Self-Regulatory Organizations; The Options Clearing Corporation; Notice of No Objection to Advance Notice, as Modified by Amendment No. 1, Concerning the Adoption of a New Minimum Cash Requirement for the Clearing Fund, 2843-2846 [2018-00857]
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Federal Register / Vol. 83, No. 13 / Friday, January 19, 2018 / Notices
with access to the internet or television.
Conversely, the value of such products
to Distributors and investors decreases if
order flow falls, because the products
contain less content.
Competition among trading platforms
can be expected to constrain the
aggregate return each platform earns
from the sale of its joint products, but
different platforms may choose from a
range of possible, and equally
reasonable, pricing strategies as the
means of recovering total costs. The
Exchange pays rebates to attract orders,
charges relatively low prices for market
information and charges relatively high
prices for accessing posted liquidity.
Other platforms may choose a strategy
of paying lower liquidity rebates to
attract orders, setting relatively low
prices for accessing posted liquidity,
and setting relatively high prices for
market information. Still others may
provide most data free of charge and
rely exclusively on transaction fees to
recover their costs. Finally, some
platforms may incentivize use by
providing opportunities for equity
ownership, which may allow them to
charge lower direct fees for executions
and data.
In this environment, there is no
economic basis for regulating maximum
prices for one of the joint products in an
industry in which suppliers face
competitive constraints with regard to
the joint offering. Such regulation is
unnecessary because an ‘‘excessive’’
price for one of the joint products will
ultimately have to be reflected in lower
prices for other products sold by the
firm, or otherwise the firm will
experience a loss in the volume of its
sales that will be adverse to its overall
profitability. In other words, an increase
in the price of data will ultimately have
to be accompanied by a decrease in the
cost of executions, or the volume of both
data and executions will fall.
Indeed, in approving the fees for
TOPO Plus in 2010, the Commission
noted that the Exchange was subject to
competitive pressures in setting its fees
for TOPO Plus. First, the Commission
noted that the Exchange had a
‘‘compelling need’’ to attract order flow,
which imposed ‘‘significant pressure’’
on the Exchange to act reasonably in
setting its fees for PHLX market data,
particularly given that ‘‘the market
participants that will pay such fees
often will be the same market
participants from whom Phlx must
attract order flow.’’ 28 The Commission
also found that there were a number of
alternative sources of information that
imposed significant competitive
pressures on the Exchange in setting the
terms for distributing TOPO Plus. The
Commission found that the availability
of those alternatives, as well as the
Exchange’s compelling need to attract
order flow, imposed ‘‘significant
competitive pressure on Phlx to act
equitably, fairly, and reasonably in
setting the terms of its proposal.’’ 29 The
Exchange believes that the same
analysis and conclusions apply here.
In sum, the proposed fee structure is
designed to ensure a fair and reasonable
use of Exchange resources by allowing
the Exchange to recoup costs while
continuing to offer its data products at
competitive rates to firms
3. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
No written comments were either
solicited or received.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
The foregoing rule change has become
effective pursuant to Section
19(b)(3)(A)(ii) of the Act.30
At any time within 60 days of the
filing of the proposed rule change, the
Commission summarily may
temporarily suspend such rule change if
it appears to the Commission that such
action is: (i) Necessary or appropriate in
the public interest; (ii) for the protection
of investors; or (iii) otherwise in
furtherance of the purposes of the Act.
If the Commission takes such action, the
Commission shall institute proceedings
to determine whether the proposed rule
should be approved or disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
Electronic Comments
• Use the Commission’s internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
Phlx–2018–08 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE,
Washington, DC 20549–1090.
All submissions should refer to File
Number SR–Phlx–2018–08. 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 website (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 website 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.
Persons submitting comments are
cautioned that we do not redact or edit
personal identifying information from
comment submissions. You should
submit only information that you wish
to make available publicly. All
submissions should refer to File
Number SR–Phlx–2018–08, and should
be submitted on or before February 9,
2018.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.31
Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2018–00852 Filed 1–18–18; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–82501; File No. SR–OCC–
2017–808]
Self-Regulatory Organizations; The
Options Clearing Corporation; Notice
of No Objection to Advance Notice, as
Modified by Amendment No. 1,
Concerning the Adoption of a New
Minimum Cash Requirement for the
Clearing Fund
January 12, 2018.
The Options Clearing Corporation
(‘‘OCC’’) filed on November 14, 2017
29 Id.
28 See
TOPO Plus approval order, 75 FR at 31833.
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CFR 200.30–3(a)(12).
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Federal Register / Vol. 83, No. 13 / Friday, January 19, 2018 / Notices
with the Securities and Exchange
Commission (‘‘Commission’’) advance
notice SR–OCC–2017–808 (‘‘Advance
Notice’’) pursuant to Section 806(e)(1) of
the Payment, Clearing, and Settlement
Supervision Act of 2010 (‘‘Payment,
Clearing and Settlement Supervision
Act’’) 1 and Rule 19b–4(n)(1)(i) under
the Securities Exchange Act of 1934
(‘‘Exchange Act’’) 2 to propose a new
minimum cash contribution
requirement for its Clearing Fund 3
(‘‘Cash Clearing Fund Requirement’’)
and also provide for the pass-through of
interest income earned on such deposits
to its Clearing Members. The proposed
changes are intended to enhance OCC’s
liquidity risk management by increasing
the amount of qualifying liquid
resources available, as well as to
provide for a more consistent level of
cash available in its prefunded financial
resources. The Advance Notice was
published for comment in the Federal
Register on December 14, 2017.4 The
Commission did not receive any
comments on the Advance Notice. This
publication serves as notice of no
objection to the Advance Notice.
I. Background
OCC maintains a Clearing Fund,
composed of contributions required to
be made by all Clearing Members, to
make good losses suffered by OCC
under a number of circumstances,
including the default or failure of a
Clearing Member to make good on any
obligation for which OCC may be
responsible in the exercise of its duties
as a central counterparty. Presently,
Article VIII, Section 3(a) of OCC’s ByLaws provides that Clearing Fund
contributions shall be in the form of
cash and Government securities, but
neither OCC’s By-Laws nor Rules
provides a minimum cash requirement
for contributions to the Clearing Fund.
Article VIII, Section 4(a) of OCC’s ByLaws allows for OCC to invest cash
contributions to the Clearing Fund,
partially or wholly, in OCC’s account in
Government securities, and to the extent
that such contributions are not so
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1 12
U.S.C. 5465(e)(1). The Financial Stability
Oversight Council designated OCC a systemically
important financial market utility (‘‘SIFMU’’) on
July 18, 2012. See Financial Stability Oversight
Council 2012 Annual Report, Appendix A, https://
www.treasury.gov/initiatives/fsoc/Documents/
2012%20Annual%20Report.pdf. Therefore, OCC is
required to comply with the Payment, Clearing and
Settlement Supervision Act and file advance
notices with the Commission.
2 17 CFR 240.19b–4(n)(1)(i).
3 Unless specified otherwise, capitalized terms
shall have the meaning OCC ascribes in its By-Laws
and Rules.
4 Exchange Act Release No. 34–82247 (Dec. 8,
2017), 82 FR 59031 (Dec. 14, 2017) (‘‘Notice of
Filing of Advance Notice’’).
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invested, they shall be deposited by
OCC in a separate account or accounts
for Clearing Fund contributions in
approved custodians. Article VIII,
Section 4(a) of OCC’s By-Laws,
however, presently does not account for
the treatment of interest earned on cash
deposits held in OCC’s bank account at
the Federal Reserve.
II. Description of the Advance Notice
A. Proposed Change To Establish the
Cash Clearing Fund Requirement
OCC proposes to establish a Cash
Clearing Fund Requirement for its
Clearing Fund to increase the amount of
qualifying liquid resources available to
OCC to account in the event there is an
extreme scenario in the financial
markets and OCC has to address any
resultant liquidity demands. Further,
the proposal seeks to ensure that OCC
holds, and maintains access to, a more
consistent level of cash clearing fund
resources in its available prefunded
financial resources. Specifically, the
proposed rule change would require
that Clearing Members collectively
contribute $3 billion in cash to the
Clearing Fund. Each Clearing Member’s
proportionate share of the Cash Clearing
Fund Requirement shall be determined
by the current Clearing Fund allocation
methodology in OCC Rule 1001.
OCC’s current liquidity resources are
sized to cover historically observed
liquidity demands and potential
demands based on forecasts with a 12
month time horizon. The sizing
calculations, in turn, are based on the
potential exposure resulting from the
default of a single clearing member.
Further, the current clearing fund is
sized, at a minimum, to ensure that OCC
maintains sufficient collateral to access
its committed liquidity facilities. OCC
represented that it maintains committed
liquidity facilities of $3 billion to cover
its calculated historical and forecasted
demands.5
After analyzing its liquidity demands
in extreme stress scenarios,6 OCC
5 See Exchange Act Release No. 81058 (June 30,
2017), 82 FR 31371 (July 6, 2017) (SR–OCC–2017–
803); Exchange Act Release No. 76641 (December
14, 2015), 80 FR 79114 (December 18, 2015) (SR–
OCC–2015–805). Both facilities allow OCC to obtain
cash in exchange for government securities 60
minutes after notice is given and collateral is
posted.
6 OCC represented that it performed an analysis
of its stress liquidity demands based on a 1-in-70
year hypothetical market event. Specifically, OCC
started its analysis by selecting the largest historical
peak monthly settlements that occurred over the
historical look-back period of data generated by the
stress test system. It then also selected certain large
non-expiration days to supplement the analysis.
From this it estimated the mark-to-market and cash
settled exercise and assignment obligations for the
members driving the historical peak demand under
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determined that it would propose the $3
billion Cash Clearing Fund Requirement
to increase the amount and reliability of
its liquid resources. OCC represented
that, based upon its analysis, the peak
stressed liquidity demands of the largest
or two largest Clearing Members, which
normally occur in conjunction with
certain monthly expirations, could
exceed the capacity of OCC’s current
committed liquidity facilities. Although
OCC believes that it would be able to
cover the resulting shortfall with cash
already present in the Clearing Fund,
OCC stated that it could not rely on
such cash always being available
because, under OCC’s current By-Laws
and Rules, there is no ability for OCC to
ensure that a minimum amount of cash
is maintained in the Clearing Fund at all
times. As a result, OCC believes that the
proposed $3 billion Cash Clearing Fund
Requirement, combined with OCC’s $3
billion of committed liquidity facilities,
would provide liquid resources
sufficient to cover the peak stressed
liquidity demands of the largest one or
two Clearing Members observed in the
analysis.
B. Proposed Change To Allow
Temporary Increase of Cash Clearing
Fund Requirement
The proposed change would also
provide authority for OCC to
temporarily increase the amount of the
Cash Clearing Fund Requirement. OCC’s
Executive Chairman, Chief
Administrative Officer (‘‘CAO’’), or
Chief Operating Officer (‘‘COO’’), would
have the authority, upon providing
notice to the Risk Committee, to
temporarily raise the Cash Clearing
Fund Requirement up to an amount that
includes the size of the Clearing Fund
as determined in accordance with Rule
1001 for the month in question. A
Clearing Member will be required to
satisfy any increase in its required cash
contribution pursuant to an increase in
the Cash Clearing Fund Requirement no
later than one hour before the close of
the Fedwire on the business day
following OCC’s issuance of an
instruction to increase cash
contributions.
In such circumstances, the Risk
Committee, by rule, would be obligated
to review any such temporary increase
as soon as practicable, but in any event
within 20 calendar days of the increase.
In its review, the Risk Committee shall
determine whether (1) the increase in
the minimum Cash Clearing Fund
Requirement is no longer required, or
(2) OCC’s Clearing Fund contribution
the proposed stress tests scenario to determine the
stressed peak demand.
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requirements and other related rules
should be modified to ensure that OCC
continues to maintain sufficient liquid
resources to cover its largest aggregate
payment obligations in extreme but
plausible market conditions. In the
event that the Risk Committee would
determine to permanently increase the
Cash Clearing Fund Requirement, OCC
would initiate any regulatory approval
process required to effect such a
change.7
OCC acknowledged that increasing
the Cash Clearing Fund Requirement
could impose a liquidity constraint on
its clearing members. Accordingly, OCC
has proposed to limit the circumstances
in which it could make such an
increase. By rule, OCC would only be
able to exercise this authority to protect
OCC, its clearing members, or the
general public. Further, any Cash
Clearing Fund Requirement increase
would have to: (i) Be based upon thenexisting facts and circumstances, (ii) be
in furtherance of the integrity of OCC
and the stability of the financial system,
and (iii) take into consideration the
legitimate interests of Clearing Members
and market participants.
These changes would be reflected in
new paragraph (a)(i) of Section 3 of
Article VIII of OCC’s By-Laws, as well
as in new Interpretation and Policy .04
to Section 3 of Article VIII.
C. Proposed Changes to Pass-Through
Interest on Clearing Fund Cash to
Clearing Members
Under the proposal, OCC stated that
substantially all the cash deposits in the
Clearing Fund would be held in an
account established by OCC at a Federal
Reserve Bank. OCC proposes that it
would pass the interest income earned
in such account through to its Clearing
Members. Specifically, OCC proposes to
revise Article VIII, Section 4(a) of OCC’s
By-Laws to provide that any interest
earned on cash deposits held at an
account at the Federal Reserve shall
accrue to the benefit of Clearing
Members (calculated daily based on
each Clearing Member’s pro rata share
of Clearing Fund cash deposits),
provided that such Clearing Members
have provided OCC with all tax
documentation as OCC may from time
to time require in order to effectuate
such payment.
To accommodate the pass through of
interest income, OCC would also amend
7 However, OCC represented that it would not
decrease the Cash Clearing Fund Requirement
while the regulatory approvals for a change in the
Cash Clearing Fund Requirement are being obtained
to ensure that OCC continues to maintain sufficient
liquid resources to cover its liquidity demands
during that time.
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its Fee Policy to add definitions for
‘‘Pass-Through Interest Revenue’’ and
‘‘Operating Expenses’’ to exclude from
the calculation of the Business Risk
Buffer projected interest revenue and
expense, respectively, related to the
pass-through of earned interest from
OCC to Clearing Members.8 OCC also
proposes to add a new example of the
Business Risk Buffer calculation
reflecting this change and make
clarifying changes throughout the policy
to incorporate the use of the new
defined terms. In addition, OCC
proposes to amend the Fee Policy to
remove references to ‘‘Proposed Rule
17Ad–22(e)(15)’’ to reflect the adoption
of the Commission’s Covered Clearing
Agency Standards.
D. Proposed Conforming Changes
In conjunction with the
aforementioned changes, OCC is also
proposing to make four related
conforming changes. First, OCC
proposes to revise Interpretation and
Policy .01 of Rule 1001 to reflect that
the new minimum Clearing Fund size is
$3 billion (instead of $1 billion) plus
110% of the size of OCC’s committed
liquidity facilities, which conforms to
the Cash Clearing Fund Requirement.
Second, OCC proposes to amend the
definition of ‘‘Approved Custodian’’ in
Article I, Section 1 of the By-Laws to
clarify that the Federal Reserve Bank
may also be an Approved Custodian, to
the extent it is available to OCC. Third,
OCC is proposing to delete existing
Article VIII, Section 4(b), regarding the
establishment of a segregated funds
account for cash contributions to the
Clearing Fund. The segregated funds
account allows a Clearing Member to
contribute cash to a bank or trust
company account maintained in the
name of OCC, subject to OCC’s
exclusive control, but the account also
includes the name of the Clearing
Member and any interest accrues to the
Clearing Member rather than OCC. OCC
proposes to eliminate the account type
because Clearing Members have not
expressed interest in using such an
account, no such accounts are in use
today, and moving forward,
substantially all cash Clearing Fund
contributions will held in OCC’s
account at the Federal Reserve Bank.
Fourth, OCC proposes to introduce new
8 While interest income earned by OCC from its
bank account at the Federal Reserve would be
passed on to its Clearing Members, OCC anticipates
that it would charge a cash management fee to cover
associated costs (i.e., administrative and similar
costs). OCC would file a separate proposed rule
change with the Commission, subject to receiving
all necessary regulatory approvals for the proposed
changes described herein, prior to implementing
any cash management fee
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2845
language to Article VIII, Section 4(a) to
clarify that cash contributions to the
Clearing Fund that are deposited at
approved custodians may be
commingled with the Clearing Fund
contributions of different Clearing
Members.
III. Discussion and Commission
Findings
Although the Payment, Clearing and
Settlement Supervision Act does not
specify a standard of review for an
advance notice, the stated purpose is
instructive.9 The stated purpose of the
Payment, Clearing and Settlement
Supervision Act is to mitigate systemic
risk in the financial system and promote
financial stability by, among other
things, promoting uniform risk
management standards for SIFMUs and
strengthening the liquidity of SIFMUs.10
Section 805(a)(2) of the Payment,
Clearing and Settlement Supervision
Act 11 authorizes the Commission to
prescribe regulations containing riskmanagement standards for the payment,
clearing, and settlement activities of
designated clearing entities engaged in
designated activities for which the
Commission is the supervisory agency.
Section 805(b) of the Payment, Clearing
and Settlement Supervision Act 12
provides the following objectives and
principles for the Commission’s riskmanagement standards prescribed under
Section 805(a):
• To promote robust risk
management;
• To promote safety and soundness;
• To reduce systemic risks; and
• To support the stability of the
broader financial system.
Section 805(c) provides, in addition,
that the Commission’s risk-management
standards may address such areas as
risk-management and default policies
and procedures, among others areas.13
The Commission has adopted riskmanagement standards under Section
805(a)(2) of the Payment, Clearing and
Settlement Supervision Act and the
Exchange Act (the ‘‘Clearing Agency
Rules’’).14 The Clearing Agency Rules
9 See
12 U.S.C. 5461(b).
10 Id.
11 12
U.S.C. 5464(a)(2).
U.S.C. 5464(b).
13 12 U.S.C. 5464(c).
14 17 CFR 240.17Ad–22. See Securities Exchange
Act Release No. 68080 (October 22, 2012), 77 FR
66220 (November 2, 2012) (S7–08–11). See also
Securities Exchange Act Release No. 78961
(September 28, 2016), 81 FR 70786 (October 13,
2016) (S7–03–14) (‘‘Covered Clearing Agency
Standards’’). The Commission established an
effective date of December 12, 2016, and a
compliance date of April 11, 2017, for the Covered
Clearing Agency Standards. On March 4, 2017, the
12 12
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Continued
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require each covered clearing agency,
among other things, to establish,
implement, maintain, and enforce
written policies and procedures that are
reasonably designed to meet certain
minimum requirements for operations
and risk-management practices on an
ongoing basis. As such, it is appropriate
for the Commission to review advance
notices for consistency with the
objectives and principles for riskmanagement standards described in
Section 805(b) of the Payment, Clearing
and Settlement Supervision Act and the
Clearing Agency Rules.
A. Consistency With Section 805(b) of
the Payment, Clearing and Settlement
Supervision Act
The Commission believes the
Advance Notice is consistent with the
stated objectives and principles of
Section 805(b) of the Payment, Clearing
and Settlement Supervision Act of
promoting robust risk management,
promoting safety and soundness,
reducing systemic risks, and supporting
the stability of the broader financial
system.15
The Commission believes that the
Cash Clearing Fund Requirement would
enhance OCC’s ability to manage its
liquidity risk exposure, thereby
promoting robust risk management.
Similarly, the Commission believes that
increasing the amount of cash, and
therefore the overall amount of
qualifying liquid resources, available to
cover OCC’s liquidity demands arising
in stressed scenarios is consistent with
promoting safety and soundness. Based
on the analysis provided by OCC, the
Commission believes that OCC’s
conclusion is reasonable, i.e., that under
certain stressed conditions as set forth
in the analysis, the peak stressed
liquidity demands of the largest clearing
member could exceed the size of OCC’s
committed liquidity facilities. Moreover,
the Commission understands that OCC
is unable to rely on the fact that there
will always be deposits of cash in the
Clearing Fund sufficient to cover such
demands because, under its current Bylaws and Rules, there is no ability for
OCC to ensure that a minimum amount
of cash is maintained in the Clearing
Fund at all times. Therefore, there is a
risk that OCC could face liquidity
shortfalls in the event of a default by a
clearing member whose payment
obligations exceed OCC’s liquid
Commission granted covered clearing agencies a
temporary exemption from compliance with Rule
17Ad–22(e)(3)(ii) and certain requirements in Rules
17Ad–22(e)(15)(i) and (ii) until December 31, 2017,
subject to certain conditions. OCC is a ‘‘covered
clearing agency’’ as defined in Rule 17Ad–22(a)(5).
15 12 U.S.C. 5464(b).
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resources. OCC determined to address
this risk by proposing to establish the
Cash Clearing Fund Requirement.
Establishing the Cash Clearing Fund
Requirement would provide OCC with
more qualifying liquid resources, which,
in turn, enhances OCC’s ability to cover
payment obligations that could arise in
stressed conditions. Further, the
proposal to give OCC the authority to
temporarily increase the Cash Clearing
Fund Requirement gives OCC additional
means to address liquidity shortfalls in
extreme scenarios.
The Commission also believes that the
proposed changes are consistent with
reducing systemic risks and supporting
the stability of the broader financial
system. OCC is the sole registered
clearing agency for the U.S. listed
options markets and a SIFMU. As such,
it is important for OCC to implement
measures that enhance its ability to
manage risks that could cause a
financial loss or settlement disruption
and threaten the stability of the U.S.
listed options markets and the broader
financial system. The Commission
believes that the proposed change is
designed to enhance OCC’s ability to
continue to make timely settlement of
payment obligations and otherwise
service the U.S. options markets while
in the midst of experiencing an extreme
market event in the form of the default
of up to two of its largest clearing
members. As such, the Commission
believes the proposed change is
consistent with reducing systemic risks
and supporting the stability of the
broader financial system.
B. Consistency With Rules 17Ad–
22(e)(7)(i), (iii), and (viii) Under the
Exchange Act
The Commission further believes that
the proposed change is consistent with
the Covered Clearing Agency Standards,
specifically Rule 17Ad–22(e)(7), which
requires that a covered clearing agency
establish, implement, maintain and
enforce written policies and procedures
reasonably designed to effectively
measure, monitor, and manage its
liquidity risk. This includes measuring,
monitoring, and managing the covered
clearing agency’s settlement and
funding flows on an ongoing and timely
basis, as well as its use of intraday
liquidity.16 The Division believes that
the proposed change is consistent with
several particular sub-parts of Rule
17Ad–22(e)(7), which require that
OCC’s liquidity risk management
policies and procedures be reasonably
designed to achieve the following:
16 17
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• Maintaining sufficient liquid resources at
the minimum in all relevant currencies to
effect same-day and, where appropriate,
intraday and multiday settlement of payment
obligations with a high degree of confidence
under a wide range of foreseeable stress
scenarios that includes, but is not limited to,
the default of the participant family that
would generate the largest aggregate payment
obligation for the covered clearing agency in
extreme but plausible market conditions; 17
• using the access to accounts and services
at a Federal Reserve Bank or other relevant
central bank, when available and where the
board of directors of the covered clearing
agency has determined that it would be
practical to enhance its management of
liquidity risk; 18 and
• addressing foreseeable liquidity
shortfalls that would not be covered by a
covered clearing agency’s liquid resources
and seeking to avoid unwinding, revoking, or
delaying the same-day settlement of payment
obligations.19
By proposing the Cash Clearing Fund
Requirement, OCC has taken measures
consistent with the standard in Rule
17Ad–22(e)(7)(i). OCC also represented
that substantially all of OCC’s Clearing
Fund deposits consisting of cash would
be held in an account established by
OCC at a Federal Reserve Bank and
further clarified that interest earned in
such an account would be paid to its
members on a specified basis. By
proposing to use its access to accounts
at a Federal Reserve Bank to support the
maintenance of the Cash Clearing Fund
Requirement, OCC has taken measures
consistent with the standard in Rule
17Ad–22(e)(7)(iii) which provides for
using access to a central bank account,
where available and determined to be
practical. Further, the proposed
authority to temporarily increase the
Cash Clearing Fund Requirement is
intended to address a foreseeable
liquidity shortfall and is therefore
consistent with the requirement in Rule
17Ad–22(e)(7)(viii).
IV. Conclusion
It is therefore noticed, pursuant to
Section 806(e)(1)(G) of the Payment,
Clearing and Settlement Supervision
Act,20 that the Commission does not
object to Advance Notice (SR–OCC–
2017–808) and that OCC is authorized
to implement the proposed change.
By the Commission.
Brent J. Fields,
Secretary.
[FR Doc. 2018–00857 Filed 1–18–18; 8:45 am]
BILLING CODE 8011–01–P
17 17
CFR 240.17Ad–22(e)(7)(i).
CFR 240.17Ad–22(e)(7)(iii).
19 17 CFR 240.17Ad–22(e)(7)(viii).
20 12 U.S.C. 5465(e)(1)(G).
18 17
E:\FR\FM\19JAN1.SGM
19JAN1
Agencies
[Federal Register Volume 83, Number 13 (Friday, January 19, 2018)]
[Notices]
[Pages 2843-2846]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-00857]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-82501; File No. SR-OCC-2017-808]
Self-Regulatory Organizations; The Options Clearing Corporation;
Notice of No Objection to Advance Notice, as Modified by Amendment No.
1, Concerning the Adoption of a New Minimum Cash Requirement for the
Clearing Fund
January 12, 2018.
The Options Clearing Corporation (``OCC'') filed on November 14,
2017
[[Page 2844]]
with the Securities and Exchange Commission (``Commission'') advance
notice SR-OCC-2017-808 (``Advance Notice'') pursuant to Section
806(e)(1) of the Payment, Clearing, and Settlement Supervision Act of
2010 (``Payment, Clearing and Settlement Supervision Act'') \1\ and
Rule 19b-4(n)(1)(i) under the Securities Exchange Act of 1934
(``Exchange Act'') \2\ to propose a new minimum cash contribution
requirement for its Clearing Fund \3\ (``Cash Clearing Fund
Requirement'') and also provide for the pass-through of interest income
earned on such deposits to its Clearing Members. The proposed changes
are intended to enhance OCC's liquidity risk management by increasing
the amount of qualifying liquid resources available, as well as to
provide for a more consistent level of cash available in its prefunded
financial resources. The Advance Notice was published for comment in
the Federal Register on December 14, 2017.\4\ The Commission did not
receive any comments on the Advance Notice. This publication serves as
notice of no objection to the Advance Notice.
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\1\ 12 U.S.C. 5465(e)(1). The Financial Stability Oversight
Council designated OCC a systemically important financial market
utility (``SIFMU'') on July 18, 2012. See Financial Stability
Oversight Council 2012 Annual Report, Appendix A, https://www.treasury.gov/initiatives/fsoc/Documents/2012%20Annual%20Report.pdf. Therefore, OCC is required to comply
with the Payment, Clearing and Settlement Supervision Act and file
advance notices with the Commission.
\2\ 17 CFR 240.19b-4(n)(1)(i).
\3\ Unless specified otherwise, capitalized terms shall have the
meaning OCC ascribes in its By-Laws and Rules.
\4\ Exchange Act Release No. 34-82247 (Dec. 8, 2017), 82 FR
59031 (Dec. 14, 2017) (``Notice of Filing of Advance Notice'').
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I. Background
OCC maintains a Clearing Fund, composed of contributions required
to be made by all Clearing Members, to make good losses suffered by OCC
under a number of circumstances, including the default or failure of a
Clearing Member to make good on any obligation for which OCC may be
responsible in the exercise of its duties as a central counterparty.
Presently, Article VIII, Section 3(a) of OCC's By-Laws provides that
Clearing Fund contributions shall be in the form of cash and Government
securities, but neither OCC's By-Laws nor Rules provides a minimum cash
requirement for contributions to the Clearing Fund. Article VIII,
Section 4(a) of OCC's By-Laws allows for OCC to invest cash
contributions to the Clearing Fund, partially or wholly, in OCC's
account in Government securities, and to the extent that such
contributions are not so invested, they shall be deposited by OCC in a
separate account or accounts for Clearing Fund contributions in
approved custodians. Article VIII, Section 4(a) of OCC's By-Laws,
however, presently does not account for the treatment of interest
earned on cash deposits held in OCC's bank account at the Federal
Reserve.
II. Description of the Advance Notice
A. Proposed Change To Establish the Cash Clearing Fund Requirement
OCC proposes to establish a Cash Clearing Fund Requirement for its
Clearing Fund to increase the amount of qualifying liquid resources
available to OCC to account in the event there is an extreme scenario
in the financial markets and OCC has to address any resultant liquidity
demands. Further, the proposal seeks to ensure that OCC holds, and
maintains access to, a more consistent level of cash clearing fund
resources in its available prefunded financial resources. Specifically,
the proposed rule change would require that Clearing Members
collectively contribute $3 billion in cash to the Clearing Fund. Each
Clearing Member's proportionate share of the Cash Clearing Fund
Requirement shall be determined by the current Clearing Fund allocation
methodology in OCC Rule 1001.
OCC's current liquidity resources are sized to cover historically
observed liquidity demands and potential demands based on forecasts
with a 12 month time horizon. The sizing calculations, in turn, are
based on the potential exposure resulting from the default of a single
clearing member. Further, the current clearing fund is sized, at a
minimum, to ensure that OCC maintains sufficient collateral to access
its committed liquidity facilities. OCC represented that it maintains
committed liquidity facilities of $3 billion to cover its calculated
historical and forecasted demands.\5\
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\5\ See Exchange Act Release No. 81058 (June 30, 2017), 82 FR
31371 (July 6, 2017) (SR-OCC-2017-803); Exchange Act Release No.
76641 (December 14, 2015), 80 FR 79114 (December 18, 2015) (SR-OCC-
2015-805). Both facilities allow OCC to obtain cash in exchange for
government securities 60 minutes after notice is given and
collateral is posted.
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After analyzing its liquidity demands in extreme stress
scenarios,\6\ OCC determined that it would propose the $3 billion Cash
Clearing Fund Requirement to increase the amount and reliability of its
liquid resources. OCC represented that, based upon its analysis, the
peak stressed liquidity demands of the largest or two largest Clearing
Members, which normally occur in conjunction with certain monthly
expirations, could exceed the capacity of OCC's current committed
liquidity facilities. Although OCC believes that it would be able to
cover the resulting shortfall with cash already present in the Clearing
Fund, OCC stated that it could not rely on such cash always being
available because, under OCC's current By-Laws and Rules, there is no
ability for OCC to ensure that a minimum amount of cash is maintained
in the Clearing Fund at all times. As a result, OCC believes that the
proposed $3 billion Cash Clearing Fund Requirement, combined with OCC's
$3 billion of committed liquidity facilities, would provide liquid
resources sufficient to cover the peak stressed liquidity demands of
the largest one or two Clearing Members observed in the analysis.
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\6\ OCC represented that it performed an analysis of its stress
liquidity demands based on a 1-in-70 year hypothetical market event.
Specifically, OCC started its analysis by selecting the largest
historical peak monthly settlements that occurred over the
historical look-back period of data generated by the stress test
system. It then also selected certain large non-expiration days to
supplement the analysis. From this it estimated the mark-to-market
and cash settled exercise and assignment obligations for the members
driving the historical peak demand under the proposed stress tests
scenario to determine the stressed peak demand.
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B. Proposed Change To Allow Temporary Increase of Cash Clearing Fund
Requirement
The proposed change would also provide authority for OCC to
temporarily increase the amount of the Cash Clearing Fund Requirement.
OCC's Executive Chairman, Chief Administrative Officer (``CAO''), or
Chief Operating Officer (``COO''), would have the authority, upon
providing notice to the Risk Committee, to temporarily raise the Cash
Clearing Fund Requirement up to an amount that includes the size of the
Clearing Fund as determined in accordance with Rule 1001 for the month
in question. A Clearing Member will be required to satisfy any increase
in its required cash contribution pursuant to an increase in the Cash
Clearing Fund Requirement no later than one hour before the close of
the Fedwire on the business day following OCC's issuance of an
instruction to increase cash contributions.
In such circumstances, the Risk Committee, by rule, would be
obligated to review any such temporary increase as soon as practicable,
but in any event within 20 calendar days of the increase. In its
review, the Risk Committee shall determine whether (1) the increase in
the minimum Cash Clearing Fund Requirement is no longer required, or
(2) OCC's Clearing Fund contribution
[[Page 2845]]
requirements and other related rules should be modified to ensure that
OCC continues to maintain sufficient liquid resources to cover its
largest aggregate payment obligations in extreme but plausible market
conditions. In the event that the Risk Committee would determine to
permanently increase the Cash Clearing Fund Requirement, OCC would
initiate any regulatory approval process required to effect such a
change.\7\
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\7\ However, OCC represented that it would not decrease the Cash
Clearing Fund Requirement while the regulatory approvals for a
change in the Cash Clearing Fund Requirement are being obtained to
ensure that OCC continues to maintain sufficient liquid resources to
cover its liquidity demands during that time.
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OCC acknowledged that increasing the Cash Clearing Fund Requirement
could impose a liquidity constraint on its clearing members.
Accordingly, OCC has proposed to limit the circumstances in which it
could make such an increase. By rule, OCC would only be able to
exercise this authority to protect OCC, its clearing members, or the
general public. Further, any Cash Clearing Fund Requirement increase
would have to: (i) Be based upon then-existing facts and circumstances,
(ii) be in furtherance of the integrity of OCC and the stability of the
financial system, and (iii) take into consideration the legitimate
interests of Clearing Members and market participants.
These changes would be reflected in new paragraph (a)(i) of Section
3 of Article VIII of OCC's By-Laws, as well as in new Interpretation
and Policy .04 to Section 3 of Article VIII.
C. Proposed Changes to Pass-Through Interest on Clearing Fund Cash to
Clearing Members
Under the proposal, OCC stated that substantially all the cash
deposits in the Clearing Fund would be held in an account established
by OCC at a Federal Reserve Bank. OCC proposes that it would pass the
interest income earned in such account through to its Clearing Members.
Specifically, OCC proposes to revise Article VIII, Section 4(a) of
OCC's By-Laws to provide that any interest earned on cash deposits held
at an account at the Federal Reserve shall accrue to the benefit of
Clearing Members (calculated daily based on each Clearing Member's pro
rata share of Clearing Fund cash deposits), provided that such Clearing
Members have provided OCC with all tax documentation as OCC may from
time to time require in order to effectuate such payment.
To accommodate the pass through of interest income, OCC would also
amend its Fee Policy to add definitions for ``Pass-Through Interest
Revenue'' and ``Operating Expenses'' to exclude from the calculation of
the Business Risk Buffer projected interest revenue and expense,
respectively, related to the pass-through of earned interest from OCC
to Clearing Members.\8\ OCC also proposes to add a new example of the
Business Risk Buffer calculation reflecting this change and make
clarifying changes throughout the policy to incorporate the use of the
new defined terms. In addition, OCC proposes to amend the Fee Policy to
remove references to ``Proposed Rule 17Ad-22(e)(15)'' to reflect the
adoption of the Commission's Covered Clearing Agency Standards.
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\8\ While interest income earned by OCC from its bank account at
the Federal Reserve would be passed on to its Clearing Members, OCC
anticipates that it would charge a cash management fee to cover
associated costs (i.e., administrative and similar costs). OCC would
file a separate proposed rule change with the Commission, subject to
receiving all necessary regulatory approvals for the proposed
changes described herein, prior to implementing any cash management
fee
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D. Proposed Conforming Changes
In conjunction with the aforementioned changes, OCC is also
proposing to make four related conforming changes. First, OCC proposes
to revise Interpretation and Policy .01 of Rule 1001 to reflect that
the new minimum Clearing Fund size is $3 billion (instead of $1
billion) plus 110% of the size of OCC's committed liquidity facilities,
which conforms to the Cash Clearing Fund Requirement. Second, OCC
proposes to amend the definition of ``Approved Custodian'' in Article
I, Section 1 of the By-Laws to clarify that the Federal Reserve Bank
may also be an Approved Custodian, to the extent it is available to
OCC. Third, OCC is proposing to delete existing Article VIII, Section
4(b), regarding the establishment of a segregated funds account for
cash contributions to the Clearing Fund. The segregated funds account
allows a Clearing Member to contribute cash to a bank or trust company
account maintained in the name of OCC, subject to OCC's exclusive
control, but the account also includes the name of the Clearing Member
and any interest accrues to the Clearing Member rather than OCC. OCC
proposes to eliminate the account type because Clearing Members have
not expressed interest in using such an account, no such accounts are
in use today, and moving forward, substantially all cash Clearing Fund
contributions will held in OCC's account at the Federal Reserve Bank.
Fourth, OCC proposes to introduce new language to Article VIII, Section
4(a) to clarify that cash contributions to the Clearing Fund that are
deposited at approved custodians may be commingled with the Clearing
Fund contributions of different Clearing Members.
III. Discussion and Commission Findings
Although the Payment, Clearing and Settlement Supervision Act does
not specify a standard of review for an advance notice, the stated
purpose is instructive.\9\ The stated purpose of the Payment, Clearing
and Settlement Supervision Act is to mitigate systemic risk in the
financial system and promote financial stability by, among other
things, promoting uniform risk management standards for SIFMUs and
strengthening the liquidity of SIFMUs.\10\
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\9\ See 12 U.S.C. 5461(b).
\10\ Id.
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Section 805(a)(2) of the Payment, Clearing and Settlement
Supervision Act \11\ authorizes the Commission to prescribe regulations
containing risk-management standards for the payment, clearing, and
settlement activities of designated clearing entities engaged in
designated activities for which the Commission is the supervisory
agency. Section 805(b) of the Payment, Clearing and Settlement
Supervision Act \12\ provides the following objectives and principles
for the Commission's risk-management standards prescribed under Section
805(a):
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\11\ 12 U.S.C. 5464(a)(2).
\12\ 12 U.S.C. 5464(b).
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To promote robust risk management;
To promote safety and soundness;
To reduce systemic risks; and
To support the stability of the broader financial system.
Section 805(c) provides, in addition, that the Commission's risk-
management standards may address such areas as risk-management and
default policies and procedures, among others areas.\13\
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\13\ 12 U.S.C. 5464(c).
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The Commission has adopted risk-management standards under Section
805(a)(2) of the Payment, Clearing and Settlement Supervision Act and
the Exchange Act (the ``Clearing Agency Rules'').\14\ The Clearing
Agency Rules
[[Page 2846]]
require each covered clearing agency, among other things, to establish,
implement, maintain, and enforce written policies and procedures that
are reasonably designed to meet certain minimum requirements for
operations and risk-management practices on an ongoing basis. As such,
it is appropriate for the Commission to review advance notices for
consistency with the objectives and principles for risk-management
standards described in Section 805(b) of the Payment, Clearing and
Settlement Supervision Act and the Clearing Agency Rules.
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\14\ 17 CFR 240.17Ad-22. See Securities Exchange Act Release No.
68080 (October 22, 2012), 77 FR 66220 (November 2, 2012) (S7-08-11).
See also Securities Exchange Act Release No. 78961 (September 28,
2016), 81 FR 70786 (October 13, 2016) (S7-03-14) (``Covered Clearing
Agency Standards''). The Commission established an effective date of
December 12, 2016, and a compliance date of April 11, 2017, for the
Covered Clearing Agency Standards. On March 4, 2017, the Commission
granted covered clearing agencies a temporary exemption from
compliance with Rule 17Ad-22(e)(3)(ii) and certain requirements in
Rules 17Ad-22(e)(15)(i) and (ii) until December 31, 2017, subject to
certain conditions. OCC is a ``covered clearing agency'' as defined
in Rule 17Ad-22(a)(5).
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A. Consistency With Section 805(b) of the Payment, Clearing and
Settlement Supervision Act
The Commission believes the Advance Notice is consistent with the
stated objectives and principles of Section 805(b) of the Payment,
Clearing and Settlement Supervision Act of promoting robust risk
management, promoting safety and soundness, reducing systemic risks,
and supporting the stability of the broader financial system.\15\
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\15\ 12 U.S.C. 5464(b).
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The Commission believes that the Cash Clearing Fund Requirement
would enhance OCC's ability to manage its liquidity risk exposure,
thereby promoting robust risk management. Similarly, the Commission
believes that increasing the amount of cash, and therefore the overall
amount of qualifying liquid resources, available to cover OCC's
liquidity demands arising in stressed scenarios is consistent with
promoting safety and soundness. Based on the analysis provided by OCC,
the Commission believes that OCC's conclusion is reasonable, i.e., that
under certain stressed conditions as set forth in the analysis, the
peak stressed liquidity demands of the largest clearing member could
exceed the size of OCC's committed liquidity facilities. Moreover, the
Commission understands that OCC is unable to rely on the fact that
there will always be deposits of cash in the Clearing Fund sufficient
to cover such demands because, under its current By-laws and Rules,
there is no ability for OCC to ensure that a minimum amount of cash is
maintained in the Clearing Fund at all times. Therefore, there is a
risk that OCC could face liquidity shortfalls in the event of a default
by a clearing member whose payment obligations exceed OCC's liquid
resources. OCC determined to address this risk by proposing to
establish the Cash Clearing Fund Requirement. Establishing the Cash
Clearing Fund Requirement would provide OCC with more qualifying liquid
resources, which, in turn, enhances OCC's ability to cover payment
obligations that could arise in stressed conditions. Further, the
proposal to give OCC the authority to temporarily increase the Cash
Clearing Fund Requirement gives OCC additional means to address
liquidity shortfalls in extreme scenarios.
The Commission also believes that the proposed changes are
consistent with reducing systemic risks and supporting the stability of
the broader financial system. OCC is the sole registered clearing
agency for the U.S. listed options markets and a SIFMU. As such, it is
important for OCC to implement measures that enhance its ability to
manage risks that could cause a financial loss or settlement disruption
and threaten the stability of the U.S. listed options markets and the
broader financial system. The Commission believes that the proposed
change is designed to enhance OCC's ability to continue to make timely
settlement of payment obligations and otherwise service the U.S.
options markets while in the midst of experiencing an extreme market
event in the form of the default of up to two of its largest clearing
members. As such, the Commission believes the proposed change is
consistent with reducing systemic risks and supporting the stability of
the broader financial system.
B. Consistency With Rules 17Ad-22(e)(7)(i), (iii), and (viii) Under the
Exchange Act
The Commission further believes that the proposed change is
consistent with the Covered Clearing Agency Standards, specifically
Rule 17Ad-22(e)(7), which requires that a covered clearing agency
establish, implement, maintain and enforce written policies and
procedures reasonably designed to effectively measure, monitor, and
manage its liquidity risk. This includes measuring, monitoring, and
managing the covered clearing agency's settlement and funding flows on
an ongoing and timely basis, as well as its use of intraday
liquidity.\16\ The Division believes that the proposed change is
consistent with several particular sub-parts of Rule 17Ad-22(e)(7),
which require that OCC's liquidity risk management policies and
procedures be reasonably designed to achieve the following:
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\16\ 17 CFR 240.17Ad-22(e)(7).
Maintaining sufficient liquid resources at the minimum
in all relevant currencies to effect same-day and, where
appropriate, intraday and multiday settlement of payment obligations
with a high degree of confidence under a wide range of foreseeable
stress scenarios that includes, but is not limited to, the default
of the participant family that would generate the largest aggregate
payment obligation for the covered clearing agency in extreme but
plausible market conditions; \17\
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\17\ 17 CFR 240.17Ad-22(e)(7)(i).
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using the access to accounts and services at a Federal
Reserve Bank or other relevant central bank, when available and
where the board of directors of the covered clearing agency has
determined that it would be practical to enhance its management of
liquidity risk; \18\ and
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\18\ 17 CFR 240.17Ad-22(e)(7)(iii).
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addressing foreseeable liquidity shortfalls that would
not be covered by a covered clearing agency's liquid resources and
seeking to avoid unwinding, revoking, or delaying the same-day
settlement of payment obligations.\19\
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\19\ 17 CFR 240.17Ad-22(e)(7)(viii).
By proposing the Cash Clearing Fund Requirement, OCC has taken measures
consistent with the standard in Rule 17Ad-22(e)(7)(i). OCC also
represented that substantially all of OCC's Clearing Fund deposits
consisting of cash would be held in an account established by OCC at a
Federal Reserve Bank and further clarified that interest earned in such
an account would be paid to its members on a specified basis. By
proposing to use its access to accounts at a Federal Reserve Bank to
support the maintenance of the Cash Clearing Fund Requirement, OCC has
taken measures consistent with the standard in Rule 17Ad-22(e)(7)(iii)
which provides for using access to a central bank account, where
available and determined to be practical. Further, the proposed
authority to temporarily increase the Cash Clearing Fund Requirement is
intended to address a foreseeable liquidity shortfall and is therefore
consistent with the requirement in Rule 17Ad-22(e)(7)(viii).
IV. Conclusion
It is therefore noticed, pursuant to Section 806(e)(1)(G) of the
Payment, Clearing and Settlement Supervision Act,\20\ that the
Commission does not object to Advance Notice (SR-OCC-2017-808) and that
OCC is authorized to implement the proposed change.
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\20\ 12 U.S.C. 5465(e)(1)(G).
By the Commission.
Brent J. Fields,
Secretary.
[FR Doc. 2018-00857 Filed 1-18-18; 8:45 am]
BILLING CODE 8011-01-P