, OCC would be
better able to ensure that margin assets
are sufficient to liquidate the accounts
of a defaulted Clearing Member without
incurring a loss and thereby promote
robust risk management.
Anticipated Effect on and Management
of Risk
OCC believes that the proposed
change would reduce OCC’s overall
level of risk because the proposed
change makes it less likely that the
amount of margin OCC collects from
Clearing Members Clearing Fund would
be insufficient should OCC need to use
such margin in connection with a
Clearing Member default. As described
above, OCC is proposing certain
modifications to STANS to more
broadly incorporate variations in
implied volatility for Shorter Tenor
Options. Such modifications would
23 12
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result in OCC being able to better ensure
that margin requirements computed by
STANS because [sic] STANS would
appropriately take into account normal
market conditions that OCC may
encounter in the event that, pursuant to
OCC Rule 1102, it suspends a defaulted
Clearing Member and liquidates its
accounts. As a result, the proposed
change would make it less likely that
OCC would need to use additional
financial resources, such as its clearing
fund, in order to appropriately manage
a clearing member default. Moreover,
the proposed change is intended to
measure the exposure associated with
changes in option implied volatilities,
thus mitigating credit risk presented by
clearing members. Accordingly, OCC
believes that the proposed changes
would reduce risks to OCC and its
participants. Moreover, and for the same
reasons, the proposed change will
facilitate OCC’s ability to manage risk.
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III. Date of Effectiveness of the Advance
Notice and Timing for Commission
Action
The designated clearing agency may
implement this change if it has not
received an objection to the proposed
change within 60 days of the later of (i)
the date that the Commission receives
the notice of proposed change, or (ii) the
date the Commission receives any
further information it requests for
consideration of the notice. The
designated clearing agency shall not
implement this change if the
Commission has an objection.
The Commission may, during the 60day review period, extend the review
period for an additional 60 days for
proposed changes that raise novel or
complex issues, subject to the
Commission providing the designated
clearing agency with prompt written
notice of the extension. The designated
clearing agency may implement a
change in less than 60 days from the
date of receipt of the notice of proposed
change by the Commission, or the date
the Commission receives any further
information it requested, if the
Commission notifies the designated
clearing agency in writing that it does
not object to the proposed change and
authorizes the designated clearing
agency to implement the change on an
earlier date, subject to any conditions
imposed by the Commission.
The designated clearing agency shall
post notice on its Web site of proposed
changes that are implemented.
The proposal shall not take effect
until all regulatory actions required
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with respect to the proposal are
completed.24
be submitted on or before December 2,
2015.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views and
arguments concerning the foregoing.
Comments may be submitted by any of
the following methods:
By the Commission.
Robert W. Errett,
Deputy Secretary.
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–
OCC–2015–804 on the subject line.
SECURITIES AND EXCHANGE
COMMISSION
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–OCC–2015–804. 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 advance notice that
are filed with the Commission, and all
written communications relating to the
advance notice 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 OCC and on OCC’s Web site at
https://www.optionsclearing.com/
components/docs/legal/rules_and_
bylaws/sr_occ_2015_804.pdf. 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–OCC–2015–804 and should
24 OCC also filed a proposed rule change with the
Commission pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 and Rule 19b–4
thereunder, seeking approval of changes to its rules
necessary to implement the proposal. See supra
note 3.
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[FR Doc. 2015–29227 Filed 11–16–15; 8:45 am]
BILLING CODE 8011–01–P
[Release No. 34–76414; File No. SR–Phlx–
2015–92]
Self-Regulatory Organizations;
NASDAQ OMX PHLX LLC; Notice of
Filing and Immediate Effectiveness of
Proposed Rule Change To Establish
the Securities Trader and Securities
Trader Principal Registration
Categories and To Retire Other
Registration Categories
November 10, 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 November
4, 2015, NASDAQ OMX PHLX LLC
(‘‘Phlx’’ 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 the Exchange. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to establish
the Securities Trader and Securities
Trader Principal registration categories
and to retire the Proprietary Trader and
Proprietary Trader Principal registration
categories. Phlx will announce the
effective date of the proposed rule
change in a Trader Alert. The Exchange
is also amending its rules to establish
the Series 57 examination as the
appropriate qualification examination
for Securities Traders and deleting the
rule referring to the S501 continuing
education program currently applicable
to Proprietary Traders.
The text of the proposed rule
change is available on the Exchange’s
Web site at https://
nasdaqomxphlx.cchwallstreet.com/, at
the principal office of the Exchange, and
at the Commission’s Public Reference
Room.
1 15
2 17
U.S.C. 78s(b)(1).
CFR 240.19b–4.
E:\FR\FM\17NON1.SGM
17NON1
Agencies
[Federal Register Volume 80, Number 221 (Tuesday, November 17, 2015)]
[Notices]
[Pages 71900-71903]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-29227]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-76421; File No. SR-OCC-2015-804]
Self-Regulatory Organizations; The Options Clearing Corporation;
Notice of Filing of an Advance Notice To Modify the Options Clearing
Corporation's Margin Methodology by Incorporating Variations in Implied
Volatility
November 10, 2015.
Pursuant to Section 806(e)(1) of Title VIII of the Dodd-Frank Wall
Street Reform and Consumer Protection Act entitled the Payment,
Clearing, and Settlement Supervision Act of 2010 (``Payment, Clearing
and Settlement Supervision Act'') \1\ and Rule 19b-4(n)(1)(i) under the
Securities Exchange Act of 1934,\2\ notice is hereby given that on
October 5, 2015, The Options Clearing Corporation (``OCC'') filed with
the Securities and Exchange Commission (``Commission'') the advance
notice as described in Items I and II below, which Items have been
prepared by OCC.\3\ The Commission is publishing this notice to solicit
comments on the advance notice from interested persons.
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\1\ 12 U.S.C. 5465(e)(1).
\2\ 17 CFR 240.19b-4(n)(1)(i).
\3\ OCC also filed a proposed rule change with the Commission
pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
and Rule 19b-4 thereunder, seeking approval of changes to its rules
necessary to implement the proposal. 15 U.S.C. 78s(b)(1) and 17 CFR
240.19b-4, respectively. See SR-OCC-2015-016.
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I. Clearing Agency's Statement of the Terms of Substance of the Advance
Notice
This advance notice is filed by The Options Clearing Corporation
(``OCC'') in connection with a proposed change that would modify OCC's
margin methodology by incorporating variations in implied volatility
for ``shorter tenor'' options within the System for Theoretical
Analysis and Numerical Simulations (``STANS'').
II. Clearing Agency's Statement of the Purpose of, and Statutory Basis
for, the Advance Notice
In its filing with the Commission, OCC included statements
concerning the purpose of and basis for the advance notice and
discussed any comments it received on the advance notice. The text of
these statements may be examined at the places specified in Item IV
below. OCC has prepared summaries, set forth in sections (A) and (B)
below, of the most significant aspects of these statements.
(A) Clearing Agency's Statement on Comments on the Advance Notice
Received From Members, Participants or Others
Written comments were not and are not intended to be solicited with
respect to the proposed change and none have been received.
(B) Advance Notices Filed Pursuant to Section 806(e) of the Payment,
Clearing and Settlement Supervision Act
Description of the Proposed Change
The proposed change would modify OCC's margin methodology by more
broadly incorporating variations in implied volatility within STANS. As
explained below, OCC believes that expanding the use of variations in
implied volatility within STANS for substantially all \4\ option
contracts available to be cleared by OCC that have a residual tenor \5\
of less than three years (``Shorter Tenor Options'') would enhance
OCC's ability to ensure that option prices and the margin coverage
related to such positions more appropriately reflect possible future
market value fluctuations and better protect OCC in the event it must
liquidate the portfolio of a suspended Clearing Member.
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\4\ OCC is proposing to exclude: (i) Binary options, (ii)
options on energy futures, and (iii) options on U.S. Treasury
securities. These relatively new products were introduced as the
implied volatility margin methodology changes were in the process of
being completed by OCC. Subsequent to the implementation of the
revised implied volatility margin methodology discussed in this
filing, OCC would plan to modify the margin methodology to
accommodate the above new products. In addition, due to de minimus
open interest in those options, OCC does not believe there is a
substantive risk if the products would be excluded from the implied
volatility margin methodology modifications at this time.
\5\ The ``tenor'' of an option is the amount of time remaining
to its expiration.
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Implied Volatility in STANS Generally
STANS is OCC's proprietary risk management system that calculates
Clearing Members' margin requirements in accordance with OCC's
Rules.\6\ The STANS methodology uses Monte Carlo simulations to
forecast price movement and correlations in determining a Clearing
Member's margin requirement. Under STANS, the daily margin calculation
for each Clearing Member account is constructed to comply with
Commission Rule 17Ad-22(b)(2),\7\ ensuring OCC maintains sufficient
financial resources to liquidate a defaulting member's positions,
without loss, within the liquidation horizon of two business days.
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\6\ Pursuant to OCC Rule 601(e)(1), however, OCC uses the
Standard Portfolio Analysis of Risk Margin Calculation System
(``SPAN'') to calculate initial margin requirements for segregated
futures accounts. No changes are proposed to OCC's use of SPAN
because the proposed changes do not concern futures. See Securities
Exchange Act Release No. 72331 (June 5, 2014), 79 FR 33607 (June 11,
2014) (SR-OCC-2014-13).
\7\ 17 CFR 240.17Ad-22(b)(2). As a registered clearing agency
that performs central counterparty services, OCC is required to
``use margin requirements to limit its credit exposures to
participants under normal market conditions and use risk-based
models and parameters to set margin requirements and review such
margin requirements and the related risk-based models and parameters
at least monthly.''
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The STANS margin requirement for an account is composed of two
primary components: \8\ a base component and a
[[Page 71901]]
stress test component. The base component is obtained from a risk
measure of the expected margin shortfall for an account that results
under Monte Carlo price movement simulations. For the exposures that
are observed regarding the account, the base component is established
as the estimated average of potential losses higher than the 99% VaR
\9\ threshold to help ensure that OCC continuously meets the
requirements of Rule 17Ad-22(b)(2).\10\ In addition, OCC augments the
base component using the stress test component. The stress test
component is obtained by considering increases in the expected margin
shortfall for an account that would occur due to (i) market movements
that are especially large and/or in which certain risk factors would
exhibit perfect or zero correlations rather than correlations otherwise
estimated using historical data or (ii) extreme and adverse
idiosyncratic movements for individual risk factors to which the
account is particularly exposed.
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\8\ The two primary components referenced relate to the risk
calculation and are associated with the 99% two-day expected
shortfall (i.e., ES) and the concentration/dependence margin add-on
(i.e., Add-on Charge). When computing the ES or Add-on Charges,
STANS computes the theoretical value of an option for a given
simulated underlying price change using the implied volatility
reflected in the prior day closing price. Under the proposed change,
STANS would use a modeled implied volatility intended to simulate
the estimated change in implied volatilities given the simulated
underlying price change in STANS.
\9\ The term ``value at risk'' or ``VaR'' refers to a
statistical technique that, generally speaking, is used in risk
management to measure the potential risk of loss for a given set of
assets over a particular time horizon.
\10\ 17 CFR 240.17Ad-22(b)(2).
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Including variations in implied volatility within STANS is intended
to ensure that the anticipated cost of liquidating each Shorter Tenor
Option position in an account recognizes the possibility that implied
volatility could change during the two business day liquidation time
horizon in STANS and lead to corresponding changes in the market prices
of the options. Generally speaking, the implied volatility of an option
is a measure of the expected future volatility of the value of the
option's annualized standard deviation of the price of the underlying
security, index, or future at exercise, which is reflected in the
current option premium in the market. The volatility is ``implied''
from the premium for an option \11\ at any given time by calculating
the option premium under certain assumptions used in the Black-Scholes
options pricing model and then determining what value must be added to
the known values for all of the other variables in the Black-Scholes
model to equal the premium. In effect, the implied volatility is
responsible for that portion of the premium that cannot be explained by
the then-current intrinsic value \12\ of the option, discounted to
reflect its time value. OCC currently incorporates variations in
implied volatility as risk factors for certain options with residual
tenors of at least three years (``Longer Tenor Options'').\13\
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\11\ The premium is the price that the holder of an option pays
and the writer of an option receives for the rights conveyed by the
option.
\12\ Generally speaking, the intrinsic value is the difference
between the price of the underlying and the exercise price of the
option.
\13\ See Securities Exchange Act Release Nos. 68434 (December
14, 2012), 77 FR 57602 [sic] (December 19, 2012) (SR-OCC-2012-14);
70709 [sic] (October 18, 2013), 78 FR 63267 [sic] (October 23, 2013)
[sic] (SR-OCC-2013-16).
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Implied Volatility for Shorter Tenor Options
OCC is proposing certain modifications to STANS to more broadly
incorporate variations in implied volatility for Shorter Tenor Options.
Consistent with its approach for Longer Tenor Options, OCC would model
a volatility surface \14\ for Shorter Tenor Options by incorporating
into the econometric models underlying STANS certain risk factors
regarding a time series of proportional changes in implied volatilities
for a range of tenors and absolute deltas. Shorter Tenor Option
volatility points would be defined by three different tenors and three
different absolute deltas, which produce nine ``pivot points.'' In
calculating the implied volatility values for each pivot point, OCC
would use the same type of series-level pricing data set to create the
nine pivot points that it does to create the larger number of pivot
points used for Longer Tenor Options, so that the nine pivot points
would be the result of a consolidation of the entire series-level
dataset into a smaller and more manageable set of pivot points before
modeling the volatility surface.
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\14\ The term ``volatility surface'' refers to a three-
dimensional graphed surface that represents the implied volatility
for possible tenors of the option and the implied volatility of the
option over those tenors for the possible levels of ``moneyness'' of
the option. The term ``moneyness'' refers to the relationship
between the current market price of the underlying interest and the
exercise price.
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OCC partnered with an experienced vendor in this area to study
implied volatility surfaces and to use back-testing of OCC's margin
requirements to build a model that would be appropriately sophisticated
and operate conservatively to minimize margin exceedances. The back-
testing results support that, over a look-back period from January 2008
to May 2013,\15\ using nine pivot points to define the volatility
surface would have resulted in a comparable number of instances in
which an account containing certain hypothetical positions would have
been under-margined compared to using a larger number of pivot points
to define the volatility surface. Therefore, although OCC could create
a more detailed volatility surface by increasing the number of pivot
points, OCC has determined that doing so for Shorter Tenor Options
would not be appropriate. Moreover, due to the significantly larger
volume of Shorter Tenor Options, OCC also believes that relying on a
greater number of pivot points could potentially lead to increases in
the time necessary to compute margin requirements that would impair
OCC's capacity to make timely calculations.
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\15\ The look-back period was determined based on the
availability of relevant data at the time of the back-testing.
Relevant data in this case means data obtained from OCC's
consultants, Finance Concepts. The back-testing was performed by
Finance Concepts using data from their OptionMetrics Ivy source. The
Ivy source maintains data from prior to 2008, but it is not clear
that data from before the market dislocation in early August 2007 is
as relevant to today's options markets.
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Under OCC's model for Shorter Tenor Options, the volatility
surfaces would be defined using tenors of one month, three months, and
one year with absolute deltas, in each case, of 0.25, 0.5, and 0.75.
This results in the nine implied volatility pivot points. Given that
premiums of deep-in-the-money options (those with absolute deltas
closer to 1.0) and deep-out-of-the-money options (those with absolute
deltas closer to 0) are insensitive to changes in implied volatility,
in each case notwithstanding increases or decreases in implied
volatility over the two business day liquidation time horizon, those
higher and lower absolute deltas have not been selected as pivot
points. OCC believes that it is appropriate to focus on pivot points
representing at- and near-the-money options because prices for those
options are more sensitive to variations in implied volatility over the
liquidation time horizon of two business days. Specifically, for SPX
index options, four factors explain 99% variance of implied volatility
movements: (i) A parallel shift of the entire surface, (ii) a slope or
skewness with respect to Delta, (iii) a slope with respect to time to
maturity; and, (iv) a convexity with respect to the time to maturity.
The nine correlated pivot points, arranged by delta and tenor, give OCC
the flexibility to capture these factors.
In the proposed approach to computing margin for Shorter Tenor
Options under STANS, OCC would first use its econometric models to
simulate implied volatility changes at the nine pivot points that would
correspond to
[[Page 71902]]
underlying price simulations used by STANS.\16\ For each Shorter Tenor
Option in the account of a Clearing Member, changes in its implied
volatility would then be simulated according to the corresponding pivot
point and the price of the option would be computed to determine the
amount of profit or loss in the account under the particular STANS
price simulation. Additionally, as OCC does today, it would continue to
use simulated closing prices for the assets underlying options in the
account of a Clearing Member that are scheduled to expire within the
liquidation time horizon of two business days to compute the options'
intrinsic value \17\ and use those values to help calculate the profit
or loss in the account.\18\
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\16\ STANS relies on 10,000 price simulation scenarios that are
based generally on a historical data period of 500 business days,
which is updated monthly to keep model results from becoming stale.
\17\ Generally speaking, the intrinsic value is the difference
between the price of the underlying and the exercise price of the
option.
\18\ For such Shorter Tenor Options that are scheduled to expire
on the open of the market rather than the close, OCC would use the
relevant opening price for the underlying assets.
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Effects of the Proposed Change and Implementation
OCC believes that the proposed change would enhance OCC's ability
to ensure that in determining margin requirements STANS appropriately
takes into account normal market conditions that OCC may encounter in
the event that, pursuant to OCC Rule 1102, it suspends a defaulted
Clearing Member and liquidates its accounts.\19\ Accordingly, the
change would promote OCC's ability to ensure that margin assets are
sufficient to liquidate the accounts of a defaulted Clearing Member
without incurring a loss.
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\19\ Under authority in OCC Rules 1104 and 1106, OCC has
authority to promptly liquidate margin assets and options positions
of a suspended Clearing Member in the most orderly manner
practicable, which might include, but would not be limited to, a
private auction.
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OCC estimates that Clearing Member accounts generally would
experience increased margin requirements as compared to those
calculated for the same options positions in an account today. OCC
estimates the proposed change would most significantly affect customer
accounts and least significantly affect firm accounts, with the effect
on Market Maker accounts falling in between.
OCC expects customer accounts to experience the largest margin
increases because positions considered under STANS for customer
accounts typically consist of more short than long options positions,
and therefore reflect a greater magnitude of direction risk than other
account types. Positions considered under STANS for customer accounts
typically consist of more short than long options positions because, to
facilitate Clearing Members' compliance with Commission requirements
for the protection of certain customer property under Rule 15c3-
3(b),\20\ OCC segregates long option positions in the securities
customers' account of each Clearing Member and does not assign them any
value in determining the expected liquidating value of the account.\21\
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\20\ 17 CFR 240.15c3-3(b).
\21\ See OCC Rule 601(d)(1). Pursuant to OCC Rule 611, however,
a Clearing Member, subject to certain conditions, may instruct OCC
to release segregated long option positions from segregation. Long
positions may be released, for example, if they are part of a spread
position. Once released from segregation, OCC receives a lien on
each unsegregated long securities option carried in a customers'
account and therefore OCC permits the unsegregated long to offset
corresponding short option positions in the account.
---------------------------------------------------------------------------
While overall OCC expects an increase in aggregate margins by about
$1.5 billion (9% of expected shortfall and stress-test add-on), OCC
does anticipate a decrease in margins in certain clearing member
accounts' requirements. OCC anticipates that such a decrease would
occur in accounts with underlying exposure and implied volatility
exposure in the same direction, such as concentrated call positions,
due to the negative correlation typically observed between these two
factors. Over the back-testing period, about 28% of the observations
for accounts on the days studied had lower margins under the proposed
methodology and the average reduction was about 2.7%. Parallel results
will be made available to the membership in the weeks ahead of
implementation.
To help Clearing Members prepare for the proposed change, OCC has
provided Clearing Members with an Information Memo explaining the
proposal, including the planned timeline for its implementation,\22\
and discussed with certain other clearinghouses the likely effects of
the change on OCC's cross-margin agreements with them. OCC is also
publishing an Information Memo to notify Clearing Members of the
submission of this filing to the Commission. Subject to all necessary
regulatory approvals regarding the proposed change, for a period of at
least two months beginning in October 2015, OCC intends to begin making
parallel margin calculations with and without the changes in the margin
methodology. The commencement of the calculations would be announced by
an Information Memo, and OCC would provide the calculations to Clearing
Members each business day. OCC believes that Clearing Members will have
sufficient time and data to plan for the potential increases in their
respective margin requirements. OCC would also provide at least thirty
days prior notice to Clearing Members before implementing the change.
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\22\ In addition to the proposal to introduce variations in
implied volatility for Shorter Tenor Options, OCC is also
contemporaneously proposing an additional change to its margin
methodology that would use liquidity charges to account for certain
costs associated with hedging in which OCC would engage during a
Clearing Member liquidation and the reasonably expected effect that
OCC's management of the liquidation would have on related bid-ask
spreads in the marketplace. The Information Memo explained both of
these proposed changes and their expected effects on margin
requirements.
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Consistency With the Payment, Clearing and Settlement Supervision Act
OCC believes that the proposed change regarding the incorporation
of variations in implied volatility within STANS is consistent with
Section 805(b)(1) of the Payment, Clearing and Settlement Supervision
Act \23\ because the proposed procedures would promote robust risk
management by more robustly computing Clearing Member margin
requirements in order to ensure that OCC maintains adequate financial
resources in the event of a Clearing Member default. As described
above, OCC believes that the proposed change would enhance OCC's
ability to ensure that margin requirements determined through STANS
appropriately take into account normal market conditions that OCC may
encounter in the event that, pursuant to OCC Rule 1102, it suspends a
defaulted Clearing Member and liquidates its accounts. As a result, OCC
would be better able to ensure that margin assets are sufficient to
liquidate the accounts of a defaulted Clearing Member without incurring
a loss and thereby promote robust risk management.
---------------------------------------------------------------------------
\23\ 12 U.S.C. 5464(b)(1).
---------------------------------------------------------------------------
Anticipated Effect on and Management of Risk
OCC believes that the proposed change would reduce OCC's overall
level of risk because the proposed change makes it less likely that the
amount of margin OCC collects from Clearing Members Clearing Fund would
be insufficient should OCC need to use such margin in connection with a
Clearing Member default. As described above, OCC is proposing certain
modifications to STANS to more broadly incorporate variations in
implied volatility for Shorter Tenor Options. Such modifications would
[[Page 71903]]
result in OCC being able to better ensure that margin requirements
computed by STANS because [sic] STANS would appropriately take into
account normal market conditions that OCC may encounter in the event
that, pursuant to OCC Rule 1102, it suspends a defaulted Clearing
Member and liquidates its accounts. As a result, the proposed change
would make it less likely that OCC would need to use additional
financial resources, such as its clearing fund, in order to
appropriately manage a clearing member default. Moreover, the proposed
change is intended to measure the exposure associated with changes in
option implied volatilities, thus mitigating credit risk presented by
clearing members. Accordingly, OCC believes that the proposed changes
would reduce risks to OCC and its participants. Moreover, and for the
same reasons, the proposed change will facilitate OCC's ability to
manage risk.
III. Date of Effectiveness of the Advance Notice and Timing for
Commission Action
The designated clearing agency may implement this change if it has
not received an objection to the proposed change within 60 days of the
later of (i) the date that the Commission receives the notice of
proposed change, or (ii) the date the Commission receives any further
information it requests for consideration of the notice. The designated
clearing agency shall not implement this change if the Commission has
an objection.
The Commission may, during the 60-day review period, extend the
review period for an additional 60 days for proposed changes that raise
novel or complex issues, subject to the Commission providing the
designated clearing agency with prompt written notice of the extension.
The designated clearing agency may implement a change in less than 60
days from the date of receipt of the notice of proposed change by the
Commission, or the date the Commission receives any further information
it requested, if the Commission notifies the designated clearing agency
in writing that it does not object to the proposed change and
authorizes the designated clearing agency to implement the change on an
earlier date, subject to any conditions imposed by the Commission.
The designated clearing agency shall post notice on its Web site of
proposed changes that are implemented.
The proposal shall not take effect until all regulatory actions
required with respect to the proposal are completed.\24\
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\24\ OCC also filed a proposed rule change with the Commission
pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
and Rule 19b-4 thereunder, seeking approval of changes to its rules
necessary to implement the proposal. See supra note 3.
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IV. Solicitation of Comments
Interested persons are invited to submit written data, views and
arguments concerning the foregoing. 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-OCC-2015-804 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-OCC-2015-804. 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 advance notice that are filed
with the Commission, and all written communications relating to the
advance notice 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 OCC and on OCC's Web site at https://www.optionsclearing.com/components/docs/legal/rules_and_bylaws/sr_occ_2015_804.pdf. 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-OCC-2015-804 and should be submitted on or before December 2, 2015.
By the Commission.
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2015-29227 Filed 11-16-15; 8:45 am]
BILLING CODE 8011-01-P