Self-Regulatory Organizations; National Securities Clearing Corporation; Notice of No Objection To Advance Notice Filing, as Modified by Amendment No. 1, To Enhance the Calculation of the Volatility Component of the Clearing Fund Formula That Utilizes a Parametric Value-at-Risk Model and Eliminate the Market Maker Domination Charge, 9035-9039 [2018-04237]
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Federal Register / Vol. 83, No. 42 / Friday, March 2, 2018 / Notices
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
a.m. and 3 p.m. Copies of such filing
also will be available for inspection and
copying at the principal office of CBOE.
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–CBOE–2018–017
and should be submitted on or before
March 23, 2018.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.18
Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2018–04208 Filed 3–1–18; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–82780; File No. SR–NSCC–
2017–808]
Self-Regulatory Organizations;
National Securities Clearing
Corporation; Notice of No Objection To
Advance Notice Filing, as Modified by
Amendment No. 1, To Enhance the
Calculation of the Volatility Component
of the Clearing Fund Formula That
Utilizes a Parametric Value-at-Risk
Model and Eliminate the Market Maker
Domination Charge
daltland on DSKBBV9HB2PROD with NOTICES
February 26, 2018.
National Securities Clearing
Corporation (‘‘NSCC’’) filed with the
U.S. Securities and Exchange
Commission (‘‘Commission’’) on
December 28, 2017 the advance notice
SR–NSCC–2017–808 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–
18 17
CFR 200.30–3(a)(12).
U.S.C. 5465(e)(1). The Financial Stability
Oversight Council designated NSCC a systemically
important financial market utility on July 18, 2012.
See Financial Stability Oversight Council 2012
Annual Report, Appendix A, https://
1 12
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4(n)(1)(i) 2 under the Securities
Exchange Act of 1934, as amended
(‘‘Exchange Act’’). On January 10, 2018,
NSCC filed Amendment No. 1 to the
advance notice.3 The advance notice, as
modified by Amendment No. 1
(hereinafter, the ‘‘Advance Notice’’) was
published for comment in the Federal
Register on February 8, 2018.4 The
Commission did not receive any
comments on the Advance Notice. This
publication serves as notice that the
Commission does not object to the
changes set forth in the Advance Notice.
I. Description of the Advance Notice
The Advance Notice consists of
changes to NSCC’s Rules & Procedures
(‘‘Rules’’) 5 that would enhance NSCC’s
method for calculating the daily margin
requirement for each NSCC member
(‘‘Member’’).6 Specifically, NSCC
proposes to (1) add three new ways to
calculate the volatility component of its
Members’ margin requirements, and (2)
eliminate an outdated component of the
margin calculation, as described more
fully below.7 NSCC states that the new
volatility component calculations would
enable NSCC to mitigate the credit risks
presented by Member portfolios in a
broader range of scenarios and market
conditions than NSCC’s current
volatility component calculation.8
A key tool that NSCC uses to manage
its credit exposures to Members is the
daily calculation and collection of
margin from each Member (‘‘Required
Deposit’’).9 NSCC collects Required
Deposits from Members to mitigate
www.treasury.gov/initiatives/fsoc/Documents/
2012%20Annual%20Report.pdf. Therefore, NSCC
is required to comply with the Payment, Clearing
and Settlement Supervision Act and file advance
notices with the Commission. See 12 U.S.C.
5465(e).
2 17 CFR 240.19b–4(n)(1)(i).
3 In Amendment No. 1 to the advance notice,
NSCC amended and replaced in its entirety the
originally filed confidential Exhibit 3a with a new
confidential Exhibit 3a in order to remove
references to a practice that was not intended for
consideration as part of the filing.
4 Securities Exchange Act Release No. 82631
(February 5, 2018), 83 FR 5658 (February 8, 2017)
(SR–NSCC–2017–808) (‘‘Notice’’). NSCC also filed a
related proposed rule change with the Commission
pursuant to Section 19(b)(1) of the Exchange Act
and Rule 19b–4 thereunder, seeking approval of
changes to its rules necessary to implement the
Advance Notice. 15 U.S.C. 78s(b)(1) and 17 CFR
240.19b–4, respectively. The proposed rule change
was published in the Federal Register on January
19, 2018. Securities Exchange Act Release No.
82494 (January 12, 2018), 83 FR 2828 (January 19,
2018) (SR–NSCC–2017–020). The Commission did
not receive any comments on that proposal.
5 NSCC’s Rules, available at https://dtcc.com/∼/
media/Files/Downloads/legal/rules/nscc_rules.pdf.
6 Notice, 83 FR at 5659.
7 Id.
8 Id.
9 Id.
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NSCC’s potential losses associated with
the liquidation of a Member’s portfolio
should the Member default.10 The
aggregate of all Members’ Required
Deposits constitutes NSCC’s Clearing
Fund, which NSCC can access should a
defaulting Member’s own Required
Deposit be insufficient to satisfy NSCC’s
losses caused by the liquidation of the
Member’s portfolio.11
A. Evenly-Weighted Volatility
Estimation
Each Member’s Required Deposit
consists of several components.12
Generally, the largest component of a
Member’s Required Deposit is the
volatility component, which is designed
to capture the market price risk
associated with each Member’s portfolio
at a 99th percentile level of
confidence.13 NSCC currently calculates
the volatility component using a
parametric Value-at-Risk (‘‘VaR’’)
model.14 NSCC’s current VaR
calculation places more emphasis on
recent market observations (such as
recent price history) for the purpose of
estimating current market price
volatility levels, based on the
assumption that the most recent price
history is more relevant and accurate for
measuring current market price
volatility levels (referred to as an
‘‘exponentially-weighted volatility
estimation’’).15 However, volatility in
the equity markets often rapidly reverts
to more commonly observed levels,
followed by a subsequent spike.16 While
a VaR calculation that applies
exclusively an exponentially-weighted
volatility estimation can capture sudden
increases in volatility, it may result in
a swift decline in margin that does not
adequately capture the risks related to a
rapid decrease in market price volatility
levels.17 NSCC proposes to mitigate this
shortcoming by adding another method
for computing the VaR calculation that
does not diminish the value of older
market observations.18 Specifically,
NSCC proposes to add a VaR calculation
that gives equal weight to all historical
volatility observations during a
specified look-back period (referred to
by NSCC as an ‘‘evenly-weighted
volatility estimation’’),19 which could
10 Id.
11 Id.
12 See Procedure XV (Clearing Fund Formula and
Other Matters) of the Rules, supra note 5.
13 Notice, 83 FR at 5659–60.
14 Notice, 83 FR at 5660.
15 Id.
16 Id.
17 Id.
18 Id.
19 Id.
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result in margin requirement amounts
during non-volatile periods greater than
margin requirement amounts based
upon the exponentially-weighted
volatility estimation.20 Under the
proposal, NSCC would calculate both
the exponentially-weighted volatility
estimation and the evenly-weighted
volatility estimation, and the greater
result would represent the ‘‘Core
Parametric Estimation.’’ 21
B. Gap Risk Measure
In addition to the Core Parametric
Estimation, NSCC proposes to add a
second method for determining the
volatility component of a Member’s
Required Deposit.22 This second
method, referred to as the Gap Risk
Measure, would help address risks that
are unique to Member portfolios that
hold a concentrated position in a
specific security.23 More specifically,
when a Member’s portfolio holds a
concentrated position in a specific
security, such that the position
represents a significant percentage of
the entire portfolio’s value, the portfolio
may be more susceptible to risks
associated with issuer-specific events
affecting the price of the concentrated
security.24 Such events include earning
reports, management changes, merger
announcements, insolvency, or other
unexpected issuer-specific events
(collectively, ‘‘Gap Risk Events’’).25
NSCC has observed that portfolios
with a concentration level of more than
30 percent in a specific security tend to
have backtesting coverage below the 99
percent confidence level.26 To mitigate
the concentration risk posed by such
portfolios, NSCC proposes the Gap Risk
Measure, which would apply to all
individual equities in a Member’s
portfolio, but only when the Member
holds a position in a security that meets
a 30 percent concentration threshold
relative to the remainder of the
portfolio.27
NSCC also has observed that
exchange-traded products (‘‘ETPs’’) that
track to a broad market index are
generally not susceptible to Gap Risk
Events.28 Accordingly, NSCC would not
apply the Gap Risk Measure to positions
in such index-based ETPs, even if the 30
percent concentration threshold is
met.29 However, non-index-based ETPs
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20 Id.
21 Notice,
83 FR at 5661.
22 Id.
23 Id.
24 Id.
25 Id.
26 Id.
27 Id.
28 Id.
29 Id.
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and index-based ETPs that track a
narrow market index are susceptible to
Gap Risk Events, and would, therefore,
be subject to the Gap Risk Measure,
provided that the 30 percent
concentration threshold is met.30
When applicable, NSCC would
calculate the Gap Risk Measure by
multiplying the gross market value of
the largest (non-index) position in the
portfolio by a percent of not less than
10 percent.31
C. Portfolio Margin Floor
In addition to the Core Parametric
Estimation and the Gap Risk Measure,
NSCC proposes to add a third method
for determining the volatility
component of a Member’s Required
Deposit.32 This third method, referred to
as the Portfolio Margin Floor, would
help address risks that may not be
adequately accounted for by the Core
Parametric Estimation or the Gap Risk
Measure.33 For example, a volatility
component based solely on a parametric
VaR model calculation may prove
inadequate where there is low market
price volatility and the portfolio holds
either large gross market values or large
net directional market values.34 In such
cases, the model may not collect
sufficient margin, which could hinder
NSCC’s ability to effectively liquidate or
hedge the Member’s portfolio in three
business days.35
NSCC proposes the Portfolio Margin
Floor to operate as a floor to (i.e.,
minimum amount of) a Member’s
volatility component.36 Specifically, the
Portfolio Margin Floor would be based
on the balance and direction of the
positions in the Member’s portfolio and
would be designed to be proportional to
the market value of the portfolio.37
30 Id. NSCC states that it would use a third-party
market provider to identify index-based ETPs. Id.
The third-party market provider would identify
index-based ETPs as those with criteria that require
the portfolio returns to track to a broad market
index. Id. ETPs that do not meet this criteria would
not be considered index-based ETPs and, therefore,
would be included in the Gap Risk Measure
calculation. Id.
31 Id. NSCC would determine such percent
empirically as no less than the larger of the 1st and
99th percentiles of three-day returns of a set of
CUSIPs that are subject to the volatility component,
giving equal rank to each to determine which has
the highest movement over that three-day period.
Id. NSCC would use a look-back period of not less
than ten years that includes a one-year stress
period. Id. If the one-year stress period overlaps
with the look-back period, only the nonoverlapping period would be combined with the
look-back period. Id. The result would then be
rounded up to the nearest whole percentage. Id.
32 Notice, 83 FR at 5661.
33 Id.
34 Notice, 83 FR at 5662.
35 Id.
36 Id.
37 Id.
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The Portfolio Margin Floor would be
the sum of two separate calculations,
both of which would measure the
market value of the portfolio based on
the direction of net positions in the
portfolio.38 First, NSCC would calculate
the net directional market value of the
portfolio by calculating the absolute
difference between the market value of
the long positions and shorts positions
in the portfolio,39 then multiplying that
amount by a percentage.40 Second,
NSCC would calculate the balanced
market value of the portfolio by taking
the lowest market value of either the
long or short positions in the portfolio,41
then multiplying that value by a
percentage.42 The combined results of
these two calculations would constitute
the final Portfolio Margin Floor
amount.43
Finally, in order to choose the amount
to be charged as the volatility
component of a Member’s Required
Deposit, NSCC would compare the
amounts calculated by the Portfolio
Margin Floor, the Gap Risk Measure (if
applicable), and the Core Parametric
Estimation. NSCC then would use the
highest of those three calculations as the
volatility component of the Member’s
Required Deposit.44
D. Elimination of the Market Maker
Domination Component
NSCC proposes to eliminate the
Market Maker Domination Component
(‘‘MMD Charge’’) from its Clearing Fund
formula.45 The MMD Charge is an
existing component of the Clearing
Fund formula calculated for Members
that are Market Makers and Members
that clear for Market Makers.46 The
MMD Charge was developed to address
the risks presented by concentrated
positions (of the overall unsettled long
position in the security) held by Market
Makers.47 More specifically, the charge
38 Id.
39 For example, if the market value of the long
positions is $100,000, and the market value of the
short positions is $200,000, the net directional
market value of the portfolio would be $100,000. Id.
40 Id. NSCC would determine the applicable
percentage by examining the annual historical
volatility levels of benchmark indices over a
historical look-back period. Id.
41 For example, if the market value of the long
positions is $100,000, and the market value of the
short positions is $110,000, the balanced market
value of the portfolio would be $100,000. Id.
42 Id. NSCC would determine the applicable
percentage to be an amount that covers the
transaction costs and other relevant risks associated
with the positions in the portfolio. Id.
43 Id.
44 Id.
45 Id.
46 Id; see also Procedure XV, Section I(A)(1)(d) of
the Rules, supra note 5.
47 Notice, 83 FR at 5662.
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is designed to address securities that are
susceptible to marketability and
liquidation impairment because of the
relative size of the positions that NSCC
would have to liquidate or hedge in the
case of a Market Maker default.48
Under the current Rules, NSCC may
impose the MMD Charge if the Market
Maker (either the Member or the
correspondent of the Member) holds a
position that is greater than 40 percent
of the overall unsettled long position
(i.e., the sum of each clearing broker’s
net long position) in a specific
security.49 NSCC calculates the MMD
Charge as the sum of each of the
absolute values of the net positions in
the relevant securities, less the reported
amount of excess net capital for that
Member.50
NSCC states that since
implementation of the MMD Charge,
several developments in the U.S. equity
markets (e.g., improved price
transparency, access across exchange
venues, and participation by market
liquidity providers) have reduced the
risks that the MMD Charge was
designed to address.51 NSCC further
states that the MMD Charge may not
effectively address concentration risk
because the MMD Charge (1) only
applies to positions in certain securities,
as described above, (2) does not address
concentration risk presented by
positions in securities that are not listed
on NASDAQ or in securities traded by
firms that are not Market Makers, and
(3) does not account for concentration in
market capitalization categories.52
NSCC states that the proposed Gap Risk
Measure would provide better
concentration risk coverage than the
MMD Charge because the former would
apply to all Members, whereas the latter
only applies to Market Makers.53
II. Discussion and Commission
Findings
Although the Clearing Supervision
Act does not specify a standard of
review for an advance notice, its stated
purpose is instructive: To mitigate
systemic risk in the financial system
and promote financial stability by,
among other things, promoting uniform
risk management standards for
systemically important financial market
utilities and strengthening the liquidity
daltland on DSKBBV9HB2PROD with NOTICES
A. Consistency With Section 805(b) of
the Clearing Supervision Act
The Commission believes that the
changes proposed in the Advance
Notice are consistent with each of the
objectives and principles described in
Section 805(b) of the Act.63 Specifically,
as discussed below, the Commission
believes that the changes proposed in
the Advance Notice are consistent with
54 See
48 Id.
12 U.S.C. 5461(b).
U.S.C. 5464(a)(2).
56 12 U.S.C. 5464(b).
57 12 U.S.C. 5464(c).
58 12 U.S.C. 5464(a)(2).
59 15 U.S.C. 78q–1.
60 17 CFR 240.17Ad–22.
61 12 U.S.C. 5464(b).
62 17 CFR 240.17Ad–22.
63 12 U.S.C. 5464(b).
55 12
49 Id.
50 Id. NSCC does not apply the excess net capital
offset for Members with the weakest credit rating
(i.e. 7) on the Credit Risk Rating Matrix. See
Procedure XV, Sections I(A)(1)(d) and I(A)(2)(c) of
the Rules, supra note 5.
51 Notice, 83 FR at 5662.
52 Id.
53 Id.
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of systemically important financial
market utilities.54
Section 805(a)(2) of the Clearing
Supervision Act 55 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 Clearing Supervision Act 56
provides the following objectives and
principles for the Commission’s riskmanagement standards prescribed under
Section 805(a):
• Promote robust risk management;
• promote safety and soundness;
• reduce systemic risks; and
• support the stability of the broader
financial system.
Section 805(c) of the Clearing
Supervision Act 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.57
The Commission has adopted riskmanagement standards under Section
805(a)(2) of the Clearing Supervision
Act 58 and Section 17A of the Exchange
Act (‘‘Rule 17Ad–22’’).59 Rule 17Ad–22
requires 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 their
operations and risk-management
practices on an ongoing basis.60
Therefore, it is appropriate for the
Commission to review proposed
changes in advance notices for
consistency with the objectives and
principles of the risk-management
standards described in Section 805(b) of
the Clearing Supervision Act 61 and
against Rule 17Ad–22.62
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9037
promoting robust risk management in
the area of credit risk and promoting
safety and soundness, which in turn,
would help reduce systemic risk and
support the stability of the broader
financial system.
The Commission believes that the
proposed changes promote robust risk
management by adding three new
volatility component calculations that
would better enable NSCC to mitigate
the credit risks presented by Member
portfolios in a broader range of
scenarios and market conditions than
NSCC’s current volatility component
calculation.
First, as described above, NSCC
currently calculates the volatility
component of each Member’s Required
Deposit using a VaR calculation that
relies exclusively on an exponentiallyweighted volatility estimation.
However, the current VaR calculation
places more emphasis on recent market
observations, which may result in a
swift decline in margin that does not
adequately capture the risks related to a
rapid decrease in market price volatility
levels. To address this shortcoming,
NSCC proposes to (1) add a VaR
calculation that relies on an evenlyweighted volatility estimation (i.e., that
gives equal weight to all historical
volatility observations during a
specified look-back period), (2) compare
the amounts of both VaR calculations
(i.e., based on both evenly- and
exponentially-weighted volatility
estimations), and (3) use the greater
amount as the Core Parametric
Estimation. Accordingly, the
Commission believes adding the VaR
calculation based on an evenlyweighted volatility estimation would
enable NSCC to more effectively limit
its credit exposure to Members in
market conditions that reflect a rapid
decrease in market price volatility
levels.
Second, as described above, when a
Member’s portfolio holds a concentrated
position in a specific security beyond a
significant percentage of the entire
portfolio’s value, the portfolio may be
more susceptible to Gap Risk Events. In
such a scenario, NSCC’s current
volatility component calculation may
result in inadequate margin coverage.
To address this issue, NSCC has
proposed the Gap Risk Measure as an
alternative volatility component
calculation. The Gap Risk Measure is
designed to provide better margin
coverage in such a scenario as it would
apply to all individual equities
(including non-index-based and narrowindex-based ETPs, as described above)
when a Member maintains a position in
its portfolio that exceeds the 30 percent
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concentration threshold. Accordingly,
the Commission believes adding the
Gap Risk Measure would enable NSCC
to more effectively limit its credit
exposure to Members in certain
scenarios in which a Member holds a
security that meets the 30 percent
concentration threshold relative to the
remainder of its portfolio.
Third, as described above, when a
Member’s portfolio holds either large
gross market values or large net
directional market values in a period of
low market price volatility, NSCC’s
current volatility component calculation
may not result in adequate margin,
which could hinder NSCC’s ability to
effectively liquidate or hedge the
Member’s portfolio in the event of the
Member’s default. To address this
concern, NSCC proposes the Portfolio
Margin Floor, which would operate as a
floor to (i.e., minimum amount of) the
volatility component of a Member’s
Required Deposit. Accordingly, the
Commission believes adding the
Portfolio Margin Floor would enable
NSCC to more effectively limit its credit
exposure to Members in certain
scenarios, such as when a Member’s
portfolio holds either large gross market
values or large net directional market
values and market prices exhibit low
volatility.
Finally, to help ensure that the
amount of margin that NSCC collects as
the volatility component of a Member’s
Required Deposit would help mitigate
each of the specific concerns addressed
by the Core Parametric Estimation, Gap
Risk Measure, and Portfolio Margin
Floor, NSCC would assess the largest
amount of those three calculations as
the volatility component of the
Member’s Required Deposit.
In addition to the three proposed
volatility component calculations,
NSCC also proposes to eliminate the
MMD Charge. As described above,
NSCC has found the MMD Charge to be
an inefficient and ineffective component
of the Clearing Fund formula that may
not accurately capture the credit risk
presented by a Member’s portfolio. More
specifically, the charge does not cover a
range of scenarios and market
conditions that would be covered by the
proposed Gap Risk Measure. Moreover,
in contrast to the proposed Gap Risk
Measure, the MMD Charge (1) only
applies to positions in certain securities,
(2) does not address concentration risk
presented by positions in securities that
are not listed on NASDAQ, (3) does not
account for concentration in market
capitalization categories, and (4) only
applies to Market Makers. Accordingly,
NSCC’s proposal to eliminate the MMD
Charge is designed to remove an
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obsolete component from the Clearing
Fund formula.
Taken together, each of the above
described changes would enhance
NSCC’s current method for calculating
each Member’s volatility component,
enabling NSCC to produce margin levels
more commensurate with the risks
associated with its Members’ portfolios
in a broader range of scenarios and
market conditions, and, thus, more
effectively cover its credit exposure to
its Members. Therefore, the Commission
believes the changes proposed in the
Advance Notice are consistent with
promoting robust risk management,
consistent with Section 805(b) of the
Clearing Supervision Act.64
The Commission also believes that the
proposed changes would promote safety
and soundness at NSCC, which, in turn,
would help reduce systemic risk and
support the stability of the broader
financial system. As described above,
the proposed changes are designed to
better limit NSCC’s credit exposure to
Members in the event of a Member
default. More specifically, the proposed
VaR calculation based on an evenlyweighted volatility estimation would
enable NSCC to better manage its credit
exposure to Members in market
conditions that reflect a rapid decrease
in market price volatility levels.
Meanwhile, the proposed Gap Risk
Measure would enable NSCC to manage
its credit exposure to Member portfolios
that are more susceptible to Gap Risk
Events. Finally, the proposed Portfolio
Margin Floor would enable NSCC to
better manage its credit exposure to
Members in certain scenarios, such as
low market price volatility when a
Member’s portfolio holds either large
gross market values or large net
directional market values.
By better limiting credit exposure to
its Members, NSCC’s proposed changes
are designed to help ensure that, in the
event of a Member default, NSCC’s
operations would not be disrupted and
non-defaulting Members would not be
exposed to losses that they cannot
anticipate or control. As such, the
Commission finds that the proposed
changes would promote safety and
soundness, which in turn, would reduce
systemic risks and support the stability
of the broader financial system,
consistent with Section 805(b) of the
Clearing Supervision Act.65
Therefore, the Commission believes
that the changes proposed in the
Advance Notice are consistent with
Section 805(b) of the Clearing
Supervision Act.66
B. Consistency With Rule 17Ad–
22(e)(4)(i) of the Exchange Act
The Commission believes that the
changes proposed in the Advance
Notice are consistent with Rule 17Ad–
22(e)(4)(i) under the Exchange Act,
which requires that NSCC establish,
implement, maintain and enforce
written policies and procedures
reasonably designed to effectively
identify, measure, monitor, and manage
its credit exposures to participants and
those arising from its payment, clearing,
and settlement processes, including by
maintaining sufficient financial
resources to cover its credit exposure to
each participant fully with a high degree
of confidence.67
As described above, the Commission
believes the proposed VaR calculation
based on an evenly-weighted volatility
estimation would enable NSCC to better
manage its credit exposure to Members
in market conditions that reflect a rapid
decrease in market price volatility
levels; the proposed Gap Risk Measure
would enable NSCC to better manage its
credit exposure to Member portfolios
that are more susceptible to Gap Risk
Events; and the proposed Portfolio
Margin Floor would enable NSCC to
better manage its credit exposure to
Members in certain scenarios, such as
when a Member’s portfolio holds either
large gross market values or large net
directional market values and market
prices exhibit low volatility.
Furthermore, NSCC would assess a
Member the largest of these three
calculations as the Member’s volatility
component to its Required Deposit.
Each of these proposed changes is
designed to help NSCC more effectively
identify, measure, monitor, and manage
its credit exposures to its Members. In
doing so, the proposed changes would
enable NSCC to more accurately assess
the volatility component of a Member’s
Required Deposit and, thus, help NSCC
maintain sufficient financial resources
to cover its credit exposure to each
Member fully with a high degree of
confidence. Therefore, the Commission
finds that the changes proposed in the
Advance Notice are consistent with
Rule 17Ad–22(e)(4)(i) under the
Exchange Act.68
C. Consistency With Rule 17Ad–
22(e)(6)(i) and (v) of the Exchange Act
The Commission believes that the
changes proposed in the Advance
66 Id.
64 Id.
67 17
65 Id.
68 Id.
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CFR 240.17Ad–22(e)(4)(i).
02MRN1
daltland on DSKBBV9HB2PROD with NOTICES
Federal Register / Vol. 83, No. 42 / Friday, March 2, 2018 / Notices
Notice are consistent with Rule 17Ad–
22(e)(6)(i) under the Exchange Act,
which requires that NSCC establish,
implement, maintain and enforce
written policies and procedures
reasonably designed to cover its credit
exposures to its participants by
establishing a risk-based margin system
that, at a minimum considers, and
produces margin levels commensurate
with, the risks and particular attributes
of each relevant product, portfolio, and
market.69 Furthermore, the Commission
believes that the changes proposed in
the Advance Notice are consistent with
Rule 17Ad–22(e)(6)(v) under the
Exchange Act, which requires that
NSCC establish, implement, maintain
and enforce written policies and
procedures reasonably designed to use
an appropriate method for measuring
credit exposure that accounts for
relevant product risk factors and
portfolio effects across products.70
As described above, the Commission
believes the proposed VaR calculation
based on an evenly-weighted volatility
estimation would enable NSCC to better
manage its credit exposure to Members
in certain market conditions with a
rapid decrease in market price volatility
levels; the proposed Gap Risk Measure
would enable NSCC to better manage its
credit exposure to Member portfolios
that are more susceptible to Gap Risk
Events; and the proposed Portfolio
Margin Floor would enable NSCC to
better manage its credit exposure to
Members in certain scenarios, such as
low market price volatility when a
Member’s portfolio holds either large
gross market values or large net
directional market values and market
prices exhibit low volatility. Moreover,
NSCC would assess a Member the
largest of these three calculations as the
Member’s volatility component to its
Required Deposit.
These three proposed volatility
component calculations are designed to
help improve NSCC’s risk-based margin
system by enabling NSCC to produce
margin levels that are more
commensurate with the risks and
particular attributes of the relevant
products, portfolios, and markets that
NSCC serves. Additionally, as described
above, the three proposed volatility
component calculations are designed to
use methods that are more appropriately
tailored for measuring credit exposure
that account for specific risk factors and
portfolio effects. Therefore, the
Commission finds that the changes
proposed in the Advance Notice are
69 17
70 17
CFR 240.17Ad–22(e)(6)(i).
CFR 240.17Ad–22(e)(6)(v).
VerDate Sep<11>2014
18:10 Mar 01, 2018
Jkt 244001
consistent with Rules 17Ad–22(e)(6)(i)
and (v) under the Exchange Act.71
III. Conclusion
It is therefore noticed, pursuant to
Section 806(e)(1)(I) of the Clearing
Supervision Act,72 that the Commission
does not object to advance notice SR–
NSCC–2017–808 and that NSCC is
authorized to implement the proposed
change as of the date of this notice or
the date of an order by the Commission
approving proposed rule change SR–
NSCC–2017–020 that reflects rule
changes that are consistent with this
Advance Notice, whichever is later.
By the Commission.
Brent J. Fields,
Secretary.
[FR Doc. 2018–04237 Filed 3–1–18; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–82772; File No. SR–FINRA–
2018–010]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Notice of Filing and
Immediate Effectiveness of a Proposed
Rule Change To Revise the Securities
Trader (Series 57) Examination
February 26, 2018.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that on February
12, 2018, Financial Industry Regulatory
Authority, Inc. (‘‘FINRA’’) filed with the
Securities and Exchange Commission
(‘‘SEC’’ or ‘‘Commission’’) the proposed
rule change as described in Items I, II,
and III below, which Items have been
prepared by FINRA. FINRA has
designated the proposed rule change as
‘‘constituting a stated policy, practice,
or interpretation with respect to the
meaning, administration, or
enforcement of an existing rule’’ under
Section 19(b)(3)(A)(i) of the Act 3 and
Rule 19b–4(f)(1) thereunder,4 which
renders the proposal effective upon
receipt of this filing by the Commission.
The Commission is publishing this
notice to solicit comments on the
proposed rule change from interested
persons.
71 17
CFR 240.17Ad–22(e)(6)(i) and (v).
U.S.C. 5465(e)(1)(I).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 15 U.S.C. 78s(b)(3)(A)(i).
4 17 CFR 240.19b–4(f)(1).
72 12
PO 00000
Frm 00077
Fmt 4703
Sfmt 4703
9039
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
FINRA is proposing revisions to the
content outline and selection
specifications for the Securities Trader
(Series 57) examination as part of the
restructuring of the representative-level
examination program.5 In addition,
FINRA is proposing to make changes to
the format of the content outline. FINRA
is not proposing any textual changes to
the By-Laws, Schedules to the By-Laws
or Rules of FINRA.
The revised Series 57 content outline
is attached.6 The revised Series 57
selection specifications have been
submitted to the Commission under
separate cover with a request for
confidential treatment pursuant to SEA
Rule 24b–2.7
The text of the proposed rule change
is available on FINRA’s website at
https://www.finra.org, at the principal
office of FINRA and at the
Commission’s Public Reference
Room.[sic]
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission,
FINRA included statements concerning
the purpose of and basis for the
proposed rule change and discussed any
comments it received on the proposed
rule change. The text of these statements
may be examined at the places specified
in Item IV below. FINRA 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
Section 15A(g)(3) of the Act 8
authorizes FINRA to prescribe standards
of training, experience, and competence
for persons associated with FINRA
members. In accordance with that
provision, FINRA has developed
5 FINRA also is proposing corresponding
revisions to the Series 57 question bank. Based on
instruction from SEC staff, FINRA is submitting this
filing for immediate effectiveness pursuant to
Section 19(b)(3)(A) of the Act and Rule 19b–4(f)(1)
thereunder, and is not filing the question bank. See
Letter to Alden S. Adkins, Senior Vice President
and General Counsel, NASD Regulation, from
Belinda Blaine, Associate Director, Division of
Market Regulation, SEC, dated July 24, 2000. The
question bank is available for SEC review.
6 The Commission notes that the content outline
is attached to the filing, not to this Notice.
7 17 CFR 240.24b–2.
8 15 U.S.C. 78o–3(g)(3).
E:\FR\FM\02MRN1.SGM
02MRN1
Agencies
[Federal Register Volume 83, Number 42 (Friday, March 2, 2018)]
[Notices]
[Pages 9035-9039]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-04237]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-82780; File No. SR-NSCC-2017-808]
Self-Regulatory Organizations; National Securities Clearing
Corporation; Notice of No Objection To Advance Notice Filing, as
Modified by Amendment No. 1, To Enhance the Calculation of the
Volatility Component of the Clearing Fund Formula That Utilizes a
Parametric Value-at-Risk Model and Eliminate the Market Maker
Domination Charge
February 26, 2018.
National Securities Clearing Corporation (``NSCC'') filed with the
U.S. Securities and Exchange Commission (``Commission'') on December
28, 2017 the advance notice SR-NSCC-2017-808 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) \2\ under the Securities Exchange Act of 1934, as
amended (``Exchange Act''). On January 10, 2018, NSCC filed Amendment
No. 1 to the advance notice.\3\ The advance notice, as modified by
Amendment No. 1 (hereinafter, the ``Advance Notice'') was published for
comment in the Federal Register on February 8, 2018.\4\ The Commission
did not receive any comments on the Advance Notice. This publication
serves as notice that the Commission does not object to the changes set
forth in the Advance Notice.
---------------------------------------------------------------------------
\1\ 12 U.S.C. 5465(e)(1). The Financial Stability Oversight
Council designated NSCC a systemically important financial market
utility 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, NSCC is
required to comply with the Payment, Clearing and Settlement
Supervision Act and file advance notices with the Commission. See 12
U.S.C. 5465(e).
\2\ 17 CFR 240.19b-4(n)(1)(i).
\3\ In Amendment No. 1 to the advance notice, NSCC amended and
replaced in its entirety the originally filed confidential Exhibit
3a with a new confidential Exhibit 3a in order to remove references
to a practice that was not intended for consideration as part of the
filing.
\4\ Securities Exchange Act Release No. 82631 (February 5,
2018), 83 FR 5658 (February 8, 2017) (SR-NSCC-2017-808)
(``Notice''). NSCC also filed a related proposed rule change with
the Commission pursuant to Section 19(b)(1) of the Exchange Act and
Rule 19b-4 thereunder, seeking approval of changes to its rules
necessary to implement the Advance Notice. 15 U.S.C. 78s(b)(1) and
17 CFR 240.19b-4, respectively. The proposed rule change was
published in the Federal Register on January 19, 2018. Securities
Exchange Act Release No. 82494 (January 12, 2018), 83 FR 2828
(January 19, 2018) (SR-NSCC-2017-020). The Commission did not
receive any comments on that proposal.
---------------------------------------------------------------------------
I. Description of the Advance Notice
The Advance Notice consists of changes to NSCC's Rules & Procedures
(``Rules'') \5\ that would enhance NSCC's method for calculating the
daily margin requirement for each NSCC member (``Member'').\6\
Specifically, NSCC proposes to (1) add three new ways to calculate the
volatility component of its Members' margin requirements, and (2)
eliminate an outdated component of the margin calculation, as described
more fully below.\7\ NSCC states that the new volatility component
calculations would enable NSCC to mitigate the credit risks presented
by Member portfolios in a broader range of scenarios and market
conditions than NSCC's current volatility component calculation.\8\
---------------------------------------------------------------------------
\5\ NSCC's Rules, available at https://dtcc.com/~/media/Files/
Downloads/legal/rules/nscc_rules.pdf.
\6\ Notice, 83 FR at 5659.
\7\ Id.
\8\ Id.
---------------------------------------------------------------------------
A key tool that NSCC uses to manage its credit exposures to Members
is the daily calculation and collection of margin from each Member
(``Required Deposit'').\9\ NSCC collects Required Deposits from Members
to mitigate NSCC's potential losses associated with the liquidation of
a Member's portfolio should the Member default.\10\ The aggregate of
all Members' Required Deposits constitutes NSCC's Clearing Fund, which
NSCC can access should a defaulting Member's own Required Deposit be
insufficient to satisfy NSCC's losses caused by the liquidation of the
Member's portfolio.\11\
---------------------------------------------------------------------------
\9\ Id.
\10\ Id.
\11\ Id.
---------------------------------------------------------------------------
A. Evenly-Weighted Volatility Estimation
Each Member's Required Deposit consists of several components.\12\
Generally, the largest component of a Member's Required Deposit is the
volatility component, which is designed to capture the market price
risk associated with each Member's portfolio at a 99th percentile level
of confidence.\13\ NSCC currently calculates the volatility component
using a parametric Value-at-Risk (``VaR'') model.\14\ NSCC's current
VaR calculation places more emphasis on recent market observations
(such as recent price history) for the purpose of estimating current
market price volatility levels, based on the assumption that the most
recent price history is more relevant and accurate for measuring
current market price volatility levels (referred to as an
``exponentially-weighted volatility estimation'').\15\ However,
volatility in the equity markets often rapidly reverts to more commonly
observed levels, followed by a subsequent spike.\16\ While a VaR
calculation that applies exclusively an exponentially-weighted
volatility estimation can capture sudden increases in volatility, it
may result in a swift decline in margin that does not adequately
capture the risks related to a rapid decrease in market price
volatility levels.\17\ NSCC proposes to mitigate this shortcoming by
adding another method for computing the VaR calculation that does not
diminish the value of older market observations.\18\ Specifically, NSCC
proposes to add a VaR calculation that gives equal weight to all
historical volatility observations during a specified look-back period
(referred to by NSCC as an ``evenly-weighted volatility
estimation''),\19\ which could
[[Page 9036]]
result in margin requirement amounts during non-volatile periods
greater than margin requirement amounts based upon the exponentially-
weighted volatility estimation.\20\ Under the proposal, NSCC would
calculate both the exponentially-weighted volatility estimation and the
evenly-weighted volatility estimation, and the greater result would
represent the ``Core Parametric Estimation.'' \21\
---------------------------------------------------------------------------
\12\ See Procedure XV (Clearing Fund Formula and Other Matters)
of the Rules, supra note 5.
\13\ Notice, 83 FR at 5659-60.
\14\ Notice, 83 FR at 5660.
\15\ Id.
\16\ Id.
\17\ Id.
\18\ Id.
\19\ Id.
\20\ Id.
\21\ Notice, 83 FR at 5661.
---------------------------------------------------------------------------
B. Gap Risk Measure
In addition to the Core Parametric Estimation, NSCC proposes to add
a second method for determining the volatility component of a Member's
Required Deposit.\22\ This second method, referred to as the Gap Risk
Measure, would help address risks that are unique to Member portfolios
that hold a concentrated position in a specific security.\23\ More
specifically, when a Member's portfolio holds a concentrated position
in a specific security, such that the position represents a significant
percentage of the entire portfolio's value, the portfolio may be more
susceptible to risks associated with issuer-specific events affecting
the price of the concentrated security.\24\ Such events include earning
reports, management changes, merger announcements, insolvency, or other
unexpected issuer-specific events (collectively, ``Gap Risk
Events'').\25\
---------------------------------------------------------------------------
\22\ Id.
\23\ Id.
\24\ Id.
\25\ Id.
---------------------------------------------------------------------------
NSCC has observed that portfolios with a concentration level of
more than 30 percent in a specific security tend to have backtesting
coverage below the 99 percent confidence level.\26\ To mitigate the
concentration risk posed by such portfolios, NSCC proposes the Gap Risk
Measure, which would apply to all individual equities in a Member's
portfolio, but only when the Member holds a position in a security that
meets a 30 percent concentration threshold relative to the remainder of
the portfolio.\27\
---------------------------------------------------------------------------
\26\ Id.
\27\ Id.
---------------------------------------------------------------------------
NSCC also has observed that exchange-traded products (``ETPs'')
that track to a broad market index are generally not susceptible to Gap
Risk Events.\28\ Accordingly, NSCC would not apply the Gap Risk Measure
to positions in such index-based ETPs, even if the 30 percent
concentration threshold is met.\29\ However, non-index-based ETPs and
index-based ETPs that track a narrow market index are susceptible to
Gap Risk Events, and would, therefore, be subject to the Gap Risk
Measure, provided that the 30 percent concentration threshold is
met.\30\
---------------------------------------------------------------------------
\28\ Id.
\29\ Id.
\30\ Id. NSCC states that it would use a third-party market
provider to identify index-based ETPs. Id. The third-party market
provider would identify index-based ETPs as those with criteria that
require the portfolio returns to track to a broad market index. Id.
ETPs that do not meet this criteria would not be considered index-
based ETPs and, therefore, would be included in the Gap Risk Measure
calculation. Id.
---------------------------------------------------------------------------
When applicable, NSCC would calculate the Gap Risk Measure by
multiplying the gross market value of the largest (non-index) position
in the portfolio by a percent of not less than 10 percent.\31\
---------------------------------------------------------------------------
\31\ Id. NSCC would determine such percent empirically as no
less than the larger of the 1st and 99th percentiles of three-day
returns of a set of CUSIPs that are subject to the volatility
component, giving equal rank to each to determine which has the
highest movement over that three-day period. Id. NSCC would use a
look-back period of not less than ten years that includes a one-year
stress period. Id. If the one-year stress period overlaps with the
look-back period, only the non-overlapping period would be combined
with the look-back period. Id. The result would then be rounded up
to the nearest whole percentage. Id.
---------------------------------------------------------------------------
C. Portfolio Margin Floor
In addition to the Core Parametric Estimation and the Gap Risk
Measure, NSCC proposes to add a third method for determining the
volatility component of a Member's Required Deposit.\32\ This third
method, referred to as the Portfolio Margin Floor, would help address
risks that may not be adequately accounted for by the Core Parametric
Estimation or the Gap Risk Measure.\33\ For example, a volatility
component based solely on a parametric VaR model calculation may prove
inadequate where there is low market price volatility and the portfolio
holds either large gross market values or large net directional market
values.\34\ In such cases, the model may not collect sufficient margin,
which could hinder NSCC's ability to effectively liquidate or hedge the
Member's portfolio in three business days.\35\
---------------------------------------------------------------------------
\32\ Notice, 83 FR at 5661.
\33\ Id.
\34\ Notice, 83 FR at 5662.
\35\ Id.
---------------------------------------------------------------------------
NSCC proposes the Portfolio Margin Floor to operate as a floor to
(i.e., minimum amount of) a Member's volatility component.\36\
Specifically, the Portfolio Margin Floor would be based on the balance
and direction of the positions in the Member's portfolio and would be
designed to be proportional to the market value of the portfolio.\37\
---------------------------------------------------------------------------
\36\ Id.
\37\ Id.
---------------------------------------------------------------------------
The Portfolio Margin Floor would be the sum of two separate
calculations, both of which would measure the market value of the
portfolio based on the direction of net positions in the portfolio.\38\
First, NSCC would calculate the net directional market value of the
portfolio by calculating the absolute difference between the market
value of the long positions and shorts positions in the portfolio,\39\
then multiplying that amount by a percentage.\40\ Second, NSCC would
calculate the balanced market value of the portfolio by taking the
lowest market value of either the long or short positions in the
portfolio,\41\ then multiplying that value by a percentage.\42\ The
combined results of these two calculations would constitute the final
Portfolio Margin Floor amount.\43\
---------------------------------------------------------------------------
\38\ Id.
\39\ For example, if the market value of the long positions is
$100,000, and the market value of the short positions is $200,000,
the net directional market value of the portfolio would be $100,000.
Id.
\40\ Id. NSCC would determine the applicable percentage by
examining the annual historical volatility levels of benchmark
indices over a historical look-back period. Id.
\41\ For example, if the market value of the long positions is
$100,000, and the market value of the short positions is $110,000,
the balanced market value of the portfolio would be $100,000. Id.
\42\ Id. NSCC would determine the applicable percentage to be an
amount that covers the transaction costs and other relevant risks
associated with the positions in the portfolio. Id.
\43\ Id.
---------------------------------------------------------------------------
Finally, in order to choose the amount to be charged as the
volatility component of a Member's Required Deposit, NSCC would compare
the amounts calculated by the Portfolio Margin Floor, the Gap Risk
Measure (if applicable), and the Core Parametric Estimation. NSCC then
would use the highest of those three calculations as the volatility
component of the Member's Required Deposit.\44\
---------------------------------------------------------------------------
\44\ Id.
---------------------------------------------------------------------------
D. Elimination of the Market Maker Domination Component
NSCC proposes to eliminate the Market Maker Domination Component
(``MMD Charge'') from its Clearing Fund formula.\45\ The MMD Charge is
an existing component of the Clearing Fund formula calculated for
Members that are Market Makers and Members that clear for Market
Makers.\46\ The MMD Charge was developed to address the risks presented
by concentrated positions (of the overall unsettled long position in
the security) held by Market Makers.\47\ More specifically, the charge
[[Page 9037]]
is designed to address securities that are susceptible to marketability
and liquidation impairment because of the relative size of the
positions that NSCC would have to liquidate or hedge in the case of a
Market Maker default.\48\
---------------------------------------------------------------------------
\45\ Id.
\46\ Id; see also Procedure XV, Section I(A)(1)(d) of the Rules,
supra note 5.
\47\ Notice, 83 FR at 5662.
\48\ Id.
---------------------------------------------------------------------------
Under the current Rules, NSCC may impose the MMD Charge if the
Market Maker (either the Member or the correspondent of the Member)
holds a position that is greater than 40 percent of the overall
unsettled long position (i.e., the sum of each clearing broker's net
long position) in a specific security.\49\ NSCC calculates the MMD
Charge as the sum of each of the absolute values of the net positions
in the relevant securities, less the reported amount of excess net
capital for that Member.\50\
---------------------------------------------------------------------------
\49\ Id.
\50\ Id. NSCC does not apply the excess net capital offset for
Members with the weakest credit rating (i.e. 7) on the Credit Risk
Rating Matrix. See Procedure XV, Sections I(A)(1)(d) and I(A)(2)(c)
of the Rules, supra note 5.
---------------------------------------------------------------------------
NSCC states that since implementation of the MMD Charge, several
developments in the U.S. equity markets (e.g., improved price
transparency, access across exchange venues, and participation by
market liquidity providers) have reduced the risks that the MMD Charge
was designed to address.\51\ NSCC further states that the MMD Charge
may not effectively address concentration risk because the MMD Charge
(1) only applies to positions in certain securities, as described
above, (2) does not address concentration risk presented by positions
in securities that are not listed on NASDAQ or in securities traded by
firms that are not Market Makers, and (3) does not account for
concentration in market capitalization categories.\52\ NSCC states that
the proposed Gap Risk Measure would provide better concentration risk
coverage than the MMD Charge because the former would apply to all
Members, whereas the latter only applies to Market Makers.\53\
---------------------------------------------------------------------------
\51\ Notice, 83 FR at 5662.
\52\ Id.
\53\ Id.
---------------------------------------------------------------------------
II. Discussion and Commission Findings
Although the Clearing Supervision Act does not specify a standard
of review for an advance notice, its stated purpose is instructive: To
mitigate systemic risk in the financial system and promote financial
stability by, among other things, promoting uniform risk management
standards for systemically important financial market utilities and
strengthening the liquidity of systemically important financial market
utilities.\54\
---------------------------------------------------------------------------
\54\ See 12 U.S.C. 5461(b).
---------------------------------------------------------------------------
Section 805(a)(2) of the Clearing Supervision Act \55\ 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
Clearing Supervision Act \56\ provides the following objectives and
principles for the Commission's risk-management standards prescribed
under Section 805(a):
---------------------------------------------------------------------------
\55\ 12 U.S.C. 5464(a)(2).
\56\ 12 U.S.C. 5464(b).
---------------------------------------------------------------------------
Promote robust risk management;
promote safety and soundness;
reduce systemic risks; and
support the stability of the broader financial system.
Section 805(c) of the Clearing Supervision Act 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.\57\
---------------------------------------------------------------------------
\57\ 12 U.S.C. 5464(c).
---------------------------------------------------------------------------
The Commission has adopted risk-management standards under Section
805(a)(2) of the Clearing Supervision Act \58\ and Section 17A of the
Exchange Act (``Rule 17Ad-22'').\59\ Rule 17Ad-22 requires 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 their operations and
risk-management practices on an ongoing basis.\60\ Therefore, it is
appropriate for the Commission to review proposed changes in advance
notices for consistency with the objectives and principles of the risk-
management standards described in Section 805(b) of the Clearing
Supervision Act \61\ and against Rule 17Ad-22.\62\
---------------------------------------------------------------------------
\58\ 12 U.S.C. 5464(a)(2).
\59\ 15 U.S.C. 78q-1.
\60\ 17 CFR 240.17Ad-22.
\61\ 12 U.S.C. 5464(b).
\62\ 17 CFR 240.17Ad-22.
---------------------------------------------------------------------------
A. Consistency With Section 805(b) of the Clearing Supervision Act
The Commission believes that the changes proposed in the Advance
Notice are consistent with each of the objectives and principles
described in Section 805(b) of the Act.\63\ Specifically, as discussed
below, the Commission believes that the changes proposed in the Advance
Notice are consistent with promoting robust risk management in the area
of credit risk and promoting safety and soundness, which in turn, would
help reduce systemic risk and support the stability of the broader
financial system.
---------------------------------------------------------------------------
\63\ 12 U.S.C. 5464(b).
---------------------------------------------------------------------------
The Commission believes that the proposed changes promote robust
risk management by adding three new volatility component calculations
that would better enable NSCC to mitigate the credit risks presented by
Member portfolios in a broader range of scenarios and market conditions
than NSCC's current volatility component calculation.
First, as described above, NSCC currently calculates the volatility
component of each Member's Required Deposit using a VaR calculation
that relies exclusively on an exponentially-weighted volatility
estimation. However, the current VaR calculation places more emphasis
on recent market observations, which may result in a swift decline in
margin that does not adequately capture the risks related to a rapid
decrease in market price volatility levels. To address this
shortcoming, NSCC proposes to (1) add a VaR calculation that relies on
an evenly-weighted volatility estimation (i.e., that gives equal weight
to all historical volatility observations during a specified look-back
period), (2) compare the amounts of both VaR calculations (i.e., based
on both evenly- and exponentially-weighted volatility estimations), and
(3) use the greater amount as the Core Parametric Estimation.
Accordingly, the Commission believes adding the VaR calculation based
on an evenly-weighted volatility estimation would enable NSCC to more
effectively limit its credit exposure to Members in market conditions
that reflect a rapid decrease in market price volatility levels.
Second, as described above, when a Member's portfolio holds a
concentrated position in a specific security beyond a significant
percentage of the entire portfolio's value, the portfolio may be more
susceptible to Gap Risk Events. In such a scenario, NSCC's current
volatility component calculation may result in inadequate margin
coverage. To address this issue, NSCC has proposed the Gap Risk Measure
as an alternative volatility component calculation. The Gap Risk
Measure is designed to provide better margin coverage in such a
scenario as it would apply to all individual equities (including non-
index-based and narrow-index-based ETPs, as described above) when a
Member maintains a position in its portfolio that exceeds the 30
percent
[[Page 9038]]
concentration threshold. Accordingly, the Commission believes adding
the Gap Risk Measure would enable NSCC to more effectively limit its
credit exposure to Members in certain scenarios in which a Member holds
a security that meets the 30 percent concentration threshold relative
to the remainder of its portfolio.
Third, as described above, when a Member's portfolio holds either
large gross market values or large net directional market values in a
period of low market price volatility, NSCC's current volatility
component calculation may not result in adequate margin, which could
hinder NSCC's ability to effectively liquidate or hedge the Member's
portfolio in the event of the Member's default. To address this
concern, NSCC proposes the Portfolio Margin Floor, which would operate
as a floor to (i.e., minimum amount of) the volatility component of a
Member's Required Deposit. Accordingly, the Commission believes adding
the Portfolio Margin Floor would enable NSCC to more effectively limit
its credit exposure to Members in certain scenarios, such as when a
Member's portfolio holds either large gross market values or large net
directional market values and market prices exhibit low volatility.
Finally, to help ensure that the amount of margin that NSCC
collects as the volatility component of a Member's Required Deposit
would help mitigate each of the specific concerns addressed by the Core
Parametric Estimation, Gap Risk Measure, and Portfolio Margin Floor,
NSCC would assess the largest amount of those three calculations as the
volatility component of the Member's Required Deposit.
In addition to the three proposed volatility component
calculations, NSCC also proposes to eliminate the MMD Charge. As
described above, NSCC has found the MMD Charge to be an inefficient and
ineffective component of the Clearing Fund formula that may not
accurately capture the credit risk presented by a Member's portfolio.
More specifically, the charge does not cover a range of scenarios and
market conditions that would be covered by the proposed Gap Risk
Measure. Moreover, in contrast to the proposed Gap Risk Measure, the
MMD Charge (1) only applies to positions in certain securities, (2)
does not address concentration risk presented by positions in
securities that are not listed on NASDAQ, (3) does not account for
concentration in market capitalization categories, and (4) only applies
to Market Makers. Accordingly, NSCC's proposal to eliminate the MMD
Charge is designed to remove an obsolete component from the Clearing
Fund formula.
Taken together, each of the above described changes would enhance
NSCC's current method for calculating each Member's volatility
component, enabling NSCC to produce margin levels more commensurate
with the risks associated with its Members' portfolios in a broader
range of scenarios and market conditions, and, thus, more effectively
cover its credit exposure to its Members. Therefore, the Commission
believes the changes proposed in the Advance Notice are consistent with
promoting robust risk management, consistent with Section 805(b) of the
Clearing Supervision Act.\64\
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\64\ Id.
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The Commission also believes that the proposed changes would
promote safety and soundness at NSCC, which, in turn, would help reduce
systemic risk and support the stability of the broader financial
system. As described above, the proposed changes are designed to better
limit NSCC's credit exposure to Members in the event of a Member
default. More specifically, the proposed VaR calculation based on an
evenly-weighted volatility estimation would enable NSCC to better
manage its credit exposure to Members in market conditions that reflect
a rapid decrease in market price volatility levels. Meanwhile, the
proposed Gap Risk Measure would enable NSCC to manage its credit
exposure to Member portfolios that are more susceptible to Gap Risk
Events. Finally, the proposed Portfolio Margin Floor would enable NSCC
to better manage its credit exposure to Members in certain scenarios,
such as low market price volatility when a Member's portfolio holds
either large gross market values or large net directional market
values.
By better limiting credit exposure to its Members, NSCC's proposed
changes are designed to help ensure that, in the event of a Member
default, NSCC's operations would not be disrupted and non-defaulting
Members would not be exposed to losses that they cannot anticipate or
control. As such, the Commission finds that the proposed changes would
promote safety and soundness, which in turn, would reduce systemic
risks and support the stability of the broader financial system,
consistent with Section 805(b) of the Clearing Supervision Act.\65\
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\65\ Id.
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Therefore, the Commission believes that the changes proposed in the
Advance Notice are consistent with Section 805(b) of the Clearing
Supervision Act.\66\
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\66\ Id.
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B. Consistency With Rule 17Ad-22(e)(4)(i) of the Exchange Act
The Commission believes that the changes proposed in the Advance
Notice are consistent with Rule 17Ad-22(e)(4)(i) under the Exchange
Act, which requires that NSCC establish, implement, maintain and
enforce written policies and procedures reasonably designed to
effectively identify, measure, monitor, and manage its credit exposures
to participants and those arising from its payment, clearing, and
settlement processes, including by maintaining sufficient financial
resources to cover its credit exposure to each participant fully with a
high degree of confidence.\67\
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\67\ 17 CFR 240.17Ad-22(e)(4)(i).
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As described above, the Commission believes the proposed VaR
calculation based on an evenly-weighted volatility estimation would
enable NSCC to better manage its credit exposure to Members in market
conditions that reflect a rapid decrease in market price volatility
levels; the proposed Gap Risk Measure would enable NSCC to better
manage its credit exposure to Member portfolios that are more
susceptible to Gap Risk Events; and the proposed Portfolio Margin Floor
would enable NSCC to better manage its credit exposure to Members in
certain scenarios, such as when a Member's portfolio holds either large
gross market values or large net directional market values and market
prices exhibit low volatility. Furthermore, NSCC would assess a Member
the largest of these three calculations as the Member's volatility
component to its Required Deposit.
Each of these proposed changes is designed to help NSCC more
effectively identify, measure, monitor, and manage its credit exposures
to its Members. In doing so, the proposed changes would enable NSCC to
more accurately assess the volatility component of a Member's Required
Deposit and, thus, help NSCC maintain sufficient financial resources to
cover its credit exposure to each Member fully with a high degree of
confidence. Therefore, the Commission finds that the changes proposed
in the Advance Notice are consistent with Rule 17Ad-22(e)(4)(i) under
the Exchange Act.\68\
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\68\ Id.
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C. Consistency With Rule 17Ad-22(e)(6)(i) and (v) of the Exchange Act
The Commission believes that the changes proposed in the Advance
[[Page 9039]]
Notice are consistent with Rule 17Ad-22(e)(6)(i) under the Exchange
Act, which requires that NSCC establish, implement, maintain and
enforce written policies and procedures reasonably designed to cover
its credit exposures to its participants by establishing a risk-based
margin system that, at a minimum considers, and produces margin levels
commensurate with, the risks and particular attributes of each relevant
product, portfolio, and market.\69\ Furthermore, the Commission
believes that the changes proposed in the Advance Notice are consistent
with Rule 17Ad-22(e)(6)(v) under the Exchange Act, which requires that
NSCC establish, implement, maintain and enforce written policies and
procedures reasonably designed to use an appropriate method for
measuring credit exposure that accounts for relevant product risk
factors and portfolio effects across products.\70\
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\69\ 17 CFR 240.17Ad-22(e)(6)(i).
\70\ 17 CFR 240.17Ad-22(e)(6)(v).
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As described above, the Commission believes the proposed VaR
calculation based on an evenly-weighted volatility estimation would
enable NSCC to better manage its credit exposure to Members in certain
market conditions with a rapid decrease in market price volatility
levels; the proposed Gap Risk Measure would enable NSCC to better
manage its credit exposure to Member portfolios that are more
susceptible to Gap Risk Events; and the proposed Portfolio Margin Floor
would enable NSCC to better manage its credit exposure to Members in
certain scenarios, such as low market price volatility when a Member's
portfolio holds either large gross market values or large net
directional market values and market prices exhibit low volatility.
Moreover, NSCC would assess a Member the largest of these three
calculations as the Member's volatility component to its Required
Deposit.
These three proposed volatility component calculations are designed
to help improve NSCC's risk-based margin system by enabling NSCC to
produce margin levels that are more commensurate with the risks and
particular attributes of the relevant products, portfolios, and markets
that NSCC serves. Additionally, as described above, the three proposed
volatility component calculations are designed to use methods that are
more appropriately tailored for measuring credit exposure that account
for specific risk factors and portfolio effects. Therefore, the
Commission finds that the changes proposed in the Advance Notice are
consistent with Rules 17Ad-22(e)(6)(i) and (v) under the Exchange
Act.\71\
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\71\ 17 CFR 240.17Ad-22(e)(6)(i) and (v).
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III. Conclusion
It is therefore noticed, pursuant to Section 806(e)(1)(I) of the
Clearing Supervision Act,\72\ that the Commission does not object to
advance notice SR-NSCC-2017-808 and that NSCC is authorized to
implement the proposed change as of the date of this notice or the date
of an order by the Commission approving proposed rule change SR-NSCC-
2017-020 that reflects rule changes that are consistent with this
Advance Notice, whichever is later.
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\72\ 12 U.S.C. 5465(e)(1)(I).
By the Commission.
Brent J. Fields,
Secretary.
[FR Doc. 2018-04237 Filed 3-1-18; 8:45 am]
BILLING CODE 8011-01-P