Self-Regulatory Organizations; National Securities Clearing Corporation; Notice of Filing of Advance Notice To Enhance the Credit Risk Rating Matrix and Make Other Changes, 17921-17927 [2017-07453]
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Federal Register / Vol. 82, No. 70 / Thursday, April 13, 2017 / Notices
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change;
the Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–NYSE–
2017–15 and should be submitted on or
before May 4, 2017.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.12
Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2017–07455 Filed 4–12–17; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–80396; File No. SR–NSCC–
2017–801]
Self-Regulatory Organizations;
National Securities Clearing
Corporation; Notice of Filing of
Advance Notice To Enhance the Credit
Risk Rating Matrix and Make Other
Changes
Exchange Commission (‘‘Commission’’)
the advance notice SR–NSCC–2017–801
(‘‘Advance Notice’’) as described in
Items I, II and III below, which Items
have been prepared by NSCC.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 consists of
proposed modifications to NSCC’s Rules
and Procedures (‘‘Rules’’).4 The
proposed rule change would amend the
Rules in order to (i) enhance the matrix
(hereinafter referred to as the ‘‘Credit
Risk Rating Matrix’’ or ‘‘CRRM’’) 5
developed by NSCC to evaluate the risks
posed by certain Members (‘‘CRRMRated Members’’) to NSCC and its
Members from providing services to
these CRRM-Rated Members and (ii)
make other amendments to the Rules to
provide more transparency and clarity
regarding NSCC’s current ongoing
membership monitoring process.
II. Clearing Agency’s Statement of the
Purpose of, and Statutory Basis for, the
Advance Notice
In its filing with the Commission, the
clearing agency 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. The clearing agency has
prepared summaries, set forth in
sections A and B below, of the most
significant aspects of such statements.
(A) Clearing Agency’s Statement on
Comments on the Advance Notice
Received From Members, Participants,
or Others
Written comments relating to this
proposal have not been solicited or
received. NSCC will notify the
Commission of any written comments
received by NSCC.
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April 7, 2017.
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
(‘‘Clearing Supervision Act’’) 1 and Rule
19b–4(n)(1)(i) under the Securities
Exchange Act of 1934 (‘‘Act’’),2 notice is
hereby given that on March 22, 2017,
National Securities Clearing Corporation
(‘‘NSCC’’) filed with the Securities and
12 17
CFR 200.30–3(a)(12).
U.S.C. 5465(e)(1).
2 17 CFR 240.19b–4(n)(1)(i).
1 12
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3 On March 22, 2017, NSCC filed this Advance
Notice as a proposed rule change (SR–NSCC–2017–
002) with the Commission pursuant to Section
19(b)(1) of the Act, 15 U.S.C. 78s(b)(1), and Rule
19b–4, 17 CFR 240.19b–4. A copy of the proposed
rule change is available at https://www.dtcc.com/
legal/sec-rule-filings.aspx.
4 Capitalized terms not defined herein are defined
in the Rules, available at https://www.dtcc.com/∼/
media/Files/Downloads/legal/rules/nscc_rules.pdf.
5 The proposed rule changes with respect to the
enhancement of the CRRM are reflected in the
inclusion of (i) qualitative factors and examples
thereof in the proposed new definition for ‘‘Credit
Risk Rating Matrix’’ in Rule 1 and (ii) Members that
are foreign banks or trust companies that have
audited financial data that is publicly available in
Section 4(b)(i) of Rule 2B.
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17921
(B) Advance Notice Filed Pursuant to
Section 806(e) of the Payment, Clearing
and Settlement Supervision Act
Nature of the Proposed Change
The proposed rule change would,
among other things, enhance the CRRM
to enable it to rate Members that are
foreign banks or trust companies and
have audited financial data that is
publicly available. It would also
enhance the CRRM by allowing it to
take into account qualitative factors
when generating credit ratings for
Members. In addition, it would enhance
the CRRM by shifting it from a relative
scoring approach to an absolute scoring
approach.
This rule filing also contains
proposed rule changes that are not
related to the proposed CRRM
enhancements but that provide
specificity, clarity and additional
transparency to the Rules related to
NSCC’s current ongoing membership
monitoring process.
(i) Background
NSCC occupies an important role in
the securities settlement system by
interposing itself as a central
counterparty between Members that are
counterparties to transactions accepted
for clearing by NSCC, thereby reducing
the risk faced by Members. NSCC uses
the CRRM, the Watch List (as defined
below) and the enhanced surveillance to
manage and monitor default risks of
Members on an ongoing basis, as
discussed below. The level and
frequency of such monitoring for a
Member is determined by the Member’s
risk of default as assessed by NSCC.
Members that are deemed by NSCC to
pose a heightened risk to NSCC and its
Members are subject to closer and more
frequent monitoring.
Existing Credit Risk Rating Matrix
In 2005, the Commission approved a
proposed rule change filed by NSCC
(‘‘Initial Filing’’) 6 to establish new
criteria for placing certain Members on
a list for closer monitoring (‘‘Watch
List’’).
NSCC proposed in the Initial Filing
that all U.S. broker-dealers and U.S.
banks that were Members would be
assigned a rating generated by entering
financial data of those Members into an
internal risk assessment matrix, i.e., the
CRRM. However, the text of the current
Rule 2B, Section 4, does not specify
which Members are CRRM-Rated
Members and whether non-CRRM-Rated
6 See Securities Exchange Act Release No. 51362
(March 11, 2005), 70 FR 13562 (March 21, 2005)
(SR–NSCC–2003–11).
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Federal Register / Vol. 82, No. 70 / Thursday, April 13, 2017 / Notices
Members may be included on the Watch
List.
Currently, Members that are U.S.
broker-dealers and U.S. banks are
assessed against the CRRM and assigned
a credit rating based on certain
quantitative factors.7 Unfavorably-rated
Members are placed on the Watch List.
In addition, NSCC credit risk staff may
downgrade a particular Member’s credit
rating based on various qualitative
factors. An example of such qualitative
factors might be that the Member in
question received a qualified audit
opinion on its annual audit. NSCC
believes that, in order to protect NSCC
and its other Members, it is important
that credit risk staff maintain the
discretion to downgrade a Member’s
credit rating on the CRRM and thus
subject the Member to closer
monitoring.
The current CRRM is comprised of
two credit rating models—one for the
U.S. broker-dealers and one for the U.S.
banks—and generates credit ratings for
the relevant Members based on a 7-point
rating system, with ‘‘1’’ being the
strongest credit rating and ‘‘7’’ being the
weakest credit rating.
Over time, the current CRRM has not
kept pace with NSCC’s evolving
membership base and heightened
expectations from regulators and
stakeholders for robustness of financial
models. Specifically, the current CRRM
only generates credit ratings for those
Members that are U.S. banks or U.S.
broker-dealers that file standard reports
with their regulators. Although these
types of Members currently represent
the vast majority (approximately 95%)
of Members at NSCC,8 foreign banks and
trust companies are expected to be a
growing category of NSCC’s
membership base in the future, and the
proposed enhancements to the CRRM
would enable it to assign credit ratings
to these entities. Foreign banks and trust
companies are typically large global
financial institutions that have complex
businesses and conduct a high volume
of activities. Although foreign banks and
trust companies are not currently rated
by the CRRM, they are monitored by
NSCC’s credit risk staff using financial
criteria deemed relevant by NSCC and
can be placed on the Watch List if they
experience a financial change that
presents risk to NSCC. Given the
7 Quantitative
factors considered by NSCC
include (a) for broker dealers, size (i.e., total excess
net capital), capital, leverage, liquidity, and
profitability and (b) for banks, size, capital, asset
quality, earnings, and liquidity.
8 As of March 16, 2017, there are 155 Members.
Of the 155 Members, 11 (or 7%) are U.S. banks, 136
(or 88%) are U.S. broker-dealers and one (or 1%)
is a foreign bank or trust company.
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potential increase in the number of
Members that are foreign banks or trust
companies in the coming years, there is
a need to formalize NSCC’s credit risk
evaluation process of these Members by
assigning credit ratings to them in order
to better facilitate the comparability of
credit risks among Members.9
In addition, the current CRRM assigns
each Member that is a U.S. bank or U.S.
broker-dealer and that files standard
reports with its regulator(s) a credit
rating based on inputting certain
quantitative data relative to the
applicable Member into the CRRM.
Accordingly, a Member’s credit rating is
currently based solely upon quantitative
factors. It is only after the CRRM has
generated a credit rating with respect to
a particular Member that such Member’s
credit rating may be downgraded
manually by credit risk staff, after taking
into consideration relevant qualitative
factors. The inability of the current
CRRM to take into account qualitative
factors requires frequent and manual
overrides by credit risk staff, which may
result in inconsistent and/or incomplete
credit ratings for Members.
Furthermore, the current CRRM uses
a relative scoring approach and relies on
peer grouping of Members to calculate
the credit rating of a Member. This
approach is not ideal because a
Member’s credit rating can be affected
by changes in its peer group even if the
Member’s financial condition is
unchanged.
Proposed Credit Risk Rating Matrix
Enhancements
To improve the coverage and the
effectiveness of the current CRRM,
NSCC is proposing three enhancements.
The first proposed enhancement would
expand the scope of CRRM coverage by
enabling the CRRM to generate credit
ratings for Members that are foreign
banks or trust companies and that have
audited financial data that is publicly
available. The second proposed
enhancement would incorporate
qualitative factors into the CRRM and
therefore is expected to reduce the need
and the frequency of manual overrides
of Member credit ratings. The third
enhancement would replace the relative
scoring approach currently used by
CRRM with a statistical approach to
9 CRRM is applied across NSCC and its affiliated
clearing agencies, Fixed Income Clearing
Corporation (‘‘FICC’’) and The Depository Trust
Company (‘‘DTC’’). Specifically, in order to run the
CRRM, credit risk staff uses the financial data of the
applicable NSCC Members in addition to data of
applicable members and participants of FICC and
DTC, respectively. In this way, each applicable
NSCC Member is rated against other applicable
members and participants of FICC and DTC,
respectively.
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estimate the absolute probability of
default of each Member.
A. Enable the CRRM to Generate Credit
Ratings for Foreign Bank or Trust
Company Members
The current CRRM is comprised of
two credit rating models—one for the
U.S. broker-dealers and one for the U.S.
banks. NSCC is proposing to enhance
the CRRM by adding an additional
credit rating model for the foreign banks
and trust companies. The additional
model would expand the membership
classes to which the CRRM would apply
to include Members that are foreign
banks or trust companies and that have
audited financial data that is publicly
available. The CRRM credit rating of a
Member that is a foreign bank or trust
company would be based on
quantitative factors, including size,
capital, leverage, liquidity, profitability
and growth, and qualitative factors,
including market position and
sustainability, information reporting
and compliance, management quality,
capital management and business/
product diversity. By enabling the
CRRM to generate credit ratings for
these Members, the enhanced CRRM
would provide more comprehensive
credit risk coverage of NSCC’s
membership base.
With the proposed enhancement to
the CRRM as described above,
applicable foreign bank or trust
company Members would be included
in the CRRM process and be evaluated
more effectively and efficiently because
financial data with respect to these
foreign bank or trust company Members
could be extracted from data sources in
an automated form.10
After the proposed enhancement,
CRRM would be able to generate credit
ratings on an ongoing basis for all
Members that are U.S. banks, U.S.
brokers-dealers and foreign banks and
trust companies, which together
represent approximately 96% of the
NSCC Members.11
B. Incorporate Qualitative Factors Into
the CRRM
In addition, as proposed, the
enhanced CRRM would blend
qualitative factors with quantitative
factors to produce a credit rating for
each applicable Member in relation to
10 Currently, these Members are monitored by
NSCC credit risk staff that review similar criteria as
those reviewed for CRRM-Rated Members, but such
review occurs outside of the CRRM process.
11 As of March 16, 2017, there are 7 Members that
would not be rated by the enhanced CRRM, as
proposed, because they are central securities
depositories, securities exchanges and U.S. trust
companies that do not file Call Reports (as defined
below).
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the Member’s credit risk. For U.S. and
foreign banks and trust companies, the
enhanced CRRM would use a 70/30
weighted split between quantitative and
qualitative factors to generate credit
ratings. For U.S. broker-dealers, the
weight split between quantitative and
qualitative factors would be 60/40.
These weight splits are chosen by NSCC
based on the industry best practice as
well as research and sensitivity analysis
conducted by NSCC. NSCC would
review and adjust the weight splits as
well as the quantitative and qualitative
factors, as needed, based on
recalibration of the CRRM to be
conducted by NSCC approximately
every three to five years.
Although there are advantages to
measuring credit risk quantitatively,
quantitative evaluation models alone are
incapable of fully capturing all credit
risks. Certain qualitative factors may
indicate that a Member is or will soon
be undergoing financial distress, which
may in turn signal a higher default
exposure to NSCC and its other
Members. As such, a key enhancement
being proposed to the CRRM is the
incorporation of relevant qualitative
factors into each of the three credit
rating models mentioned above. By
including qualitative factors in the three
credit rating models, the enhanced
CRRM would capture risks that would
otherwise not be accounted for with
quantitative factors alone.12 Adding
qualitative factors to the CRRM would
not only enable it to generate more
consistent and comprehensive credit
ratings for applicable Members, but it
would also help reduce the need and
frequency of manual credit rating
overrides by the credit risk staff because
overrides would likely only be required
under more limited circumstances.13
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C. Shifting From Relative Scoring to
Absolute Scoring
As proposed, the enhanced CRRM
would use an absolute scoring approach
and rank each Member based on its
12 The initial set of qualitative factors that would
be incorporated into the CRRM includes (a) for U.S.
broker dealers, market position and sustainability,
management quality, capital management, liquidity
management, geographic diversification, business/
product diversity and access to funding, (b) for U.S.
banks, environment, compliance/litigation,
management quality, liquidity management and
parental demands and (c) for foreign banks and
trust companies, market position and sustainability,
information reporting and compliance, management
quality, capital management and business/product
diversity.
13 Once a Member is assigned a credit rating, if
circumstances warrant, credit risk staff would still
have the ability to override the CRRM-issued credit
rating by manually downgrading such rating as they
do today. To ensure a conservative approach, the
CRRM-issued credit ratings cannot be manually
upgraded.
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individual probability of default rather
than the relative scoring approach that
is currently in use. This proposed
change is designed to have a Member’s
CRRM-generated credit rating reflect an
absolute measure of the Member’s
default risk and eliminate any potential
distortion of a Member’s credit rating
from the Member’s peer group that may
occur under the relative scoring
approach used in the existing CRRM.
D. Watch List and Enhanced
Surveillance
In addition to the Watch List, NSCC
also maintains an enhanced surveillance
list (referenced herein and in the
proposed rule text as ‘‘enhanced
surveillance’’) for membership
monitoring. The enhanced surveillance
list is generally used when Members are
undergoing drastic and unexpected
changes in their financial conditions or
operation capabilities and thus are
deemed by NSCC to be of the highest
risk level and/or warrant additional
scrutiny due to NSCC’s ongoing
concerns about these Members.
Accordingly, Members that are subject
to enhanced surveillance are reported to
NSCC’s management committees and
are also regularly reviewed by a crossfunctional team comprised of senior
management of NSCC. More often than
not, Members that are subject to
enhanced surveillance are also on the
Watch List. The group of Members that
is subject to enhanced surveillance is
generally much smaller than the group
on the Watch List. The enhanced
surveillance list is an internal tool for
NSCC that triggers increased monitoring
of a Member above the monitoring that
occurs when a Member is on the Watch
List.
A Member could be placed on the
Watch List either based on its credit
rating of 5, 6 or 7, which can either be
generated by the CRRM or from a
manual downgrade, or when NSCC
deems such placement as necessary to
protect NSCC and its Members. In
contrast, a Member would be subject to
enhanced surveillance only when close
monitoring of the Member is deemed
necessary to protect NSCC and its
Members.
The Watch List and enhanced
surveillance tools are not mutually
exclusive; they may complement each
other under certain circumstances. A
key distinction between the Watch List
and enhanced surveillance is that being
placed on the Watch List may result in
Required Deposit 14 related
14 See Rule 4 (Section 1). The ‘‘Required Deposit’’
is the amount that each Member is required to
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17923
consequences under the Rules, whereas
enhanced surveillance does not.15 For
example, a Member that is in a
precarious situation could be placed on
the Watch List and be subject to
enhanced surveillance; however,
because the Watch List status could
increase a Member’s Required Deposit,
when NSCC has preliminary concerns
about a Member, to avoid potential
increase to a Member’s Required
Deposit, NSCC may opt not to place the
Member on the Watch List until it is
certain that such concerns would not be
alleviated in the short-term. Instead, in
such a situation, NSCC might first
subject the Member to enhanced
surveillance in order to closely monitor
the Member’s situation without affecting
the Member’s Required Deposit. If the
Member’s situation improves, then it
will no longer be subject to enhanced
surveillance. If the situation of the
Member worsens, the Member may then
be placed on the Watch List as deemed
necessary by NSCC.
(ii) Detailed Description of the Proposed
Rule Changes Related to the Proposed
CRRM Enhancements
In connection with the proposed
enhancements to the CRRM, NSCC
proposes to amend the Rules to (1)
incorporate qualitative factors into
CRRM and (2) add Members that are
foreign banks or trust companies to the
categories of Members that would be
assigned credit ratings by NSCC using
the CRRM.
A. Proposed Changes to Rule 1
(Definitions and Descriptions)
NSCC is proposing to include
qualitative factors, such as management
quality, market position/environment,
and capital and liquidity risk
management in the proposed new
definition for ‘‘Credit Risk Rating
Matrix’’ in Rule 1 because, as proposed,
the enhanced CRRM would blend both
qualitative factors and quantitative
factors to produce a credit rating for
each applicable Member.
B. Proposed Changes to Section 4(b)(i)
of Rule 2B (Ongoing Membership
Requirements and Monitoring)
NSCC is proposing to expand the
membership types to which the CRRM
would apply to include Members that
are foreign banks or trust companies and
that have audited financial data that is
deposit in NSCC’s Clearing Fund. Rules, supra note
4.
15 NSCC expects to provide additional clarity to
Members regarding the Watch List and its impact
on Required Deposit in a subsequent proposed rule
change to be filed with the Commission in 2017.
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publicly available by amending Section
4 of Rule 2B.
The enhanced CRRM would assign
credit ratings for each Member that is a
foreign bank or trust company based on
its publicly available audited financial
data. The credit rating would be based
on an 18-point scale, which is then
mapped to the 7-point rating system
currently in use today, with ‘‘1’’ being
the strongest credit rating and ‘‘7’’ being
the weakest credit rating.
(iii) Other Proposed Rule Changes
This rule filing also contains
proposed rule changes that are
unrelated to the proposed enhancement
of the CRRM. These proposed rule
changes would provide specificity,
clarity and additional transparency to
the Rules with respect to NSCC’s
current ongoing membership monitoring
process, as described below.
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A. Proposed Changes to Rule 1
(Definitions and Descriptions)
NSCC is proposing to amend Rule 1
to add definitions for the CRRM and the
Watch List.
The proposed definition of the CRRM
would provide that the term ‘‘Credit
Risk Rating Matrix’’ means a matrix of
credit ratings of Members as specified in
Section 4 of Rule 2B. The definition
would state that the CRRM is developed
by NSCC to evaluate the credit risk such
Members pose to NSCC and its Members
and is based on factors determined to be
relevant by NSCC from time to time,
which factors are designed to
collectively reflect the financial and
operational condition of a Member. The
proposed definition would state that, in
addition to the proposed qualitative
factors described above, these factors
include quantitative factors, such as
capital, assets, earnings and liquidity.
The proposed definition of the Watch
List would provide that the term
‘‘Watch List’’ means, at any time and
from time to time, the list of Members
whose credit ratings derived from the
CRRM are 5, 6 or 7, as well as Members
and Limited Members that, based on
NSCC’s consideration of relevant
factors, including those set forth in
Section 4(d) of Rule 2B (described
below), are deemed by NSCC to pose a
heightened risk to NSCC and its
Members.
B. Proposed Changes to Rule 2B
(Ongoing Membership Requirements
and Monitoring)
Section 2B of Rule 2B
NSCC is proposing to amend Section
2B of Rule 2B to state that NSCC may
review the financial responsibility and
operational capability of each Member
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and may otherwise require additional
reporting from the Member regarding its
financial or operational condition that
may (1) include information regarding
the businesses and operations of the
Member and its risk management
practices with respect to NSCC’s
services utilized by the Member for
another Person and (2) result in the
Member being placed on the Watch List
and/or being subject to enhanced
surveillance as determined by NSCC.
Members are direct participants of
NSCC. However, there are firms that
rely on the services provided by
Members in order to have their activity
cleared and settled through NSCC’s
facilities (the ‘‘indirect participants’’).
These indirect participants pose certain
risks to NSCC that need to be identified
and monitored as part of NSCC’s
ongoing member due diligence process.
In order for NSCC to understand (1) the
material dependencies between
Members and the indirect participants
that rely on the Members for the
clearance and settlement of the indirect
participants’ transactions, (2) significant
Member-indirect participant
relationships and (3) the various risk
controls and mitigants that these
Members employ to manage their risks
with respect to such relationships,
NSCC may request information from
Members regarding the Members’
businesses and operations as well as
their risk management practices with
respect to services of NSCC utilized by
the Members for indirect participants.
The information provided by Members
would then be taken into consideration
by NSCC when determining whether a
Member may need to be placed on the
Watch List, be subject to enhanced
surveillance or both.
Section 4 of NSCC Rule 2B
NSCC is proposing to amend Section
4 of Rule 2B in order to (1) specify the
membership types that are currently
subject to NSCC’s ongoing monitoring
and review, (2) clarify which U.S.
broker-dealers and U.S. banks will be
assigned a credit rating by NSCC in
accordance with the CRRM, (3) provide
that NSCC may manually downgrade a
CRRM-Rated Member’s credit rating in
certain instances, (4) provide that NSCC
may place non-CRRM-Rated Members
and certain Limited Members on the
Watch List and/or subject them to
enhanced surveillance, if necessary, (5)
describe some of the factors that could
be taken into consideration by NSCC
when downgrading a Member’s or
Limited Member’s credit rating, placing
a Member or Limited Member on the
Watch List and/or subjecting a Member
or Limited Member to enhanced
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surveillance, (6) allow NSCC to collect
additional deposits to the Clearing Fund
and to retain deposits in excess of the
Required Deposit from Members or
Limited Members that are on the Watch
List and (7) provide for enhanced
monitoring of Members or Limited
Members that are on the Watch List
and/or are subject to enhanced
surveillance.
In connection with the forgoing,
NSCC proposes to delete the current
first paragraph in Section 4 of NSCC
Rule 2B and add the following:
1. Section 4(a), specifying that NSCC
currently monitors and reviews all
Members and certain Limited Members
on an ongoing and periodic basis, which
may include monitoring news and
market developments relating to these
Members and Limited Members and
conducting reviews of financial reports
and other public information of these
Members and Limited Members.
2. Section 4(b)(i), clarifying that (1)
Members that are (A) U.S. banks or trust
companies that file the Consolidated
Report of Condition and Income (‘‘Call
Report’’) or (B) U.S. broker-dealers that
file the Financial and Operational
Combined Uniform Single Report
(‘‘FOCUS Report’’) or the equivalent
with their regulators, would be assigned
a credit rating by NSCC in accordance
with the CRRM and (2) each CRRMRated Member’s credit rating would be
reassessed upon receipt of additional
information from the Member.
3. Section 4(b)(ii), providing that,
because the factors used as part of the
CRRM may not identify all risks that a
Member may pose to NSCC, NSCC may,
in addition to other actions permitted by
the Rules, downgrade the Member’s
credit rating derived from the CRRM if
NSCC believes the CRRM-generated
rating is insufficiently conservative or if
it deems such downgrade as necessary
to protect NSCC and its Members.
Depending on the credit rating of the
Member, a downgrade may result in the
Member being placed on the Watch List
and/or being subject to enhanced
surveillance based on relevant factors.
4. Section 4(c), specifying that, other
than CRRM-Rated Members, NSCC may
place Members and Limited Members
that are monitored and reviewed by
NSCC on the Watch List and/or subject
them to enhanced surveillance even
though they are not being assigned
credit ratings by NSCC in accordance
with the CRRM.
5. Section 4(d), describing some of the
factors that could be taken into
consideration by NSCC when
downgrading a Member’s credit rating,
placing a Member or Limited Member
on the Watch List and/or subjecting a
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Member or Limited Member to
enhanced surveillance. These factors
include but are not limited to (i) news
reports and/or regulatory observations
that raise reasonable concerns relating
to the Member or Limited Member, (ii)
reasonable concerns around the
Member’s or Limited Member’s liquidity
arrangements, (iii) material changes to
the Member’s or Limited Member’s
organizational structure, (iv) reasonable
concerns of NSCC about the Member’s
or Limited Member’s financial stability
due to particular facts and
circumstances, such as material
litigation or other legal and/or
regulatory risks, (v) failure of the
Member or Limited Member to
demonstrate satisfactory financial
condition or operational capability or if
NSCC has a reasonable concern
regarding the Member’s or Limited
Member’s ability to maintain applicable
membership standards and (vi) failure
of the Member or Limited Member to
provide information required by NSCC
to assess risk exposures posed by the
Member’s or Limited Member’s activity.
6. Section 4(e), allowing NSCC to (1)
require a Member or Limited Member
that has been placed on the Watch List
to make and maintain additional
deposits to the Clearing Fund and (2)
withhold any deposit in excess of the
Required Deposit of a Member or
Limited Member that has been placed
on the Watch List as provided in
Section 9 of Rule 4.
7. Section 4(f), providing that NSCC
would, in addition to other actions
permitted by the Rules, conduct a more
thorough monitoring of the financial
condition and/or operational capability
of, and require more frequent financial
disclosures from, not only those
Members and Limited Members that are
placed on the Watch List but also
Members and Limited Members subject
to enhanced surveillance, including
examples of how the monitoring could
be conducted and the types of
disclosures that may be required. In
addition, Members and Limited
Members that are subject to enhanced
surveillance would be reported to
NSCC’s management committees and
regularly reviewed by a cross-functional
team comprised of senior management
of NSCC.
In addition to the proposed changes
described above, NSCC is proposing to
make technical corrections to the
second paragraph of Section 4 of Rule
2B to (1) renumber the paragraph as
Section 4(g), (2) update an internal cross
reference and (3) clarify that the
references in the paragraph to Members
under surveillance are referring to
Members on the Watch List.
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C. Proposed Changes to Rule 4 (Clearing
Fund)
NSCC is proposing to amend Section
9 of Rule 4 to clarify that NSCC may, in
its discretion, withhold all or part of any
excess Clearing Fund deposit of
Members that are on the Watch List.
D. Proposed Changes to Procedure XV
(Clearing Fund Formula and Other
Matters)
NSCC is proposing to amend Section
I(B)(1) of Procedure XV to clarify that
Members or Limited Members that are
placed on the Watch List would be
required to make additional Clearing
Fund deposits, as determined by NSCC.
In addition, NSCC is proposing to
make the following technical
corrections to Section I(B)(1) of
Procedure XV, (i) renumber the final
three paragraphs as Section I(B)(2) and
title the new subsection ‘‘Family Issued
Securities’’ to reflect the different
subject matter of the new subsection, (ii)
capitalize references to the Credit Risk
Rating Matrix to reflect the proposed
addition of the defined term to Rule 1
and (iii) make other grammatical
corrections to the new Section I(B)(2).
Finally, NSCC is proposing to amend
Section II(C) of Procedure XV to clarify
that, although NSCC would not request
additional Clearing Fund deposits from
Members unless they exceed a
predetermined threshold, such floor
would not apply to Members or Limited
Members that are on the Watch List.
E. Additional Proposed Changes to Rule
1 (Definitions and Descriptions) and
Procedure XV (Clearing Fund Formula
and Other Matters)
NSCC is proposing to amend the
definition of ‘‘Illiquid Position’’ in Rule
1 as well as Procedure XV Sections
I(A)(1) and I(A)(2), each as proposed in
connection with a separate proposed
rule change filed with the Commission
but not yet approved.16 Specifically, the
proposed amendments would replace
and conform references to ‘‘credit risk
matrix’’ with ‘‘Credit Risk Rating
Matrix’’ in the proposed definition of
‘‘Illiquid Position’’ in Rule 1 as well as
Procedure XV Sections I(A)(1) and
I(A)(2).
Implementation Timeframe
Pending Commission approval, NSCC
expects to implement this proposal
promptly. Members would be advised of
the implementation date of this
proposal through issuance of a NSCC
Important Notice.
16 See Securities Exchange Act Release No. 80260
(March 16, 2017), 82 FR 14781 (March 22, 2017)
(SR–NSCC–2017–001).
PO 00000
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17925
Expected Effect on Risks to the Clearing
Agency, Its Participants and the Market
The proposed rule changes would
mitigate counterparty credit risk for
NSCC by allowing NSCC to more
accurately monitor the creditworthiness
and risk profile of its Members. The
enhanced CRRM would provide a more
robust credit rating methodology by
incorporating qualitative factors and
adopting an absolute scoring approach.
Both of these enhancements would
improve NSCC’s ability to monitor the
credit risk of its Members and are
expected to lessen the frequency of
manual overrides. The enhanced CRRM
would also expand the coverage of
NSCC’s membership by providing credit
ratings for Members that are foreign
banks or trust companies, which are not
covered under the existing CRRM.
By mitigating counterparty credit risk
for NSCC as described above, the
enhanced CRRM would also mitigate
risk for Members because lowering the
risk profile for NSCC would in turn
lower the risk exposure that Members
may have with respect to NSCC in its
role as a central counterparty.
Management of Identified Risks
The proposed rule changes are
designed to mitigate counterparty credit
risk for NSCC and to provide greater
clarity and transparency to Members
regarding the counterparty credit risk
management approach used by NSCC.
The enhanced CRRM would improve
NSCC’s ability to monitor the
probability of default for Members that
are rated by the CRRM and is expected
to lessen the need and the frequency of
manual downgrades due to the
anticipated improvement in the
accuracy of the credit ratings generated
by the enhanced CRRM.
NSCC employs a risk-based approach
to conducting monitoring and review of
its Members by using the CRRM to
identify higher risk Members. Once
identified, NSCC would place these
Members on the Watch List, which
would result in more frequent review by
NSCC of these Members than the other
Members. For Members that are placed
on the Watch List, NSCC would conduct
more thorough monitoring of these
Members’ financial condition and/or
operational capability, which could
include, for example, on-site visits or
additional due diligence information
requests.
Members that have been placed on the
Watch List may also be required to
maintain a higher deposit to the
Clearing Fund, which would help offset
potential risks to NSCC and its Members
arising from activity submitted by these
Members.
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The enhanced CRRM would also
expand the coverage of NSCC’s
membership by providing credit ratings
for foreign banks and trust companies,
which are not currently rated under the
existing CRRM. The addition of these
entities would allow NSCC to employ
its risk-based approach to identify those
higher risk Members for additional
monitoring with more efficiency (by
reducing the need for manual overrides)
and effectiveness (by generating a more
comprehensive and accurate credit
rating after taking into account both
quantitative and qualitative factors and
adopting the absolute scoring approach).
Thus, the enhanced CRRM would
help NSCC to identify those Members
that could present credit risk to NSCC,
which then would allow NSCC to better
manage the potential risks from these
Members.
Consistency With the Clearing
Supervision Act
The proposed enhancements to the
CRRM as described in detail above
would be consistent with Section 805(b)
of Clearing Supervision Act.17 The
objectives and principles of Section
805(b) of the Clearing Supervision Act
include, among other things, the
promotion of robust risk management.18
By enhancing the CRRM to enable it
to assign credit ratings to Members that
are foreign banks or trust companies and
that have audited financial data that is
publicly available, the proposed rule
change would expand the CRRM’s
applicability to a wider group of
Members, which would improve
NSCC’s membership monitoring process
and promote robust risk management,
consistent with the objectives and
principles of Section 805(b) of the
Clearing Supervision Act cited above.
Similarly, by enhancing the CRRM to
enable it to incorporate qualitative
factors when assigning a Member’s
credit rating, the proposed change
would enable NSCC to take into account
relevant qualitative factors in an
automated and more effective manner
when monitoring the credit risks
presented by the Members, which
would improve NSCC’s membership
monitoring process overall and promote
robust risk management, consistent with
the objectives and principles of Section
805(b) of the Clearing Supervision Act
cited above.
Likewise, by enhancing the CRRM to
shift from a relative scoring approach to
an absolute scoring approach when
assigning a Member’s credit rating, the
proposed rule change would enable
17 12
U.S.C. 5464(b).
18 Id.
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NSCC to generate credit ratings for
Members that are more reflective of the
Members’ default risk, which would
improve NSCC’s membership
monitoring process and promote robust
risk management, consistent with the
objectives and principles of Section
805(b) of the Clearing Supervision Act
cited above.
The proposed enhancements to the
CRRM are consistent with Rule 17Ad–
22(e)(3)(i) under the Act, which was
recently adopted by the Commission.19
Rule 17Ad–22(e)(3)(i) will require NSCC
to establish, implement, maintain and
enforce written policies and procedures
reasonably designed to maintain a
sound risk management framework for
comprehensively managing risks that
arise in or are born by NSCC, which
includes * * * systems designed to
identify, measure, monitor and manage
the range of risks that arise in or are
borne by NSCC.20 The proposed
enhancements to the CRRM have been
designed to assist NSCC in identifying,
measuring, monitoring and managing
the credit risks to NSCC posed by its
Members. The proposed enhancements
to the CRRM accomplish this by (i)
expanding the CRRM’s applicability to a
wider group of Members to include
Members that are foreign banks or trust
companies, (ii) enabling the CRRM to
take into account relevant qualitative
factors in an automated and more
effective manner when monitoring the
credit risks presented by Members and
(iii) enabling the CRRM to generate
credit ratings for Members that are more
reflective of the Members’ default risk
by shifting to an absolute scoring
approach, all of which would improve
NSCC’s membership monitoring process
overall. Therefore, NSCC believes the
proposed enhancements to the CRRM
would assist NSCC in identifying,
measuring, monitoring and managing
risks that arise in or are born by NSCC,
consistent with the requirements of Rule
17Ad–22(e)(3)(i).
The proposed rule change to Section
2B of Rule 2B with respect to the scope
of information that may be requested by
NSCC from its Members has been
designed to be consistent with Rule
17Ad–22(e)(19) under the Act, which
was recently adopted by the
19 17 CFR 240.17Ad–22(e)(3)(i). The Commission
adopted amendments to Rule 17Ad–22, including
the addition of new subsection 17Ad–22(e), on
September 28, 2016. See Securities Exchange Act
Release No. 78961 (September 28, 2016), 81 FR
70786 (October 13, 2016) (S7–03–14). FICC is a
‘‘covered clearing agency’’ as defined by the new
Rule 17Ad–22(a)(5) and must comply with new
subsection (e) of Rule 17Ad–22 by April 11, 2017.
Id.
20 Id.
PO 00000
Frm 00133
Fmt 4703
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Commission.21 Rule 17Ad–22(e)(19)
will require NSCC to establish,
implement, maintain and enforce
written policies and procedures
reasonably designed to identify,
monitor, and manage the material risk to
NSCC arising from arrangements in
which firms that are indirect
participants in NSCC rely on the
services provided by Members to access
NSCC’s payment, clearing, or settlement
facilities.22 By expressly reflecting in
the Rules what is already NSCC’s
current practice associated with its
request for additional reporting of a
Member’s financial or operational
conditions to state that such request
may include information regarding the
businesses and operations of the
Member, as well as its risk management
practices with respect to services of
NSCC utilized by the Member for
another Person, this proposed rule
change would help enable NSCC to have
rule provisions that are reasonably
designed to identify, monitor and
manage the material risks to NSCC
arising from tiered participation
arrangements consistent with Rule
17Ad–22(e)(19).
III. Date of Effectiveness of the Advance
Notice, and Timing for Commission
Action
The proposed change may be
implemented if the Commission does
not object to the proposed change
within 60 days of the later of (i) the date
that the proposed change was filed with
the Commission or (ii) the date that any
additional information requested by the
Commission is received. The clearing
agency shall not implement the
proposed change if the Commission has
any objection to the proposed change.
The Commission may extend the
period for review by an additional 60
days if the proposed change raises novel
or complex issues, subject to the
Commission providing the clearing
agency with prompt written notice of
the extension. A proposed change may
be implemented in less than 60 days
from the date the advance notice is
filed, or the date further information
requested by the Commission is
received, if the Commission notifies the
clearing agency in writing that it does
not object to the proposed change and
authorizes the clearing agency to
implement the proposed change on an
earlier date, subject to any conditions
imposed by the Commission.
The clearing agency shall post notice
on its Web site of proposed changes that
are implemented.
21 17
CFR 240.17Ad–22(e)(19). Id.
22 Id.
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The proposal shall not take effect
until all regulatory actions required
with respect to the proposal are
completed.
By the Commission.
Eduardo A. Aleman,
Assistant Secretary.
IV. Solicitation of Comments
BILLING CODE 8011–01–P
[FR Doc. 2017–07453 Filed 4–12–17; 8:45 am]
Interested persons are invited to
submit written data, views and
arguments concerning the foregoing,
including whether the Advance Notice
is consistent with the Clearing
Supervision 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–
NSCC–2017–801 on the subject line.
asabaliauskas on DSK3SPTVN1PROD with NOTICES
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549.
All submissions should refer to File
Number SR–NSCC–2017–801. 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 of NSCC and on DTCC’s Web site
(https://dtcc.com/legal/sec-rulefilings.aspx). 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–NSCC–
2017–801 and should be submitted on
or before April 28, 2017.
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SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–80401; File No. SR–
PEARL–2017–17]
Self-Regulatory Organizations; MIAX
PEARL, LLC; Notice of Filing and
Immediate Effectiveness of a Proposed
Rule Change To Amend the MIAX
PEARL Fee Schedule
April 7, 2017.
Pursuant to the provisions of 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 April 6, 2017, MIAX PEARL, LLC
(‘‘MIAX PEARL’’ or ‘‘Exchange’’) filed
with the Securities and Exchange
Commission (‘‘Commission’’) a
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 is filing a proposal to
amend the MIAX PEARL Fee Schedule
(the ‘‘Fee Schedule’’) to waive
transaction rebates/fees applicable to
transactions executed during the
opening and transactions that uncross
the Away Best Bid or Offer (‘‘ABBO’’).
The Exchange initially filed the
proposal on March 29, 2017 (SR–
PEARL–2017–13). That filing has been
withdrawn and replaced with the
current filing (SR–PEARL–2017–17).
The text of the proposed rule change
is available on the Exchange’s Web site
at https://www.miaxoptions.com/rulefilings/pearl, at MIAX PEARL’s
principal office, and at the
Commission’s Public Reference Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
Exchange included statements
concerning the purpose of and basis for
the proposed rule change and discussed
any comments it received on the
1 15
2 17
PO 00000
U.S.C. 78s(b)(1).
CFR 240.19b–4.
Frm 00134
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17927
proposed rule change. The text of these
statements may be examined at the
places specified in Item IV below. The
Exchange has prepared summaries, set
forth in sections A, B, and C below, of
the most significant aspects of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The purpose of this proposed rule
change is to waive transaction rebates/
fees applicable to executions that occur
as part of the Exchange’s opening
procedures as described in Rule 503
(‘‘Openings on the Exchange’’) or that
uncross the ABBO,3 as described in
Rule 515 (‘‘Execution of Orders’’).
Under the Openings on the Exchange
Rule, the Exchange will accept orders
for queuing in a series of options prior
to the opening of trading in that series
of options. As such and as further
described in Rule 503, executions might
occur in a series as part of the Exchange
Opening as the series is being opened
for trading. Pursuant to Section 1)a) of
the Exchange’s Fee Schedule, the
Exchange currently assesses transaction
rebates and fees for transactions that
occur as part of the Exchange Opening.
In order to determine the applicable
transaction rebate and fee, the Exchange
treats orders from Priority Customer 4
origin type as a ‘‘Maker,’’ and treats
orders from all origin types other than
Priority Customer (i.e., MIAX PEARL
Market Maker 5 and Non-Priority
Customer, Firm, BD and Non-MIAX
PEARL Market Maker) 6 as a ‘‘Taker.’’
The Exchange now proposes that, for
executions occurring as part of the
Exchange Opening, the Exchange will
neither charge a fee nor provide a
rebate, regardless of origin type.
Further, pursuant to Section 1)a) of
the Exchange’s Fee Schedule, the
Exchange currently assesses transaction
rebates and fees for transactions that
uncross the ABBO. In order to
3 See
MIAX PEARL Rule 100.
term ‘‘Priority Customer’’ is defined in
Exchange Rule 100 to mean a person or entity that
(i) is not a broker or dealer in securities, and (ii)
does not place more than 390 orders in listed
options per day on average during a calendar month
for its own beneficial accounts(s). The number of
orders is counted in accordance with Rule 100
Interpretation and Policy .01.
5 The term ‘‘Market Maker’’ is defined in
Exchange Rule 100 to mean a Member registered
with the Exchange for the purpose of making
markets in options contracts traded on the
Exchange and that is vested with the rights and
responsibilities specified in Chapter VI of the
Exchange’s Rules.
6 See MIAX PEARL Fee Schedule, Section 1(a).
4 The
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[Federal Register Volume 82, Number 70 (Thursday, April 13, 2017)]
[Notices]
[Pages 17921-17927]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-07453]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-80396; File No. SR-NSCC-2017-801]
Self-Regulatory Organizations; National Securities Clearing
Corporation; Notice of Filing of Advance Notice To Enhance the Credit
Risk Rating Matrix and Make Other Changes
April 7, 2017.
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 (``Clearing
Supervision Act'') \1\ and Rule 19b-4(n)(1)(i) under the Securities
Exchange Act of 1934 (``Act''),\2\ notice is hereby given that on March
22, 2017, National Securities Clearing Corporation (``NSCC'') filed
with the Securities and Exchange Commission (``Commission'') the
advance notice SR-NSCC-2017-801 (``Advance Notice'') as described in
Items I, II and III below, which Items have been prepared by NSCC.\3\
The Commission is publishing this notice to solicit comments on the
Advance Notice from interested persons.
---------------------------------------------------------------------------
\1\ 12 U.S.C. 5465(e)(1).
\2\ 17 CFR 240.19b-4(n)(1)(i).
\3\ On March 22, 2017, NSCC filed this Advance Notice as a
proposed rule change (SR-NSCC-2017-002) with the Commission pursuant
to Section 19(b)(1) of the Act, 15 U.S.C. 78s(b)(1), and Rule 19b-4,
17 CFR 240.19b-4. A copy of the proposed rule change is available at
https://www.dtcc.com/legal/sec-rule-filings.aspx.
---------------------------------------------------------------------------
I. Clearing Agency's Statement of the Terms of Substance of the Advance
Notice
This Advance Notice consists of proposed modifications to NSCC's
Rules and Procedures (``Rules'').\4\ The proposed rule change would
amend the Rules in order to (i) enhance the matrix (hereinafter
referred to as the ``Credit Risk Rating Matrix'' or ``CRRM'') \5\
developed by NSCC to evaluate the risks posed by certain Members
(``CRRM-Rated Members'') to NSCC and its Members from providing
services to these CRRM-Rated Members and (ii) make other amendments to
the Rules to provide more transparency and clarity regarding NSCC's
current ongoing membership monitoring process.
---------------------------------------------------------------------------
\4\ Capitalized terms not defined herein are defined in the
Rules, available at https://www.dtcc.com/~/media/Files/Downloads/
legal/rules/nscc_rules.pdf.
\5\ The proposed rule changes with respect to the enhancement of
the CRRM are reflected in the inclusion of (i) qualitative factors
and examples thereof in the proposed new definition for ``Credit
Risk Rating Matrix'' in Rule 1 and (ii) Members that are foreign
banks or trust companies that have audited financial data that is
publicly available in Section 4(b)(i) of Rule 2B.
---------------------------------------------------------------------------
II. Clearing Agency's Statement of the Purpose of, and Statutory Basis
for, the Advance Notice
In its filing with the Commission, the clearing agency 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. The clearing agency has prepared summaries, set forth in
sections A and B below, of the most significant aspects of such
statements.
(A) Clearing Agency's Statement on Comments on the Advance Notice
Received From Members, Participants, or Others
Written comments relating to this proposal have not been solicited
or received. NSCC will notify the Commission of any written comments
received by NSCC.
(B) Advance Notice Filed Pursuant to Section 806(e) of the Payment,
Clearing and Settlement Supervision Act
Nature of the Proposed Change
The proposed rule change would, among other things, enhance the
CRRM to enable it to rate Members that are foreign banks or trust
companies and have audited financial data that is publicly available.
It would also enhance the CRRM by allowing it to take into account
qualitative factors when generating credit ratings for Members. In
addition, it would enhance the CRRM by shifting it from a relative
scoring approach to an absolute scoring approach.
This rule filing also contains proposed rule changes that are not
related to the proposed CRRM enhancements but that provide specificity,
clarity and additional transparency to the Rules related to NSCC's
current ongoing membership monitoring process.
(i) Background
NSCC occupies an important role in the securities settlement system
by interposing itself as a central counterparty between Members that
are counterparties to transactions accepted for clearing by NSCC,
thereby reducing the risk faced by Members. NSCC uses the CRRM, the
Watch List (as defined below) and the enhanced surveillance to manage
and monitor default risks of Members on an ongoing basis, as discussed
below. The level and frequency of such monitoring for a Member is
determined by the Member's risk of default as assessed by NSCC. Members
that are deemed by NSCC to pose a heightened risk to NSCC and its
Members are subject to closer and more frequent monitoring.
Existing Credit Risk Rating Matrix
In 2005, the Commission approved a proposed rule change filed by
NSCC (``Initial Filing'') \6\ to establish new criteria for placing
certain Members on a list for closer monitoring (``Watch List'').
---------------------------------------------------------------------------
\6\ See Securities Exchange Act Release No. 51362 (March 11,
2005), 70 FR 13562 (March 21, 2005) (SR-NSCC-2003-11).
---------------------------------------------------------------------------
NSCC proposed in the Initial Filing that all U.S. broker-dealers
and U.S. banks that were Members would be assigned a rating generated
by entering financial data of those Members into an internal risk
assessment matrix, i.e., the CRRM. However, the text of the current
Rule 2B, Section 4, does not specify which Members are CRRM-Rated
Members and whether non-CRRM-Rated
[[Page 17922]]
Members may be included on the Watch List.
Currently, Members that are U.S. broker-dealers and U.S. banks are
assessed against the CRRM and assigned a credit rating based on certain
quantitative factors.\7\ Unfavorably-rated Members are placed on the
Watch List. In addition, NSCC credit risk staff may downgrade a
particular Member's credit rating based on various qualitative factors.
An example of such qualitative factors might be that the Member in
question received a qualified audit opinion on its annual audit. NSCC
believes that, in order to protect NSCC and its other Members, it is
important that credit risk staff maintain the discretion to downgrade a
Member's credit rating on the CRRM and thus subject the Member to
closer monitoring.
---------------------------------------------------------------------------
\7\ Quantitative factors considered by NSCC include (a) for
broker dealers, size (i.e., total excess net capital), capital,
leverage, liquidity, and profitability and (b) for banks, size,
capital, asset quality, earnings, and liquidity.
---------------------------------------------------------------------------
The current CRRM is comprised of two credit rating models--one for
the U.S. broker-dealers and one for the U.S. banks--and generates
credit ratings for the relevant Members based on a 7-point rating
system, with ``1'' being the strongest credit rating and ``7'' being
the weakest credit rating.
Over time, the current CRRM has not kept pace with NSCC's evolving
membership base and heightened expectations from regulators and
stakeholders for robustness of financial models. Specifically, the
current CRRM only generates credit ratings for those Members that are
U.S. banks or U.S. broker-dealers that file standard reports with their
regulators. Although these types of Members currently represent the
vast majority (approximately 95%) of Members at NSCC,\8\ foreign banks
and trust companies are expected to be a growing category of NSCC's
membership base in the future, and the proposed enhancements to the
CRRM would enable it to assign credit ratings to these entities.
Foreign banks and trust companies are typically large global financial
institutions that have complex businesses and conduct a high volume of
activities. Although foreign banks and trust companies are not
currently rated by the CRRM, they are monitored by NSCC's credit risk
staff using financial criteria deemed relevant by NSCC and can be
placed on the Watch List if they experience a financial change that
presents risk to NSCC. Given the potential increase in the number of
Members that are foreign banks or trust companies in the coming years,
there is a need to formalize NSCC's credit risk evaluation process of
these Members by assigning credit ratings to them in order to better
facilitate the comparability of credit risks among Members.\9\
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\8\ As of March 16, 2017, there are 155 Members. Of the 155
Members, 11 (or 7%) are U.S. banks, 136 (or 88%) are U.S. broker-
dealers and one (or 1%) is a foreign bank or trust company.
\9\ CRRM is applied across NSCC and its affiliated clearing
agencies, Fixed Income Clearing Corporation (``FICC'') and The
Depository Trust Company (``DTC''). Specifically, in order to run
the CRRM, credit risk staff uses the financial data of the
applicable NSCC Members in addition to data of applicable members
and participants of FICC and DTC, respectively. In this way, each
applicable NSCC Member is rated against other applicable members and
participants of FICC and DTC, respectively.
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In addition, the current CRRM assigns each Member that is a U.S.
bank or U.S. broker-dealer and that files standard reports with its
regulator(s) a credit rating based on inputting certain quantitative
data relative to the applicable Member into the CRRM. Accordingly, a
Member's credit rating is currently based solely upon quantitative
factors. It is only after the CRRM has generated a credit rating with
respect to a particular Member that such Member's credit rating may be
downgraded manually by credit risk staff, after taking into
consideration relevant qualitative factors. The inability of the
current CRRM to take into account qualitative factors requires frequent
and manual overrides by credit risk staff, which may result in
inconsistent and/or incomplete credit ratings for Members.
Furthermore, the current CRRM uses a relative scoring approach and
relies on peer grouping of Members to calculate the credit rating of a
Member. This approach is not ideal because a Member's credit rating can
be affected by changes in its peer group even if the Member's financial
condition is unchanged.
Proposed Credit Risk Rating Matrix Enhancements
To improve the coverage and the effectiveness of the current CRRM,
NSCC is proposing three enhancements. The first proposed enhancement
would expand the scope of CRRM coverage by enabling the CRRM to
generate credit ratings for Members that are foreign banks or trust
companies and that have audited financial data that is publicly
available. The second proposed enhancement would incorporate
qualitative factors into the CRRM and therefore is expected to reduce
the need and the frequency of manual overrides of Member credit
ratings. The third enhancement would replace the relative scoring
approach currently used by CRRM with a statistical approach to estimate
the absolute probability of default of each Member.
A. Enable the CRRM to Generate Credit Ratings for Foreign Bank or Trust
Company Members
The current CRRM is comprised of two credit rating models--one for
the U.S. broker-dealers and one for the U.S. banks. NSCC is proposing
to enhance the CRRM by adding an additional credit rating model for the
foreign banks and trust companies. The additional model would expand
the membership classes to which the CRRM would apply to include Members
that are foreign banks or trust companies and that have audited
financial data that is publicly available. The CRRM credit rating of a
Member that is a foreign bank or trust company would be based on
quantitative factors, including size, capital, leverage, liquidity,
profitability and growth, and qualitative factors, including market
position and sustainability, information reporting and compliance,
management quality, capital management and business/product diversity.
By enabling the CRRM to generate credit ratings for these Members, the
enhanced CRRM would provide more comprehensive credit risk coverage of
NSCC's membership base.
With the proposed enhancement to the CRRM as described above,
applicable foreign bank or trust company Members would be included in
the CRRM process and be evaluated more effectively and efficiently
because financial data with respect to these foreign bank or trust
company Members could be extracted from data sources in an automated
form.\10\
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\10\ Currently, these Members are monitored by NSCC credit risk
staff that review similar criteria as those reviewed for CRRM-Rated
Members, but such review occurs outside of the CRRM process.
---------------------------------------------------------------------------
After the proposed enhancement, CRRM would be able to generate
credit ratings on an ongoing basis for all Members that are U.S. banks,
U.S. brokers-dealers and foreign banks and trust companies, which
together represent approximately 96% of the NSCC Members.\11\
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\11\ As of March 16, 2017, there are 7 Members that would not be
rated by the enhanced CRRM, as proposed, because they are central
securities depositories, securities exchanges and U.S. trust
companies that do not file Call Reports (as defined below).
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B. Incorporate Qualitative Factors Into the CRRM
In addition, as proposed, the enhanced CRRM would blend qualitative
factors with quantitative factors to produce a credit rating for each
applicable Member in relation to
[[Page 17923]]
the Member's credit risk. For U.S. and foreign banks and trust
companies, the enhanced CRRM would use a 70/30 weighted split between
quantitative and qualitative factors to generate credit ratings. For
U.S. broker-dealers, the weight split between quantitative and
qualitative factors would be 60/40. These weight splits are chosen by
NSCC based on the industry best practice as well as research and
sensitivity analysis conducted by NSCC. NSCC would review and adjust
the weight splits as well as the quantitative and qualitative factors,
as needed, based on recalibration of the CRRM to be conducted by NSCC
approximately every three to five years.
Although there are advantages to measuring credit risk
quantitatively, quantitative evaluation models alone are incapable of
fully capturing all credit risks. Certain qualitative factors may
indicate that a Member is or will soon be undergoing financial
distress, which may in turn signal a higher default exposure to NSCC
and its other Members. As such, a key enhancement being proposed to the
CRRM is the incorporation of relevant qualitative factors into each of
the three credit rating models mentioned above. By including
qualitative factors in the three credit rating models, the enhanced
CRRM would capture risks that would otherwise not be accounted for with
quantitative factors alone.\12\ Adding qualitative factors to the CRRM
would not only enable it to generate more consistent and comprehensive
credit ratings for applicable Members, but it would also help reduce
the need and frequency of manual credit rating overrides by the credit
risk staff because overrides would likely only be required under more
limited circumstances.\13\
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\12\ The initial set of qualitative factors that would be
incorporated into the CRRM includes (a) for U.S. broker dealers,
market position and sustainability, management quality, capital
management, liquidity management, geographic diversification,
business/product diversity and access to funding, (b) for U.S.
banks, environment, compliance/litigation, management quality,
liquidity management and parental demands and (c) for foreign banks
and trust companies, market position and sustainability, information
reporting and compliance, management quality, capital management and
business/product diversity.
\13\ Once a Member is assigned a credit rating, if circumstances
warrant, credit risk staff would still have the ability to override
the CRRM-issued credit rating by manually downgrading such rating as
they do today. To ensure a conservative approach, the CRRM-issued
credit ratings cannot be manually upgraded.
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C. Shifting From Relative Scoring to Absolute Scoring
As proposed, the enhanced CRRM would use an absolute scoring
approach and rank each Member based on its individual probability of
default rather than the relative scoring approach that is currently in
use. This proposed change is designed to have a Member's CRRM-generated
credit rating reflect an absolute measure of the Member's default risk
and eliminate any potential distortion of a Member's credit rating from
the Member's peer group that may occur under the relative scoring
approach used in the existing CRRM.
D. Watch List and Enhanced Surveillance
In addition to the Watch List, NSCC also maintains an enhanced
surveillance list (referenced herein and in the proposed rule text as
``enhanced surveillance'') for membership monitoring. The enhanced
surveillance list is generally used when Members are undergoing drastic
and unexpected changes in their financial conditions or operation
capabilities and thus are deemed by NSCC to be of the highest risk
level and/or warrant additional scrutiny due to NSCC's ongoing concerns
about these Members. Accordingly, Members that are subject to enhanced
surveillance are reported to NSCC's management committees and are also
regularly reviewed by a cross-functional team comprised of senior
management of NSCC. More often than not, Members that are subject to
enhanced surveillance are also on the Watch List. The group of Members
that is subject to enhanced surveillance is generally much smaller than
the group on the Watch List. The enhanced surveillance list is an
internal tool for NSCC that triggers increased monitoring of a Member
above the monitoring that occurs when a Member is on the Watch List.
A Member could be placed on the Watch List either based on its
credit rating of 5, 6 or 7, which can either be generated by the CRRM
or from a manual downgrade, or when NSCC deems such placement as
necessary to protect NSCC and its Members. In contrast, a Member would
be subject to enhanced surveillance only when close monitoring of the
Member is deemed necessary to protect NSCC and its Members.
The Watch List and enhanced surveillance tools are not mutually
exclusive; they may complement each other under certain circumstances.
A key distinction between the Watch List and enhanced surveillance is
that being placed on the Watch List may result in Required Deposit \14\
related consequences under the Rules, whereas enhanced surveillance
does not.\15\ For example, a Member that is in a precarious situation
could be placed on the Watch List and be subject to enhanced
surveillance; however, because the Watch List status could increase a
Member's Required Deposit, when NSCC has preliminary concerns about a
Member, to avoid potential increase to a Member's Required Deposit,
NSCC may opt not to place the Member on the Watch List until it is
certain that such concerns would not be alleviated in the short-term.
Instead, in such a situation, NSCC might first subject the Member to
enhanced surveillance in order to closely monitor the Member's
situation without affecting the Member's Required Deposit. If the
Member's situation improves, then it will no longer be subject to
enhanced surveillance. If the situation of the Member worsens, the
Member may then be placed on the Watch List as deemed necessary by
NSCC.
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\14\ See Rule 4 (Section 1). The ``Required Deposit'' is the
amount that each Member is required to deposit in NSCC's Clearing
Fund. Rules, supra note 4.
\15\ NSCC expects to provide additional clarity to Members
regarding the Watch List and its impact on Required Deposit in a
subsequent proposed rule change to be filed with the Commission in
2017.
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(ii) Detailed Description of the Proposed Rule Changes Related to the
Proposed CRRM Enhancements
In connection with the proposed enhancements to the CRRM, NSCC
proposes to amend the Rules to (1) incorporate qualitative factors into
CRRM and (2) add Members that are foreign banks or trust companies to
the categories of Members that would be assigned credit ratings by NSCC
using the CRRM.
A. Proposed Changes to Rule 1 (Definitions and Descriptions)
NSCC is proposing to include qualitative factors, such as
management quality, market position/environment, and capital and
liquidity risk management in the proposed new definition for ``Credit
Risk Rating Matrix'' in Rule 1 because, as proposed, the enhanced CRRM
would blend both qualitative factors and quantitative factors to
produce a credit rating for each applicable Member.
B. Proposed Changes to Section 4(b)(i) of Rule 2B (Ongoing Membership
Requirements and Monitoring)
NSCC is proposing to expand the membership types to which the CRRM
would apply to include Members that are foreign banks or trust
companies and that have audited financial data that is
[[Page 17924]]
publicly available by amending Section 4 of Rule 2B.
The enhanced CRRM would assign credit ratings for each Member that
is a foreign bank or trust company based on its publicly available
audited financial data. The credit rating would be based on an 18-point
scale, which is then mapped to the 7-point rating system currently in
use today, with ``1'' being the strongest credit rating and ``7'' being
the weakest credit rating.
(iii) Other Proposed Rule Changes
This rule filing also contains proposed rule changes that are
unrelated to the proposed enhancement of the CRRM. These proposed rule
changes would provide specificity, clarity and additional transparency
to the Rules with respect to NSCC's current ongoing membership
monitoring process, as described below.
A. Proposed Changes to Rule 1 (Definitions and Descriptions)
NSCC is proposing to amend Rule 1 to add definitions for the CRRM
and the Watch List.
The proposed definition of the CRRM would provide that the term
``Credit Risk Rating Matrix'' means a matrix of credit ratings of
Members as specified in Section 4 of Rule 2B. The definition would
state that the CRRM is developed by NSCC to evaluate the credit risk
such Members pose to NSCC and its Members and is based on factors
determined to be relevant by NSCC from time to time, which factors are
designed to collectively reflect the financial and operational
condition of a Member. The proposed definition would state that, in
addition to the proposed qualitative factors described above, these
factors include quantitative factors, such as capital, assets, earnings
and liquidity.
The proposed definition of the Watch List would provide that the
term ``Watch List'' means, at any time and from time to time, the list
of Members whose credit ratings derived from the CRRM are 5, 6 or 7, as
well as Members and Limited Members that, based on NSCC's consideration
of relevant factors, including those set forth in Section 4(d) of Rule
2B (described below), are deemed by NSCC to pose a heightened risk to
NSCC and its Members.
B. Proposed Changes to Rule 2B (Ongoing Membership Requirements and
Monitoring)
Section 2B of Rule 2B
NSCC is proposing to amend Section 2B of Rule 2B to state that NSCC
may review the financial responsibility and operational capability of
each Member and may otherwise require additional reporting from the
Member regarding its financial or operational condition that may (1)
include information regarding the businesses and operations of the
Member and its risk management practices with respect to NSCC's
services utilized by the Member for another Person and (2) result in
the Member being placed on the Watch List and/or being subject to
enhanced surveillance as determined by NSCC.
Members are direct participants of NSCC. However, there are firms
that rely on the services provided by Members in order to have their
activity cleared and settled through NSCC's facilities (the ``indirect
participants''). These indirect participants pose certain risks to NSCC
that need to be identified and monitored as part of NSCC's ongoing
member due diligence process. In order for NSCC to understand (1) the
material dependencies between Members and the indirect participants
that rely on the Members for the clearance and settlement of the
indirect participants' transactions, (2) significant Member-indirect
participant relationships and (3) the various risk controls and
mitigants that these Members employ to manage their risks with respect
to such relationships, NSCC may request information from Members
regarding the Members' businesses and operations as well as their risk
management practices with respect to services of NSCC utilized by the
Members for indirect participants. The information provided by Members
would then be taken into consideration by NSCC when determining whether
a Member may need to be placed on the Watch List, be subject to
enhanced surveillance or both.
Section 4 of NSCC Rule 2B
NSCC is proposing to amend Section 4 of Rule 2B in order to (1)
specify the membership types that are currently subject to NSCC's
ongoing monitoring and review, (2) clarify which U.S. broker-dealers
and U.S. banks will be assigned a credit rating by NSCC in accordance
with the CRRM, (3) provide that NSCC may manually downgrade a CRRM-
Rated Member's credit rating in certain instances, (4) provide that
NSCC may place non-CRRM-Rated Members and certain Limited Members on
the Watch List and/or subject them to enhanced surveillance, if
necessary, (5) describe some of the factors that could be taken into
consideration by NSCC when downgrading a Member's or Limited Member's
credit rating, placing a Member or Limited Member on the Watch List
and/or subjecting a Member or Limited Member to enhanced surveillance,
(6) allow NSCC to collect additional deposits to the Clearing Fund and
to retain deposits in excess of the Required Deposit from Members or
Limited Members that are on the Watch List and (7) provide for enhanced
monitoring of Members or Limited Members that are on the Watch List
and/or are subject to enhanced surveillance.
In connection with the forgoing, NSCC proposes to delete the
current first paragraph in Section 4 of NSCC Rule 2B and add the
following:
1. Section 4(a), specifying that NSCC currently monitors and
reviews all Members and certain Limited Members on an ongoing and
periodic basis, which may include monitoring news and market
developments relating to these Members and Limited Members and
conducting reviews of financial reports and other public information of
these Members and Limited Members.
2. Section 4(b)(i), clarifying that (1) Members that are (A) U.S.
banks or trust companies that file the Consolidated Report of Condition
and Income (``Call Report'') or (B) U.S. broker-dealers that file the
Financial and Operational Combined Uniform Single Report (``FOCUS
Report'') or the equivalent with their regulators, would be assigned a
credit rating by NSCC in accordance with the CRRM and (2) each CRRM-
Rated Member's credit rating would be reassessed upon receipt of
additional information from the Member.
3. Section 4(b)(ii), providing that, because the factors used as
part of the CRRM may not identify all risks that a Member may pose to
NSCC, NSCC may, in addition to other actions permitted by the Rules,
downgrade the Member's credit rating derived from the CRRM if NSCC
believes the CRRM-generated rating is insufficiently conservative or if
it deems such downgrade as necessary to protect NSCC and its Members.
Depending on the credit rating of the Member, a downgrade may result in
the Member being placed on the Watch List and/or being subject to
enhanced surveillance based on relevant factors.
4. Section 4(c), specifying that, other than CRRM-Rated Members,
NSCC may place Members and Limited Members that are monitored and
reviewed by NSCC on the Watch List and/or subject them to enhanced
surveillance even though they are not being assigned credit ratings by
NSCC in accordance with the CRRM.
5. Section 4(d), describing some of the factors that could be taken
into consideration by NSCC when downgrading a Member's credit rating,
placing a Member or Limited Member on the Watch List and/or subjecting
a
[[Page 17925]]
Member or Limited Member to enhanced surveillance. These factors
include but are not limited to (i) news reports and/or regulatory
observations that raise reasonable concerns relating to the Member or
Limited Member, (ii) reasonable concerns around the Member's or Limited
Member's liquidity arrangements, (iii) material changes to the Member's
or Limited Member's organizational structure, (iv) reasonable concerns
of NSCC about the Member's or Limited Member's financial stability due
to particular facts and circumstances, such as material litigation or
other legal and/or regulatory risks, (v) failure of the Member or
Limited Member to demonstrate satisfactory financial condition or
operational capability or if NSCC has a reasonable concern regarding
the Member's or Limited Member's ability to maintain applicable
membership standards and (vi) failure of the Member or Limited Member
to provide information required by NSCC to assess risk exposures posed
by the Member's or Limited Member's activity.
6. Section 4(e), allowing NSCC to (1) require a Member or Limited
Member that has been placed on the Watch List to make and maintain
additional deposits to the Clearing Fund and (2) withhold any deposit
in excess of the Required Deposit of a Member or Limited Member that
has been placed on the Watch List as provided in Section 9 of Rule 4.
7. Section 4(f), providing that NSCC would, in addition to other
actions permitted by the Rules, conduct a more thorough monitoring of
the financial condition and/or operational capability of, and require
more frequent financial disclosures from, not only those Members and
Limited Members that are placed on the Watch List but also Members and
Limited Members subject to enhanced surveillance, including examples of
how the monitoring could be conducted and the types of disclosures that
may be required. In addition, Members and Limited Members that are
subject to enhanced surveillance would be reported to NSCC's management
committees and regularly reviewed by a cross-functional team comprised
of senior management of NSCC.
In addition to the proposed changes described above, NSCC is
proposing to make technical corrections to the second paragraph of
Section 4 of Rule 2B to (1) renumber the paragraph as Section 4(g), (2)
update an internal cross reference and (3) clarify that the references
in the paragraph to Members under surveillance are referring to Members
on the Watch List.
C. Proposed Changes to Rule 4 (Clearing Fund)
NSCC is proposing to amend Section 9 of Rule 4 to clarify that NSCC
may, in its discretion, withhold all or part of any excess Clearing
Fund deposit of Members that are on the Watch List.
D. Proposed Changes to Procedure XV (Clearing Fund Formula and Other
Matters)
NSCC is proposing to amend Section I(B)(1) of Procedure XV to
clarify that Members or Limited Members that are placed on the Watch
List would be required to make additional Clearing Fund deposits, as
determined by NSCC.
In addition, NSCC is proposing to make the following technical
corrections to Section I(B)(1) of Procedure XV, (i) renumber the final
three paragraphs as Section I(B)(2) and title the new subsection
``Family Issued Securities'' to reflect the different subject matter of
the new subsection, (ii) capitalize references to the Credit Risk
Rating Matrix to reflect the proposed addition of the defined term to
Rule 1 and (iii) make other grammatical corrections to the new Section
I(B)(2).
Finally, NSCC is proposing to amend Section II(C) of Procedure XV
to clarify that, although NSCC would not request additional Clearing
Fund deposits from Members unless they exceed a predetermined
threshold, such floor would not apply to Members or Limited Members
that are on the Watch List.
E. Additional Proposed Changes to Rule 1 (Definitions and Descriptions)
and Procedure XV (Clearing Fund Formula and Other Matters)
NSCC is proposing to amend the definition of ``Illiquid Position''
in Rule 1 as well as Procedure XV Sections I(A)(1) and I(A)(2), each as
proposed in connection with a separate proposed rule change filed with
the Commission but not yet approved.\16\ Specifically, the proposed
amendments would replace and conform references to ``credit risk
matrix'' with ``Credit Risk Rating Matrix'' in the proposed definition
of ``Illiquid Position'' in Rule 1 as well as Procedure XV Sections
I(A)(1) and I(A)(2).
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\16\ See Securities Exchange Act Release No. 80260 (March 16,
2017), 82 FR 14781 (March 22, 2017) (SR-NSCC-2017-001).
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Implementation Timeframe
Pending Commission approval, NSCC expects to implement this
proposal promptly. Members would be advised of the implementation date
of this proposal through issuance of a NSCC Important Notice.
Expected Effect on Risks to the Clearing Agency, Its Participants and
the Market
The proposed rule changes would mitigate counterparty credit risk
for NSCC by allowing NSCC to more accurately monitor the
creditworthiness and risk profile of its Members. The enhanced CRRM
would provide a more robust credit rating methodology by incorporating
qualitative factors and adopting an absolute scoring approach. Both of
these enhancements would improve NSCC's ability to monitor the credit
risk of its Members and are expected to lessen the frequency of manual
overrides. The enhanced CRRM would also expand the coverage of NSCC's
membership by providing credit ratings for Members that are foreign
banks or trust companies, which are not covered under the existing
CRRM.
By mitigating counterparty credit risk for NSCC as described above,
the enhanced CRRM would also mitigate risk for Members because lowering
the risk profile for NSCC would in turn lower the risk exposure that
Members may have with respect to NSCC in its role as a central
counterparty.
Management of Identified Risks
The proposed rule changes are designed to mitigate counterparty
credit risk for NSCC and to provide greater clarity and transparency to
Members regarding the counterparty credit risk management approach used
by NSCC.
The enhanced CRRM would improve NSCC's ability to monitor the
probability of default for Members that are rated by the CRRM and is
expected to lessen the need and the frequency of manual downgrades due
to the anticipated improvement in the accuracy of the credit ratings
generated by the enhanced CRRM.
NSCC employs a risk-based approach to conducting monitoring and
review of its Members by using the CRRM to identify higher risk
Members. Once identified, NSCC would place these Members on the Watch
List, which would result in more frequent review by NSCC of these
Members than the other Members. For Members that are placed on the
Watch List, NSCC would conduct more thorough monitoring of these
Members' financial condition and/or operational capability, which could
include, for example, on-site visits or additional due diligence
information requests.
Members that have been placed on the Watch List may also be
required to maintain a higher deposit to the Clearing Fund, which would
help offset potential risks to NSCC and its Members arising from
activity submitted by these Members.
[[Page 17926]]
The enhanced CRRM would also expand the coverage of NSCC's
membership by providing credit ratings for foreign banks and trust
companies, which are not currently rated under the existing CRRM. The
addition of these entities would allow NSCC to employ its risk-based
approach to identify those higher risk Members for additional
monitoring with more efficiency (by reducing the need for manual
overrides) and effectiveness (by generating a more comprehensive and
accurate credit rating after taking into account both quantitative and
qualitative factors and adopting the absolute scoring approach).
Thus, the enhanced CRRM would help NSCC to identify those Members
that could present credit risk to NSCC, which then would allow NSCC to
better manage the potential risks from these Members.
Consistency With the Clearing Supervision Act
The proposed enhancements to the CRRM as described in detail above
would be consistent with Section 805(b) of Clearing Supervision
Act.\17\ The objectives and principles of Section 805(b) of the
Clearing Supervision Act include, among other things, the promotion of
robust risk management.\18\
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\17\ 12 U.S.C. 5464(b).
\18\ Id.
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By enhancing the CRRM to enable it to assign credit ratings to
Members that are foreign banks or trust companies and that have audited
financial data that is publicly available, the proposed rule change
would expand the CRRM's applicability to a wider group of Members,
which would improve NSCC's membership monitoring process and promote
robust risk management, consistent with the objectives and principles
of Section 805(b) of the Clearing Supervision Act cited above.
Similarly, by enhancing the CRRM to enable it to incorporate
qualitative factors when assigning a Member's credit rating, the
proposed change would enable NSCC to take into account relevant
qualitative factors in an automated and more effective manner when
monitoring the credit risks presented by the Members, which would
improve NSCC's membership monitoring process overall and promote robust
risk management, consistent with the objectives and principles of
Section 805(b) of the Clearing Supervision Act cited above.
Likewise, by enhancing the CRRM to shift from a relative scoring
approach to an absolute scoring approach when assigning a Member's
credit rating, the proposed rule change would enable NSCC to generate
credit ratings for Members that are more reflective of the Members'
default risk, which would improve NSCC's membership monitoring process
and promote robust risk management, consistent with the objectives and
principles of Section 805(b) of the Clearing Supervision Act cited
above.
The proposed enhancements to the CRRM are consistent with Rule
17Ad-22(e)(3)(i) under the Act, which was recently adopted by the
Commission.\19\ Rule 17Ad-22(e)(3)(i) will require NSCC to establish,
implement, maintain and enforce written policies and procedures
reasonably designed to maintain a sound risk management framework for
comprehensively managing risks that arise in or are born by NSCC, which
includes * * * systems designed to identify, measure, monitor and
manage the range of risks that arise in or are borne by NSCC.\20\ The
proposed enhancements to the CRRM have been designed to assist NSCC in
identifying, measuring, monitoring and managing the credit risks to
NSCC posed by its Members. The proposed enhancements to the CRRM
accomplish this by (i) expanding the CRRM's applicability to a wider
group of Members to include Members that are foreign banks or trust
companies, (ii) enabling the CRRM to take into account relevant
qualitative factors in an automated and more effective manner when
monitoring the credit risks presented by Members and (iii) enabling the
CRRM to generate credit ratings for Members that are more reflective of
the Members' default risk by shifting to an absolute scoring approach,
all of which would improve NSCC's membership monitoring process
overall. Therefore, NSCC believes the proposed enhancements to the CRRM
would assist NSCC in identifying, measuring, monitoring and managing
risks that arise in or are born by NSCC, consistent with the
requirements of Rule 17Ad-22(e)(3)(i).
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\19\ 17 CFR 240.17Ad-22(e)(3)(i). The Commission adopted
amendments to Rule 17Ad-22, including the addition of new subsection
17Ad-22(e), on September 28, 2016. See Securities Exchange Act
Release No. 78961 (September 28, 2016), 81 FR 70786 (October 13,
2016) (S7-03-14). FICC is a ``covered clearing agency'' as defined
by the new Rule 17Ad-22(a)(5) and must comply with new subsection
(e) of Rule 17Ad-22 by April 11, 2017. Id.
\20\ Id.
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The proposed rule change to Section 2B of Rule 2B with respect to
the scope of information that may be requested by NSCC from its Members
has been designed to be consistent with Rule 17Ad-22(e)(19) under the
Act, which was recently adopted by the Commission.\21\ Rule 17Ad-
22(e)(19) will require NSCC to establish, implement, maintain and
enforce written policies and procedures reasonably designed to
identify, monitor, and manage the material risk to NSCC arising from
arrangements in which firms that are indirect participants in NSCC rely
on the services provided by Members to access NSCC's payment, clearing,
or settlement facilities.\22\ By expressly reflecting in the Rules what
is already NSCC's current practice associated with its request for
additional reporting of a Member's financial or operational conditions
to state that such request may include information regarding the
businesses and operations of the Member, as well as its risk management
practices with respect to services of NSCC utilized by the Member for
another Person, this proposed rule change would help enable NSCC to
have rule provisions that are reasonably designed to identify, monitor
and manage the material risks to NSCC arising from tiered participation
arrangements consistent with Rule 17Ad-22(e)(19).
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\21\ 17 CFR 240.17Ad-22(e)(19). Id.
\22\ Id.
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III. Date of Effectiveness of the Advance Notice, and Timing for
Commission Action
The proposed change may be implemented if the Commission does not
object to the proposed change within 60 days of the later of (i) the
date that the proposed change was filed with the Commission or (ii) the
date that any additional information requested by the Commission is
received. The clearing agency shall not implement the proposed change
if the Commission has any objection to the proposed change.
The Commission may extend the period for review by an additional 60
days if the proposed change raises novel or complex issues, subject to
the Commission providing the clearing agency with prompt written notice
of the extension. A proposed change may be implemented in less than 60
days from the date the advance notice is filed, or the date further
information requested by the Commission is received, if the Commission
notifies the clearing agency in writing that it does not object to the
proposed change and authorizes the clearing agency to implement the
proposed change on an earlier date, subject to any conditions imposed
by the Commission.
The clearing agency shall post notice on its Web site of proposed
changes that are implemented.
[[Page 17927]]
The proposal shall not take effect until all regulatory actions
required with respect to the proposal are completed.
IV. Solicitation of Comments
Interested persons are invited to submit written data, views and
arguments concerning the foregoing, including whether the Advance
Notice is consistent with the Clearing Supervision 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-NSCC-2017-801 on the subject line.
Paper Comments
Send paper comments in triplicate to Secretary, Securities
and Exchange Commission, 100 F Street NE., Washington, DC 20549.
All submissions should refer to File Number SR-NSCC-2017-801. 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 of NSCC and on DTCC's Web site
(https://dtcc.com/legal/sec-rule-filings.aspx). 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-NSCC-2017-801 and should be submitted on
or before April 28, 2017.
By the Commission.
Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2017-07453 Filed 4-12-17; 8:45 am]
BILLING CODE 8011-01-P