Self-Regulatory Organizations; ICE Clear Europe Limited; Order Approving Proposed Rule Change Relating to Amendments to the ICE Clear Europe CDS Risk Policy (the “CDS Risk Policy”), CDS Clearing Back-Testing Policy (the “Back-Testing Policy”) and CDS Stress-Testing Policy (the “Stress-Testing Policy”) (Collectively, the “CDS Policies”), 8348-8353 [2019-04085]
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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 20549–1090 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 4–546 and should be submitted
on or before March 28, 2019.
By the Commission.
Eduardo A. Aleman,
Deputy Secretary.
[FR Doc. 2019–04083 Filed 3–6–19; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–85236; File No. SR–ICEEU–
2018–010]
Self-Regulatory Organizations; ICE
Clear Europe Limited; Order Approving
Proposed Rule Change Relating to
Amendments to the ICE Clear Europe
CDS Risk Policy (the ‘‘CDS Risk
Policy’’), CDS Clearing Back-Testing
Policy (the ‘‘Back-Testing Policy’’) and
CDS Stress-Testing Policy (the
‘‘Stress-Testing Policy’’) (Collectively,
the ‘‘CDS Policies’’)
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March 1, 2019.
I. Introduction
On November 13, 2018, ICE Clear
Europe Limited (‘‘ICE Clear Europe’’)
filed with the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder,2 a proposed rule
change to modify and update certain
provisions of its risk policies related to
CDS Contracts. The proposed rule
change was published for comment in
the Federal Register on December 4,
2018.3 On December 26, 2018, the
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 Securities Exchange Act Release No. 84667
(Nov. 28, 2018), 83 FR 62638 (Dec. 4, 2018) (SR–
ICEEU–2018–010) (‘‘Notice’’).
2 17
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Commission extended the period to take
action on the proposed rule change to
March 4, 2019.4 The Commission did
not receive comments on the proposed
rule change. For the reasons discussed
below, the Commission is approving the
proposed rule change.
II. Description of the Proposed Rule
Change
A. CDS Risk Policy
The proposed rule change would
incorporate into the CDS Risk Policy a
description of ICE Clear Europe’s overall
Board risk appetite and limit
framework.5 Currently the CDS Risk
Policy does not reference the
framework, but other ICE Clear Europe
policies, including the Stress-Testing
Policy, reference the framework. The
description of the framework that the
proposed rule change would add to the
CDS Risk Policy would be consistent
with the description of the framework
that other ICE Clear Europe policies,
including the Stress-Testing Policy, use.
As described in the proposed change to
the CDS Risk Policy, the framework
would use Board-level risk appetite
statements, risk appetite metrics, and
management risk limits, and would be
subject to review at least annually.6 The
proposed rule change would add
description of the framework to the CDS
Risk Policy to make clear that the CDS
Risk Policy is part of ICE Clear Europe’s
overall risk management.
The proposed rule change would
specifically address periodic reviews of
margin requirements and the related
margin methodology and parameters.
Currently, the CDS Risk Policy provides
that ICE Clear Europe conducts a
statistical analysis of the margin levels
and market performance on at least a
monthly basis. Similarly, under the
proposed revised policy, the clearing
risk department would be required to
perform such a review at least monthly,
consistent with applicable legal
requirements.7
The proposed rule change would
provide additional detail about the use
of the results of such reviews by ICE
Clear Europe management. Specifically,
under the proposed rule change, the
head of first line clearing risk would
present the results of the monthly
review to ICE Clear Europe’s Model
Oversight Committee (‘‘MOC’’).8 The
4 Securities Exchange Act Release No. 84957 (Dec.
26, 2018), 84 FR 855 (Jan. 31, 2019) (SR–ICEEU–
2018–010).
5 Capitalized terms not otherwise defined herein
shall have the meanings given to them in the CDS
Policies or ICE Clear Europe Rulebook.
6 Notice, 83 FR at 62638.
7 See 17 CFR 240.17Ad–22(e)(6)(vi).
8 Notice, 83 FR at 62638.
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head of first line clearing risk would
report to the President of ICE Clear
Europe and would manage ICE Clear
Europe’s first line clearing risk team
including default management, liquidity
risk, market risk and counterparty risk.
Moreover, the proposed rule change
would provide that at the end of each
quarter, the Clearing Risk Department
would share its monthly reviews from
the quarter with the Risk Oversight
Department (‘‘ROD’’), which would
perform a second-line review. The head
of second line clearing risk then would
present the results of this quarterly
review to the MOC. The head of second
line clearing risk would be ICE Clear
Europe’s Chief Risk Officer and would
report to the President and the senior
independent director of ICE Clear
Europe.9 The CDS Risk Policy currently
provides only that the Risk Management
Department recommends margin
methodology changes to the President
and Board of Directors of ICE Clear
Europe for their approval. Thus, the
proposed rule change would provide
more explanation regarding ICE Clear
Europe’s use of the monthly reviews of
margin levels.
The proposed amendments would
also clarify that the Clearing Risk
Department would recommend
proposed margin methodology changes
resulting from the review process to the
Board for approval. Currently, the CDS
Risk Policy provides that the ICE Clear
Europe Risk Management Department
recommends margin methodology
changes to the President and the Board
for their approval. Thus, this proposed
change would update the name of the
responsible ICE Clear Europe
department from Risk Management
Department to Clearing Risk
Department. Moreover, this proposed
change would eliminate a redundancy
in providing that ICE Clear Europe’s
Board alone shall approve margin
methodology changes. Because ICE
Clear Europe’s President also serves on
the Board, it would not be necessary for
both the President and the Board to
separately approve margin methodology
changes.10
The proposed rule change would
specify in further detail the timing and
extent of backtesting and stress
testing.11 Currently, the CDS Risk Policy
provides that ICE Clear Europe conducts
backtesting on a daily basis, but the
Policy does not specify that ICE Clear
Europe uses standard predetermined
9 Id.
10 See https://www.theice.com/publicdocs/clear_
europe/Organisational_Structure_Objectives_
Strategy.pdf.
11 Notice, 83 FR at 62638.
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parameters and assumptions, nor does it
provide any information about
sensitivity analysis. Consistent with
applicable law, the proposed rule
change would require that: (i) ICE Clear
Europe’s Clearing Risk Department
conduct backtesting at least once each
day using standard predetermined
parameters and assumptions; (ii) ICE
Clear Europe conduct sensitivity
analyses of its margin models and
review parameters and assumptions for
backtesting on at least a monthly basis;
and (iii) ICE Clear Europe conduct
sensitivity analyses and reviews more
frequently than monthly when the
relevant products cleared or markets
served display high volatility or become
less liquid or when the size or
concentration of positions held by
Clearing Members increases or
decreases significantly.12 With respect
to stress testing, the CDS Risk Policy
currently provides details regarding
stress testing scenarios and provides
that ICE Clear Europe executes such
scenarios on a regular basis, but does
not specify that ICE Clear Europe
conducts stress testing daily or uses
standard predetermined parameters and
assumptions. Consistent with applicable
law, the proposed rule change would
require that the clearing risk department
conduct stress testing at least once each
day using standard predetermined
parameters and assumptions, which are
reviewed on at least a monthly basis and
more frequently when the relevant
products cleared or markets served
display high volatility or become less
liquid or when the size or concentration
of positions held by Clearing Members
increases or decreases significantly.13
The proposed rule change would also
establish details regarding policy
governance and reporting. The proposed
rule change would specify that the
models used to support the policy
objectives of the policy are subject to an
annual independent validation and
governance oversight which may be
performed by an independent member
of the ROD or an external validator.14
The CDS Risk Policy does not currently
provide any details regarding validation
of the models used to support the
policy. The CDS Risk Policy owner, who
is the CDS Risk Director and part of the
Clearing Risk Department, would be
responsible for ensuring that the policy
remains up-to-date and is reviewed,
with the support of the ROD.15
The proposed rule change would also
provide a new process for escalation
12 See
17 CFR 240.17Ad–22(e)(6)(vi).
17 CFR 240.17Ad–22(e)(4)(vi).
14 Notice, 83 FR at 62638.
15 Notice, 83 FR at 62638.
13 See
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and reporting of any deviations from the
policy, as well as compliance with
regulatory reporting and filing
requirements and would make the
policy owner responsible for both.
Under the current policy, any changes
to the Policy that affect the risk profile
of ICE Clear Europe are subject to Board
approval, and any exceptions or
deviations from the Policy must be
reported to the Chief Risk Officer and
escalated to the CDS Risk Committee
and Board Risk Committee, if material.
Under the proposed rule change, the
policy owner must report any deviations
from the Policy or material breaches to
the President of ICE Clear Europe and
the Risk Oversight Department, who
will then proceed with appropriate
governance and further escalation.
Thus, this change ensures that
deviations and material breaches are
reported to the President and Risk
Oversight Department who can then
proceed with Board involvement if
needed. This change also ensures the
involvement of the Risk Oversight
Department, who supports other
functions under the Policy, such as the
reviews discussed above. Finally, this
change would make the process for
escalation and reporting consistent with
the process currently found in the
Stress-Testing Policy.
The proposed rule change would
further specify the roles of various
departments and committees at ICEEU
with respect to the CDS Risk Policy.16
Currently, the CDS Risk Policy describes
the roles of the Risk Working Group
(‘‘RWG’’) (which consists of risk
personnel of Clearing Members, and
provides guidance on risk management
matters, including review of margin and
stress testing parameters), Trading
Advisory Committee (which advises on
pricing processes), and MOC (which is
responsible for overall model risk
management of the Clearing House, and
for oversight of the periodic reviews
described above) in advising on and
approving matters related to the Policy.
The proposed rule change would further
specify the role of the RWG and MOC
in providing feedback and reviewing the
results of ongoing monitoring of models
that support the CDS Risk Policy. The
proposed rule change would also
provide further detail as to the
composition and role of the RWG and
MOC. Finally, the proposed rule change
would make the Clearing Risk
Department, with the support of the
ROD, responsible for adherence to the
policy and relevant appetite metrics.
The proposed rule change would also
update references to various committees
and departments of ICE Clear Europe,
correct typographical and similar errors,
update cross-references, and remove an
unnecessary reference to ICE Clear
Credit.
B. Back-Testing Policy
The proposed rule change would
make changes to the Back-Testing Policy
similar to those changes described
above for the CDS Risk Policy.
Specifically, the proposed rule change
would incorporate into the Back-Testing
Policy a description of ICE Clear
Europe’s overall Board risk appetite and
limit framework.17 Currently the BackTesting Policy does not reference the
framework, but other ICE Clear Europe
policies, including the Stress-Testing
Policy, reference the framework. The
description of the framework that the
proposed rule change would add to the
Back-Testing Policy would be consistent
with the description of the framework
that other ICE Clear Europe policies,
including the Stress-Testing Policy, use.
As described in the proposed change to
the Back-Testing Policy, the framework
would use Board-level risk appetite
statements, risk appetite metrics, and
management risk limits, and would be
subject to review at least annually.18
The proposed rule change would add
description of the framework to the
Back-Testing Policy to make clear that
the Back-Testing Policy is part of ICE
Clear Europe’s overall risk management.
The proposed rule change would also
add the same provisions relating to the
timing of backtesting and related
sensitivity analysis discussed above in
the context of the CDS Risk Policy.19
Currently, the Back-Testing Policy
provides that ICE Clear Europe conducts
backtesting on a daily basis, but the
Policy does not specify that ICE Clear
Europe uses standard predetermined
parameters and assumptions, nor does it
provide any information about
sensitivity analysis.
In addition, the proposed rule change
would clarify the meaning of, and make
other changes to, certain confidence
levels used in the backtesting process.20
Specifically, the proposed rule change
would specify that these confidence
levels represent the confidence to which
models are expected to perform.
Although the Back-Testing Policy
currently describes the confidence
levels that ICE Clear Europe uses in
backtesting, it does not make clear what
these confidence levels represent. Thus,
the proposed change would clarify the
17 Notice,
18 Notice,
83 FR at 62638.
83 FR at 62638.
19 Id.
16 Id.
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20 Notice,
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meaning of the confidence levels and
therefore how those confidence levels
are used in evaluating ICE Clear
Europe’s backtesting. The proposed rule
change would also remove a reference to
the 99% quantile used before EMIR
implementation. ICE Clear Europe no
longer uses this confidence level in
backtesting. Rather, in the guidelines
relating to remediation of poor
backtesting, the proposed rule change
would state explicitly that portfolio
backtesting is done using a confidence
level of 99.5% or higher.
As with the amendments to the CDS
Risk Policy, the proposed rule change
would also establish details regarding
policy governance and reporting.21
Specifically, the proposed rule change
would specify that the models used to
support the objectives of the BackTesting Policy are subject to an annual
independent validation and governance
oversight which may be performed by
an independent member of the ROD or
an external validator. The Back-Testing
Policy does not currently provide
details regarding independent
validation of the models used to support
the Policy. The proposed rule change
would make the Back-Testing Policy
owner, who is the CDS Risk Director
and part of the Clearing Risk
Department, responsible for ensuring
that the Back-Testing Policy remains upto-date and is reviewed, with the
support of the ROD.22 The proposed
rule change would make the Clearing
Risk Department, with the support of
the ROD, responsible for adherence to
the policy and relevant appetite
metrics.23
The proposed rule change would also
provide a new process for escalation
and reporting of any deviations from the
policy, as well as compliance with
regulatory reporting and filing
requirements and would make the
policy owner responsible for both.
Currently, the Back-Testing Policy
provides that the Policy will be
reviewed and approved in accordance
with the Policy Governance Review
Calendar, or whenever the Clearing
House identifies further issues requiring
specific attention under the Policy. The
proposed rule change would provide
that any deviations from the Policy must
be appropriately escalated and reported
in a timely manner by the policy owner
and would also make the policy owner
responsible for reporting any material
breaches or deviations to the President
and Risk Oversight Department. Thus,
this proposed rule change would
21 Notice,
provide additional detail to the
escalation of changes to the Policy as
well as make the process for escalation
and reporting consistent with the
process proposed to be added to the
CDS Risk Policy. Finally, this change
would make the process for escalation
and reporting consistent with the
process proposed for the CDS Risk
Policy and the process currently found
in the Stress-Testing Policy.
The proposed rule change would also
update references to various committees
and departments of ICE Clear Europe,
correct typographical and similar errors,
and update cross-references.
C. Stress-Testing Policy
The proposed rule change would
make changes to the Stress-Testing
Policy similar to those described above
for the CDS Risk Policy. Specifically,
the proposed rule change would amend
the Stress-Testing Policy to include the
same provisions relating to the timing of
stress testing discussed above in the
context of the CDS Risk Policy.24
Currently, the Stress-Testing Policy
provides details regarding stress testing
scenarios and provides that ICE Clear
Europe executes such scenarios on a
regular basis, but does not specify that
ICE Clear Europe conducts stress testing
daily or uses standard predetermined
parameters and assumptions.
The proposed rule change would also
amend the Stress-Testing Policy to
reflect the role of the Board Risk
Committee, in addition to the CDS Risk
Committee, in reviewing and overseeing
stress testing. Specifically, the proposed
rule change would amend the StressTesting Policy to ensure that both the
CDS Risk Committee and the Board Risk
Committee are sufficiently informed to
advise the Board on the safety and
soundness of the risk management
approach and to provide a mechanism
for management and the committees to
test the level of protection offered in the
potential stress scenarios.25 Under the
current policy, the Board Risk
Committee, in addition to the CDS Risk
Committee, reviews and advises on
stress testing results. The current policy
does not specifically require that the
Board Risk Committee be sufficiently
informed to advise the Board on the
safety and soundness of the risk
management approach or provide a
mechanism for the Board Risk
Committee to test the level of protection
offered in the potential stress scenario,
however. Thus, the proposed rule
change would correct this situation and
ensure that the Board Risk Committee is
83 FR at 62639.
22 Id.
24 Notice,
23 Id.
25 Notice,
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83 FR at 62639.
83 FR at 62639.
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sufficiently informed to fulfill its roll
under the Policy.
III. Commission Findings
Section 19(b)(2)(C) of the Act directs
the Commission to approve a proposed
rule change of a self-regulatory
organization if it finds that such
proposed rule change is consistent with
the requirements of the Act and the
rules and regulations thereunder
applicable to such organization.26 For
the reasons given below, the
Commission finds that the proposed
rule change is consistent with Section
17A(b)(3)(F) of the Act 27 and Rules
17Ad–22(e)(2)(i) and (v), (e)(4)(vi), and
(e)(6)(vi) thereunder.28
A. Consistency With Section
17A(b)(3)(F) of the Act
Section 17A(b)(3)(F) of the Act
requires, among other things, that the
rules of ICE Clear Europe be designed to
promote the prompt and accurate
clearance and settlement of securities
transactions and, to the extent
applicable, derivative agreements,
contracts, and transactions, as well as to
assure the safeguarding of securities and
funds which are in the custody or
control of ICE Clear Europe or for which
it is responsible, and, in general, to
protect investors and the public
interest.29
As discussed above, the proposed rule
change would amend the CDS Policies
to provide more detail with respect to
the use of the results of periodic reviews
of margin requirements and the related
methodology by ICE Clear Europe
management, including second-line
reviews and reporting to ICE Clear
Europe’s Chief Risk Officer, President,
and senior independent director. The
proposed rule change would also
specify that ICE Clear Europe’s daily
backtesting uses standard
predetermined parameters and
assumptions and that ICE Clear Europe
conducts sensitivity analyses of its
margin models and reviews parameters
and assumptions for backtesting on at
least a monthly basis, and more
frequently than monthly in certain
cases, as discussed above. Similarly, the
proposed rule change would specify
that ICE Clear Europe conducts stress
testing once each day and that in doing
so, ICE Clear Europe uses standard
predetermined parameters and
assumptions, which are reviewed on at
least a monthly basis and more
26 15
U.S.C. 78s(b)(2)(C).
U.S.C. 78q–1(b)(3)(F).
28 17 CFR 240.17Ad–22(e)(2)(i) and (v), (e)(4)(vi),
and (e)(6)(vi).
29 15 U.S.C. 78q–1(b)(3)(F).
27 15
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frequently, as discussed above. Finally,
with respect to the Back-Testing Policy,
the proposed rule change would clarify
the meaning of confidence levels used
in the backtesting process and eliminate
a confidence level no longer used in
backtesting.
The Commission believes that these
changes, taken as a whole, would help
to improve ICE Clear Europe’s stress
testing and backtesting. In providing
more detail with respect to the use of
the results of periodic reviews of margin
requirements and the related
methodology by ICE Clear Europe
management, including second-line
reviews and reporting to ICE Clear
Europe’s Chief Risk Officer, President,
and senior independent director, the
Commission believes that the proposed
rule change would help to improve ICE
Clear Europe’s evaluation and revision
of its margin requirements, related
methodology, and parameters. The
Commission believes that this, in turn,
would help to ensure that ICE Clear
Europe maintains effective margin
requirements, related methodology, and
parameters.
Similarly, in specifying that stress
testing is conducted daily, the
Commission believes that the proposed
rule change would help improve the
effectiveness of stress testing by
ensuring that it is conducted on a
regular basis. Moreover, in specifying
that in conducting backtesting and
stress testing ICE Clear Europe uses
standard predetermined parameters and
assumptions, the Commission believes
that the proposed rule change would
help ensure the accuracy and reliability
of backtesting and stress testing. Finally,
the Commission believes that in
clarifying the meaning of confidence
levels used in the backtesting process
and removing a confidence level no
longer used by ICE Clear Europe, the
proposed rule change would help to
ensure the effectiveness of ICE Clear
Europe’s backtesting process by helping
to ensure that ICE Clear Europe
conducts backtesting at the correct
confidence level. Because backtesting
and stress testing can help reveal
inadequacies in ICE Clear Europe’s
margin requirements and the models
that support those requirements, the
Commission believes that the proposed
rule change would help to ensure that
ICE Clear Europe maintains effective
margin requirements.
Given that an effective margin system
is necessary to manage ICE Clear
Europe’s credit exposures to its Clearing
Members and the risks associated with
clearing security based swap-related
portfolios, the Commission believes that
the proposed rule change would help
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improve ICE Clear Europe’s ability to
avoid losses that could result from the
mismanagement of such credit
exposures and risks. Because such
losses could disrupt ICE Clear Europe’s
ability to promptly and accurately clear
security based swap transactions, by
making the above-described
improvements to the review and
reporting of ICE Clear Europe’s margin
requirements and timing and scope of
backtesting and stress testing, the
Commission believes that the proposed
rule change would help promote the
prompt and accurate clearance and
settlement of securities transactions.
Similarly, appropriate management of
ICE Clear Europe’s credit exposures to
its Clearing Members and the risks
associated with clearing security based
swap-related portfolios is critical to
avoiding the realization of losses on
such portfolios that could threaten ICE
Clear Europe’s ability to operate,
thereby threatening access to securities
and funds in ICE Clear Europe’s control.
Because the proposed changes would
improve ICE Clear Europe’s ability to
manage such credit exposures by
improving the processes ICE Clear
Europe uses to review and maintain its
margin system, including backtesting
and stress testing, the Commission
believes that the proposed rule change
would help assure the safeguarding of
securities and funds which are in the
custody or control of ICE Clear Europe
or for which it is responsible. Finally,
for both of these reasons, the
Commission believes the proposed rule
change is consistent with protecting
investors and the public interest.
Therefore, the Commission finds that
the proposed rule change would
promote the prompt and accurate
clearance and settlement of securities
transactions, assure the safeguarding of
securities and funds in ICE Clear
Europe’s custody and control, and, in
general, protect investors and the public
interest, consistent with the Section
17A(b)(3)(F) of the Act.30
B. Consistency With Rules
17Ad–22(e)(2)(i) and (v)
Rules 17Ad–22(e)(2)(i) and (v) require
that ICE Clear Europe establish,
implement, maintain and enforce
written policies and procedures
reasonably designed to provide for
governance arrangements that are clear
and transparent and specify clear and
direct lines of responsibility.31
As discussed above, the proposed rule
change would revise the CDS Policies to
specify the roles of various departments
30 15
31 17
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CFR 240.17Ad–22(e)(2)(i) and (v).
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8351
and committees at ICE Clear Europe,
including the role of RWG and MOC in
providing feedback and reviewing the
results of ongoing monitoring of models
that support the CDS Risk Policy and
update references to ICE Clear Europe
committees. The Commission believes
that this change would improve the
transparency of ICE Clear Europe’s
governance arrangements by clarifying
the role played by various departments
and committees in following and
maintaining the CDS Policies.
With respect to the CDS Risk Policy
and Back-Testing Policy specifically, the
Commission believes that the proposed
rule change, in incorporating an overall
Board risk appetite and limit
framework, would help to clarify the
governance around the risk appetite
associated with the CDS Risk Policy and
Back-Testing Policy and make clear that
the policies are part of ICE Clear
Europe’s overall risk management. The
Commission similarly believes that the
proposed rule change would help
improve the transparency of ICE Clear
Europe’s governance arrangements in
specifying that the models used to
support the CDS Risk Policy and BackTesting Policy are subject to an annual
independent validation and governance
oversight. The Commission further
believes that the proposed rule change
would help ICE Clear Europe specify
clear and direct responsibility for the
CDS Risk Policy and Back-Testing
Policy by assigning an owner for each
policy and making that owner
responsible for ensuring that the policy
remains up-to-date and is reviewed.
Similarly, the Commission believes that
in making the clearing risk department,
with the support of the ROD,
responsible for adherence to the policies
and relevant appetite metrics, the
proposed rule change would specify
who is responsible for compliance with
the polices. Finally, the Commission
believes that, in amending the CDS Risk
Policy and Back-Testing Policy to
provide a new process for escalation
and reporting of any deviations from the
policies, as well as compliance with
regulatory reporting and filing
requirements (and make the policy
owner responsible for both), the
proposed rule change would clarify the
governance arrangements with respect
to deviations from the policies. This
proposed change would also make the
process for escalation and reporting
consistent across all of the CDS Policies,
thus further contributing to clarity and
transparency of ICE Clear Europe’s
governance arrangements.
With respect to the Stress-Testing
Policy, the Commission also believes
that the proposed rule change, in
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specifically requiring that the Board
Risk Committee be sufficiently informed
to advise the Board on the safety and
soundness of the risk management
approach, would help to ensure that the
Board Risk Committee is sufficiently
informed to carry out its roll under the
Policy, thereby helping to ensure that
the Board Risk Committee has a clear
and direct responsibility under the
Policy.
Finally, the Commission believes that
in correcting typographical errors and
updating cross-references, as discussed
above, the proposed rule change would
clarify ICE Clear Europe’s governance
arrangements by helping to ensure that
the CDS Policies correctly reference the
positions, departments, and/or
committees responsible under the CDS
Policies.
Therefore, for the above reasons the
Commission finds that the proposed
rule change is consistent with Rules
17Ad–22(e)(2)(i) and (v).32
C. Consistency With Rule
17Ad–22(e)(4)(vi)
Rule 17Ad–22(e)(4)(vi) requires that
ICE Clear Europe 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 testing the
sufficiency of its total financial
resources available to meet the
minimum financial resource
requirements under Rule 17Ad–
22(e)(4)(i) through (iii), as applicable, by
(i) conducting stress testing of its total
financial resources once each day using
standard predetermined parameters and
assumptions; (ii) conducting a
comprehensive analysis on at least a
monthly basis of the existing stress
testing scenarios, models, and
underlying parameters and
assumptions, and considering
modifications to ensure they are
appropriate for determining the required
level of default protection in light of
current and evolving market conditions;
(iii) conducting a comprehensive
analysis of stress testing scenarios,
models, and underlying parameters and
assumptions more frequently than
monthly when the products cleared or
markets served display high volatility or
become less liquid, or when the size or
concentration of positions held by its
participants increases significantly; and
(iv) reporting the results of its analyses
to appropriate decision makers at ICE
Clear Europe, including but not limited
to, its risk management committee or
board of directors.33
As discussed above, ICE Clear
Europe’s policies do not currently
require that stress testing be conducted
daily or that it use standard
predetermined parameters and
assumptions. The proposed rule change
would amend the CDS Risk Policy and
Stress-Testing Policy to require that ICE
Clear Europe’s clearing risk department
conduct stress testing at least once each
day using standard predetermined
parameters and assumptions, which are
reviewed on at least a monthly basis and
more frequently when the relevant
products cleared or markets served
display high volatility or become less
liquid or when the size or concentration
of positions held by Clearing Members
increases or decreases significantly.
Moreover, the proposed rule change
would amend the CDS Risk Policy to
provide greater detail with respect to
ICE Clear Europe’s periodic reviews,
including second-line review and
reporting, of margin requirements,
related methodology, and parameters.
The Commission believes that these
proposed amendments would help
ensure that ICE Clear Europe complies
with the requirements of Rule 17Ad–
22(e)(4)(vi) by establishing standards for
frequency of testing and review and use
of standard predetermined parameters
and assumptions consistent with those
of the rule. Therefore, the Commission
finds that the proposed rule change is
consistent with Rule 17Ad–
22(e)(4)(vi).34
D. Consistency With Rule
17Ad–22(e)(6)(vi)
Rule 17Ad–22(e)(6)(vi) requires that
ICE Clear Europe 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 is
monitored by management on an
ongoing basis and is regularly reviewed,
tested, and verified by (i) conducting
backtests of its margin model at least
once each day using standard
predetermined parameters and
assumptions; (ii) conducting a
sensitivity analysis of its margin model
and a review of its parameters and
assumptions for backtesting on at least
a monthly basis, and considering
modifications to ensure the backtesting
practices are appropriate for
determining the adequacy of its margin
resources; (iii) conducting a sensitivity
analysis of its margin model and a
33 17
32 17
CFR 240.17Ad–22(e)(2)(i) and (v).
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review of its parameters and
assumptions for backtesting more
frequently than monthly during periods
of time when the products cleared or
markets served display high volatility or
become less liquid, or when the size or
concentration of positions held by
participants increases or decreases
significantly; and (iv) reporting the
results of its analyses under to
appropriate decision makers, including
but not limited to, its risk management
committee or board of directors, and
using these results to evaluate the
adequacy of and adjust its margin
methodology, model parameters, and
any other relevant aspects of its credit
risk management framework.35
As discussed above, ICE Clear
Europe’s policies do not currently
require that ICE Clear Europe use
standard predetermined parameters and
assumptions in conducting backtesting
nor do they provide detail regarding
sensitivity analysis. The proposed rule
change would amend the CDS Risk
Policy and Back-Testing Policy to
require that (i) ICE Clear Europe’s
clearing risk department conduct
backtesting at least once each day using
standard predetermined parameters and
assumptions and (ii) ICE Clear Europe
conduct sensitivity analyses of its
margin models and review parameters
and assumptions for backtesting on at
least a monthly basis, and more
frequently than monthly when the
relevant products cleared or markets
served display high volatility or become
less liquid or when the size or
concentration of positions held by
Clearing Members increases or
decreases significantly. Moreover, the
proposed rule change would amend the
CDS Risk Policy to provide greater
detail with respect to ICE Clear Europe’s
periodic reviews, including second-line
review and reporting, of margin
requirements, related methodology, and
parameters.
The Commission believes that these
proposed amendments would help
ensure that ICE Clear Europe complies
with the requirements of Rule 17Ad–
22(e)(6)(vi) by establishing standards for
frequency of testing and review, use of
standard predetermined parameters and
assumptions, and use of sensitivity
analysis consistent with those of the
rule. Therefore, the Commission finds
that the proposed rule change is
consistent with Rule 17Ad–
22(e)(6)(vi).36
35 17
36 17
E:\FR\FM\07MRN1.SGM
CFR 240.17Ad–22(e)(6)(vi).
CFR 240.17Ad–22(e)(6)(vi).
07MRN1
Federal Register / Vol. 84, No. 45 / Thursday, March 7, 2019 / Notices
IV. Conclusion
On the basis of the foregoing, the
Commission finds that the proposal is
consistent with the requirements of the
Act, and in particular, with the
requirements of Section 17A(b)(3)(F) of
the Act 37 and Rules 17Ad–22(e)(2)(i)
and (v), (e)(4)(vi), and (e)(6)(vi)
thereunder.38
It is therefore ordered pursuant to
Section 19(b)(2) of the Act 39 that the
proposed rule change (SR–ICEEU–2018–
010) be, and hereby is, approved.40
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.41
Eduardo A. Aleman,
Deputy Secretary.
[FR Doc. 2019–04085 Filed 3–6–19; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–85225; File No. SR–
EMERALD–2019–06]
Self-Regulatory Organizations; MIAX
Emerald, LLC; Notice of Filing and
Immediate Effectiveness of a Proposed
Rule Change To Amend Exchange
Rule 510, Minimum Price Variations
and Minimum Trading Increments To
Extend the Penny Pilot Program
March 1, 2019.
Pursuant to the provisions of Section
19(b)(1) of the Securities Exchange Act
of 1934 (‘‘Act’’) 1 and Rule 19b–4
thereunder,2 notice is hereby given that
on February 19, 2019, MIAX Emerald,
LLC (‘‘MIAX Emerald’’ or the
‘‘Exchange’’) filed with the Securities
and Exchange Commission
(‘‘Commission’’) a proposed rule change
as described in Items I and II below,
which Items have been prepared by the
Exchange. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange is filing a proposal to
amend Exchange Rule 510, Minimum
Price Variations and Minimum Trading
37 15
U.S.C. 78q–1(b)(3)(F).
CFR 240.17Ad–22(e)(2)(i) and (v), (e)(4)(vi),
and (e)(6)(vi).
39 15 U.S.C. 78s(b)(2).
40 In approving the proposed rule change, the
Commission considered the proposal’s impact on
efficiency, competition, and capital formation. 15
U.S.C. 78c(f).
41 17 CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
amozie on DSK9F9SC42PROD with NOTICES
38 17
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Increments, Interpretations and Policies
.01 to change the date on which the
pilot program for the quoting and
trading of certain options in pennies is
scheduled to expire.
The text of the proposed rule change
is available on the Exchange’s website at
https://www.miaxoptions.com/rulefilings/emerald, at MIAX Emerald’s
principal office, and at the
Commission’s Public Reference Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
Exchange included statements
concerning the purpose of and basis for
the proposed rule change and discussed
any comments it received on the
proposed rule change. The text of these
statements may be examined at the
places specified in Item IV below. The
Exchange has prepared summaries, set
forth in sections A, B, and C below, of
the most significant aspects of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
Background
MIAX Emerald plans to commence
operations as a national securities
exchange registered under Section 6 of
the Act 3 on March 1, 2019. As
described more fully in MIAX Emerald’s
Form 1 application,4 the Exchange is an
affiliate of Miami International
Securities Exchange, LLC (‘‘MIAX
Options’’) and MIAX PEARL, LLC
(‘‘MIAX PEARL’’). MIAX Emerald Rules,
in their current form, were filed as
Exhibit B to its Form 1 on August 16,
2018, and at that time, the above
mentioned rules, were substantially
similar to the rules of the MIAX Options
exchange. In the time between when the
Exchange filed its Form 1 and the time
the Exchange received its approval
order, MIAX Options made changes to
its rule book. In order to ensure
consistent operation of both MIAX
Emerald and MIAX Options by having
consistent rules, the Exchange proposes
to amend MIAX Emerald Rule 510, as
described below.
3 15
U.S.C. 78f.
Securities Exchange Act Release No. 84891
(December 20, 2018), 83 FR 67421 (December 28,
2018) (File No. 10–233) (order approving
application of MIAX EMERALD, LLC for
registration as a national securities exchange).
4 See
PO 00000
Frm 00059
Fmt 4703
Sfmt 4703
8353
Proposal
Once operational, the Exchange will
be a participant in an industry-wide
pilot program that provides for the
quoting and trading of certain option
classes in penny increments (the
‘‘Penny Pilot Program’’ or ‘‘Program’’).
The Penny Pilot Program allows the
quoting and trading of certain option
classes in minimum increments of $0.01
for all series in such option classes with
a price of less than $3.00; and in
minimum increments of $0.05 for all
series in such option classes with a
price of $3.00 or higher. Options
overlying the PowerShares QQQTM
(‘‘QQQ’’), SPDR® S&P 500® ETF
(‘‘SPY’’), and iShares® Russell 2000 ETF
(‘‘IWM’’), however, are quoted and
traded in minimum increments of $0.01
for all series regardless of the price. The
Penny Pilot Program was initiated at the
then existing option exchanges in
January 2007 5 and currently includes
more than 300 of the most active option
classes. Rule 510, Interpretations and
Policies .01, currently states that the
Penny Pilot Program is scheduled to
expire on December 31, 2018. The
purpose of the proposed rule change is
to modify the expiration date set forth
in Rule 510, to match the most recent
expiration date, as updated by the other
options exchanges, including MIAX
Options.6
In addition to changing the date on
which the Penny Pilot Program will
expire, which will be June 30, 2019, the
Exchange proposes to make one
additional change to the Rule.
Currently, Interpretations and Policies
.01, states that the Exchange will replace
any Penny Pilot issues that have been
delisted with the next most actively
traded multiply listed option classes
that are not yet included in the Penny
Pilot Program, and that the replacement
issues will be selected based on trading
activity in the previous six months.
Such option classes will be added to the
Penny Pilot Program on the second
trading day following July 1, 2018.7
5 See Securities Exchange Act Release Nos. 55154
(January 23, 2007), 72 FR 4743 (February 1, 2007)
(SR–CBOE–2006–92); 55161 (January 24, 2007), 72
FR 4754 (February 1, 2007) (SR–ISE–2006–62);
54886 (December 6, 2006), 71 FR 74979 (December
13, 2006) (SR–Phlx–2006–74); 54590 (October 12,
2006), 71 FR 61525 (October 18, 2006) (SR–
NYSEArca–2006–73); and 54741 (November 9,
2006), 71 FR 67176 (November 20, 2006) (SR–
Amex–2006–106).
6 See Securities Exchange Act Release No. 84864
(December 19, 2018), 83 FR 66778 (December 27,
2018) (SR–MIAX–2018–38) (extending the Penny
Pilot Program from December 31, 2018 to June 30,
2019).
7 The month immediately preceding a
replacement class’s addition to the Pilot Program
(i.e., December) is not used for purposes of the six-
E:\FR\FM\07MRN1.SGM
Continued
07MRN1
Agencies
[Federal Register Volume 84, Number 45 (Thursday, March 7, 2019)]
[Notices]
[Pages 8348-8353]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-04085]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-85236; File No. SR-ICEEU-2018-010]
Self-Regulatory Organizations; ICE Clear Europe Limited; Order
Approving Proposed Rule Change Relating to Amendments to the ICE Clear
Europe CDS Risk Policy (the ``CDS Risk Policy''), CDS Clearing Back-
Testing Policy (the ``Back-Testing Policy'') and CDS Stress-Testing
Policy (the ``Stress-Testing Policy'') (Collectively, the ``CDS
Policies'')
March 1, 2019.
I. Introduction
On November 13, 2018, ICE Clear Europe Limited (``ICE Clear
Europe'') filed with the Securities and Exchange Commission
(``Commission''), pursuant to Section 19(b)(1) of the Securities
Exchange Act of 1934 (``Act'') \1\ and Rule 19b-4 thereunder,\2\ a
proposed rule change to modify and update certain provisions of its
risk policies related to CDS Contracts. The proposed rule change was
published for comment in the Federal Register on December 4, 2018.\3\
On December 26, 2018, the Commission extended the period to take action
on the proposed rule change to March 4, 2019.\4\ The Commission did not
receive comments on the proposed rule change. For the reasons discussed
below, the Commission is approving the proposed rule change.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ Securities Exchange Act Release No. 84667 (Nov. 28, 2018),
83 FR 62638 (Dec. 4, 2018) (SR-ICEEU-2018-010) (``Notice'').
\4\ Securities Exchange Act Release No. 84957 (Dec. 26, 2018),
84 FR 855 (Jan. 31, 2019) (SR-ICEEU-2018-010).
---------------------------------------------------------------------------
II. Description of the Proposed Rule Change
A. CDS Risk Policy
The proposed rule change would incorporate into the CDS Risk Policy
a description of ICE Clear Europe's overall Board risk appetite and
limit framework.\5\ Currently the CDS Risk Policy does not reference
the framework, but other ICE Clear Europe policies, including the
Stress-Testing Policy, reference the framework. The description of the
framework that the proposed rule change would add to the CDS Risk
Policy would be consistent with the description of the framework that
other ICE Clear Europe policies, including the Stress-Testing Policy,
use. As described in the proposed change to the CDS Risk Policy, the
framework would use Board-level risk appetite statements, risk appetite
metrics, and management risk limits, and would be subject to review at
least annually.\6\ The proposed rule change would add description of
the framework to the CDS Risk Policy to make clear that the CDS Risk
Policy is part of ICE Clear Europe's overall risk management.
---------------------------------------------------------------------------
\5\ Capitalized terms not otherwise defined herein shall have
the meanings given to them in the CDS Policies or ICE Clear Europe
Rulebook.
\6\ Notice, 83 FR at 62638.
---------------------------------------------------------------------------
The proposed rule change would specifically address periodic
reviews of margin requirements and the related margin methodology and
parameters. Currently, the CDS Risk Policy provides that ICE Clear
Europe conducts a statistical analysis of the margin levels and market
performance on at least a monthly basis. Similarly, under the proposed
revised policy, the clearing risk department would be required to
perform such a review at least monthly, consistent with applicable
legal requirements.\7\
---------------------------------------------------------------------------
\7\ See 17 CFR 240.17Ad-22(e)(6)(vi).
---------------------------------------------------------------------------
The proposed rule change would provide additional detail about the
use of the results of such reviews by ICE Clear Europe management.
Specifically, under the proposed rule change, the head of first line
clearing risk would present the results of the monthly review to ICE
Clear Europe's Model Oversight Committee (``MOC'').\8\ The head of
first line clearing risk would report to the President of ICE Clear
Europe and would manage ICE Clear Europe's first line clearing risk
team including default management, liquidity risk, market risk and
counterparty risk. Moreover, the proposed rule change would provide
that at the end of each quarter, the Clearing Risk Department would
share its monthly reviews from the quarter with the Risk Oversight
Department (``ROD''), which would perform a second-line review. The
head of second line clearing risk then would present the results of
this quarterly review to the MOC. The head of second line clearing risk
would be ICE Clear Europe's Chief Risk Officer and would report to the
President and the senior independent director of ICE Clear Europe.\9\
The CDS Risk Policy currently provides only that the Risk Management
Department recommends margin methodology changes to the President and
Board of Directors of ICE Clear Europe for their approval. Thus, the
proposed rule change would provide more explanation regarding ICE Clear
Europe's use of the monthly reviews of margin levels.
---------------------------------------------------------------------------
\8\ Notice, 83 FR at 62638.
\9\ Id.
---------------------------------------------------------------------------
The proposed amendments would also clarify that the Clearing Risk
Department would recommend proposed margin methodology changes
resulting from the review process to the Board for approval. Currently,
the CDS Risk Policy provides that the ICE Clear Europe Risk Management
Department recommends margin methodology changes to the President and
the Board for their approval. Thus, this proposed change would update
the name of the responsible ICE Clear Europe department from Risk
Management Department to Clearing Risk Department. Moreover, this
proposed change would eliminate a redundancy in providing that ICE
Clear Europe's Board alone shall approve margin methodology changes.
Because ICE Clear Europe's President also serves on the Board, it would
not be necessary for both the President and the Board to separately
approve margin methodology changes.\10\
---------------------------------------------------------------------------
\10\ See https://www.theice.com/publicdocs/clear_europe/Organisational_Structure_Objectives_Strategy.pdf.
---------------------------------------------------------------------------
The proposed rule change would specify in further detail the timing
and extent of backtesting and stress testing.\11\ Currently, the CDS
Risk Policy provides that ICE Clear Europe conducts backtesting on a
daily basis, but the Policy does not specify that ICE Clear Europe uses
standard predetermined
[[Page 8349]]
parameters and assumptions, nor does it provide any information about
sensitivity analysis. Consistent with applicable law, the proposed rule
change would require that: (i) ICE Clear Europe's Clearing Risk
Department conduct backtesting at least once each day using standard
predetermined parameters and assumptions; (ii) ICE Clear Europe conduct
sensitivity analyses of its margin models and review parameters and
assumptions for backtesting on at least a monthly basis; and (iii) ICE
Clear Europe conduct sensitivity analyses and reviews more frequently
than monthly when the relevant products cleared or markets served
display high volatility or become less liquid or when the size or
concentration of positions held by Clearing Members increases or
decreases significantly.\12\ With respect to stress testing, the CDS
Risk Policy currently provides details regarding stress testing
scenarios and provides that ICE Clear Europe executes such scenarios on
a regular basis, but does not specify that ICE Clear Europe conducts
stress testing daily or uses standard predetermined parameters and
assumptions. Consistent with applicable law, the proposed rule change
would require that the clearing risk department conduct stress testing
at least once each day using standard predetermined parameters and
assumptions, which are reviewed on at least a monthly basis and more
frequently when the relevant products cleared or markets served display
high volatility or become less liquid or when the size or concentration
of positions held by Clearing Members increases or decreases
significantly.\13\
---------------------------------------------------------------------------
\11\ Notice, 83 FR at 62638.
\12\ See 17 CFR 240.17Ad-22(e)(6)(vi).
\13\ See 17 CFR 240.17Ad-22(e)(4)(vi).
---------------------------------------------------------------------------
The proposed rule change would also establish details regarding
policy governance and reporting. The proposed rule change would specify
that the models used to support the policy objectives of the policy are
subject to an annual independent validation and governance oversight
which may be performed by an independent member of the ROD or an
external validator.\14\ The CDS Risk Policy does not currently provide
any details regarding validation of the models used to support the
policy. The CDS Risk Policy owner, who is the CDS Risk Director and
part of the Clearing Risk Department, would be responsible for ensuring
that the policy remains up-to-date and is reviewed, with the support of
the ROD.\15\
---------------------------------------------------------------------------
\14\ Notice, 83 FR at 62638.
\15\ Notice, 83 FR at 62638.
---------------------------------------------------------------------------
The proposed rule change would also provide a new process for
escalation and reporting of any deviations from the policy, as well as
compliance with regulatory reporting and filing requirements and would
make the policy owner responsible for both. Under the current policy,
any changes to the Policy that affect the risk profile of ICE Clear
Europe are subject to Board approval, and any exceptions or deviations
from the Policy must be reported to the Chief Risk Officer and
escalated to the CDS Risk Committee and Board Risk Committee, if
material. Under the proposed rule change, the policy owner must report
any deviations from the Policy or material breaches to the President of
ICE Clear Europe and the Risk Oversight Department, who will then
proceed with appropriate governance and further escalation. Thus, this
change ensures that deviations and material breaches are reported to
the President and Risk Oversight Department who can then proceed with
Board involvement if needed. This change also ensures the involvement
of the Risk Oversight Department, who supports other functions under
the Policy, such as the reviews discussed above. Finally, this change
would make the process for escalation and reporting consistent with the
process currently found in the Stress-Testing Policy.
The proposed rule change would further specify the roles of various
departments and committees at ICEEU with respect to the CDS Risk
Policy.\16\ Currently, the CDS Risk Policy describes the roles of the
Risk Working Group (``RWG'') (which consists of risk personnel of
Clearing Members, and provides guidance on risk management matters,
including review of margin and stress testing parameters), Trading
Advisory Committee (which advises on pricing processes), and MOC (which
is responsible for overall model risk management of the Clearing House,
and for oversight of the periodic reviews described above) in advising
on and approving matters related to the Policy. The proposed rule
change would further specify the role of the RWG and MOC in providing
feedback and reviewing the results of ongoing monitoring of models that
support the CDS Risk Policy. The proposed rule change would also
provide further detail as to the composition and role of the RWG and
MOC. Finally, the proposed rule change would make the Clearing Risk
Department, with the support of the ROD, responsible for adherence to
the policy and relevant appetite metrics.
---------------------------------------------------------------------------
\16\ Id.
---------------------------------------------------------------------------
The proposed rule change would also update references to various
committees and departments of ICE Clear Europe, correct typographical
and similar errors, update cross-references, and remove an unnecessary
reference to ICE Clear Credit.
B. Back-Testing Policy
The proposed rule change would make changes to the Back-Testing
Policy similar to those changes described above for the CDS Risk
Policy. Specifically, the proposed rule change would incorporate into
the Back-Testing Policy a description of ICE Clear Europe's overall
Board risk appetite and limit framework.\17\ Currently the Back-Testing
Policy does not reference the framework, but other ICE Clear Europe
policies, including the Stress-Testing Policy, reference the framework.
The description of the framework that the proposed rule change would
add to the Back-Testing Policy would be consistent with the description
of the framework that other ICE Clear Europe policies, including the
Stress-Testing Policy, use. As described in the proposed change to the
Back-Testing Policy, the framework would use Board-level risk appetite
statements, risk appetite metrics, and management risk limits, and
would be subject to review at least annually.\18\ The proposed rule
change would add description of the framework to the Back-Testing
Policy to make clear that the Back-Testing Policy is part of ICE Clear
Europe's overall risk management.
---------------------------------------------------------------------------
\17\ Notice, 83 FR at 62638.
\18\ Notice, 83 FR at 62638.
---------------------------------------------------------------------------
The proposed rule change would also add the same provisions
relating to the timing of backtesting and related sensitivity analysis
discussed above in the context of the CDS Risk Policy.\19\ Currently,
the Back-Testing Policy provides that ICE Clear Europe conducts
backtesting on a daily basis, but the Policy does not specify that ICE
Clear Europe uses standard predetermined parameters and assumptions,
nor does it provide any information about sensitivity analysis.
---------------------------------------------------------------------------
\19\ Id.
---------------------------------------------------------------------------
In addition, the proposed rule change would clarify the meaning of,
and make other changes to, certain confidence levels used in the
backtesting process.\20\ Specifically, the proposed rule change would
specify that these confidence levels represent the confidence to which
models are expected to perform. Although the Back-Testing Policy
currently describes the confidence levels that ICE Clear Europe uses in
backtesting, it does not make clear what these confidence levels
represent. Thus, the proposed change would clarify the
[[Page 8350]]
meaning of the confidence levels and therefore how those confidence
levels are used in evaluating ICE Clear Europe's backtesting. The
proposed rule change would also remove a reference to the 99% quantile
used before EMIR implementation. ICE Clear Europe no longer uses this
confidence level in backtesting. Rather, in the guidelines relating to
remediation of poor backtesting, the proposed rule change would state
explicitly that portfolio backtesting is done using a confidence level
of 99.5% or higher.
---------------------------------------------------------------------------
\20\ Notice, 83 FR at 62639.
---------------------------------------------------------------------------
As with the amendments to the CDS Risk Policy, the proposed rule
change would also establish details regarding policy governance and
reporting.\21\ Specifically, the proposed rule change would specify
that the models used to support the objectives of the Back-Testing
Policy are subject to an annual independent validation and governance
oversight which may be performed by an independent member of the ROD or
an external validator. The Back-Testing Policy does not currently
provide details regarding independent validation of the models used to
support the Policy. The proposed rule change would make the Back-
Testing Policy owner, who is the CDS Risk Director and part of the
Clearing Risk Department, responsible for ensuring that the Back-
Testing Policy remains up-to-date and is reviewed, with the support of
the ROD.\22\ The proposed rule change would make the Clearing Risk
Department, with the support of the ROD, responsible for adherence to
the policy and relevant appetite metrics.\23\
---------------------------------------------------------------------------
\21\ Notice, 83 FR at 62639.
\22\ Id.
\23\ Id.
---------------------------------------------------------------------------
The proposed rule change would also provide a new process for
escalation and reporting of any deviations from the policy, as well as
compliance with regulatory reporting and filing requirements and would
make the policy owner responsible for both. Currently, the Back-Testing
Policy provides that the Policy will be reviewed and approved in
accordance with the Policy Governance Review Calendar, or whenever the
Clearing House identifies further issues requiring specific attention
under the Policy. The proposed rule change would provide that any
deviations from the Policy must be appropriately escalated and reported
in a timely manner by the policy owner and would also make the policy
owner responsible for reporting any material breaches or deviations to
the President and Risk Oversight Department. Thus, this proposed rule
change would provide additional detail to the escalation of changes to
the Policy as well as make the process for escalation and reporting
consistent with the process proposed to be added to the CDS Risk
Policy. Finally, this change would make the process for escalation and
reporting consistent with the process proposed for the CDS Risk Policy
and the process currently found in the Stress-Testing Policy.
The proposed rule change would also update references to various
committees and departments of ICE Clear Europe, correct typographical
and similar errors, and update cross-references.
C. Stress-Testing Policy
The proposed rule change would make changes to the Stress-Testing
Policy similar to those described above for the CDS Risk Policy.
Specifically, the proposed rule change would amend the Stress-Testing
Policy to include the same provisions relating to the timing of stress
testing discussed above in the context of the CDS Risk Policy.\24\
Currently, the Stress-Testing Policy provides details regarding stress
testing scenarios and provides that ICE Clear Europe executes such
scenarios on a regular basis, but does not specify that ICE Clear
Europe conducts stress testing daily or uses standard predetermined
parameters and assumptions.
---------------------------------------------------------------------------
\24\ Notice, 83 FR at 62639.
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The proposed rule change would also amend the Stress-Testing Policy
to reflect the role of the Board Risk Committee, in addition to the CDS
Risk Committee, in reviewing and overseeing stress testing.
Specifically, the proposed rule change would amend the Stress-Testing
Policy to ensure that both the CDS Risk Committee and the Board Risk
Committee are sufficiently informed to advise the Board on the safety
and soundness of the risk management approach and to provide a
mechanism for management and the committees to test the level of
protection offered in the potential stress scenarios.\25\ Under the
current policy, the Board Risk Committee, in addition to the CDS Risk
Committee, reviews and advises on stress testing results. The current
policy does not specifically require that the Board Risk Committee be
sufficiently informed to advise the Board on the safety and soundness
of the risk management approach or provide a mechanism for the Board
Risk Committee to test the level of protection offered in the potential
stress scenario, however. Thus, the proposed rule change would correct
this situation and ensure that the Board Risk Committee is sufficiently
informed to fulfill its roll under the Policy.
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\25\ Notice, 83 FR at 62639.
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III. Commission Findings
Section 19(b)(2)(C) of the Act directs the Commission to approve a
proposed rule change of a self-regulatory organization if it finds that
such proposed rule change is consistent with the requirements of the
Act and the rules and regulations thereunder applicable to such
organization.\26\ For the reasons given below, the Commission finds
that the proposed rule change is consistent with Section 17A(b)(3)(F)
of the Act \27\ and Rules 17Ad-22(e)(2)(i) and (v), (e)(4)(vi), and
(e)(6)(vi) thereunder.\28\
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\26\ 15 U.S.C. 78s(b)(2)(C).
\27\ 15 U.S.C. 78q-1(b)(3)(F).
\28\ 17 CFR 240.17Ad-22(e)(2)(i) and (v), (e)(4)(vi), and
(e)(6)(vi).
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A. Consistency With Section 17A(b)(3)(F) of the Act
Section 17A(b)(3)(F) of the Act requires, among other things, that
the rules of ICE Clear Europe be designed to promote the prompt and
accurate clearance and settlement of securities transactions and, to
the extent applicable, derivative agreements, contracts, and
transactions, as well as to assure the safeguarding of securities and
funds which are in the custody or control of ICE Clear Europe or for
which it is responsible, and, in general, to protect investors and the
public interest.\29\
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\29\ 15 U.S.C. 78q-1(b)(3)(F).
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As discussed above, the proposed rule change would amend the CDS
Policies to provide more detail with respect to the use of the results
of periodic reviews of margin requirements and the related methodology
by ICE Clear Europe management, including second-line reviews and
reporting to ICE Clear Europe's Chief Risk Officer, President, and
senior independent director. The proposed rule change would also
specify that ICE Clear Europe's daily backtesting uses standard
predetermined parameters and assumptions and that ICE Clear Europe
conducts sensitivity analyses of its margin models and reviews
parameters and assumptions for backtesting on at least a monthly basis,
and more frequently than monthly in certain cases, as discussed above.
Similarly, the proposed rule change would specify that ICE Clear Europe
conducts stress testing once each day and that in doing so, ICE Clear
Europe uses standard predetermined parameters and assumptions, which
are reviewed on at least a monthly basis and more
[[Page 8351]]
frequently, as discussed above. Finally, with respect to the Back-
Testing Policy, the proposed rule change would clarify the meaning of
confidence levels used in the backtesting process and eliminate a
confidence level no longer used in backtesting.
The Commission believes that these changes, taken as a whole, would
help to improve ICE Clear Europe's stress testing and backtesting. In
providing more detail with respect to the use of the results of
periodic reviews of margin requirements and the related methodology by
ICE Clear Europe management, including second-line reviews and
reporting to ICE Clear Europe's Chief Risk Officer, President, and
senior independent director, the Commission believes that the proposed
rule change would help to improve ICE Clear Europe's evaluation and
revision of its margin requirements, related methodology, and
parameters. The Commission believes that this, in turn, would help to
ensure that ICE Clear Europe maintains effective margin requirements,
related methodology, and parameters.
Similarly, in specifying that stress testing is conducted daily,
the Commission believes that the proposed rule change would help
improve the effectiveness of stress testing by ensuring that it is
conducted on a regular basis. Moreover, in specifying that in
conducting backtesting and stress testing ICE Clear Europe uses
standard predetermined parameters and assumptions, the Commission
believes that the proposed rule change would help ensure the accuracy
and reliability of backtesting and stress testing. Finally, the
Commission believes that in clarifying the meaning of confidence levels
used in the backtesting process and removing a confidence level no
longer used by ICE Clear Europe, the proposed rule change would help to
ensure the effectiveness of ICE Clear Europe's backtesting process by
helping to ensure that ICE Clear Europe conducts backtesting at the
correct confidence level. Because backtesting and stress testing can
help reveal inadequacies in ICE Clear Europe's margin requirements and
the models that support those requirements, the Commission believes
that the proposed rule change would help to ensure that ICE Clear
Europe maintains effective margin requirements.
Given that an effective margin system is necessary to manage ICE
Clear Europe's credit exposures to its Clearing Members and the risks
associated with clearing security based swap-related portfolios, the
Commission believes that the proposed rule change would help improve
ICE Clear Europe's ability to avoid losses that could result from the
mismanagement of such credit exposures and risks. Because such losses
could disrupt ICE Clear Europe's ability to promptly and accurately
clear security based swap transactions, by making the above-described
improvements to the review and reporting of ICE Clear Europe's margin
requirements and timing and scope of backtesting and stress testing,
the Commission believes that the proposed rule change would help
promote the prompt and accurate clearance and settlement of securities
transactions.
Similarly, appropriate management of ICE Clear Europe's credit
exposures to its Clearing Members and the risks associated with
clearing security based swap-related portfolios is critical to avoiding
the realization of losses on such portfolios that could threaten ICE
Clear Europe's ability to operate, thereby threatening access to
securities and funds in ICE Clear Europe's control. Because the
proposed changes would improve ICE Clear Europe's ability to manage
such credit exposures by improving the processes ICE Clear Europe uses
to review and maintain its margin system, including backtesting and
stress testing, the Commission believes that the proposed rule change
would help assure the safeguarding of securities and funds which are in
the custody or control of ICE Clear Europe or for which it is
responsible. Finally, for both of these reasons, the Commission
believes the proposed rule change is consistent with protecting
investors and the public interest.
Therefore, the Commission finds that the proposed rule change would
promote the prompt and accurate clearance and settlement of securities
transactions, assure the safeguarding of securities and funds in ICE
Clear Europe's custody and control, and, in general, protect investors
and the public interest, consistent with the Section 17A(b)(3)(F) of
the Act.\30\
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\30\ 15 U.S.C. 78q-1(b)(3)(F).
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B. Consistency With Rules 17Ad-22(e)(2)(i) and (v)
Rules 17Ad-22(e)(2)(i) and (v) require that ICE Clear Europe
establish, implement, maintain and enforce written policies and
procedures reasonably designed to provide for governance arrangements
that are clear and transparent and specify clear and direct lines of
responsibility.\31\
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\31\ 17 CFR 240.17Ad-22(e)(2)(i) and (v).
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As discussed above, the proposed rule change would revise the CDS
Policies to specify the roles of various departments and committees at
ICE Clear Europe, including the role of RWG and MOC in providing
feedback and reviewing the results of ongoing monitoring of models that
support the CDS Risk Policy and update references to ICE Clear Europe
committees. The Commission believes that this change would improve the
transparency of ICE Clear Europe's governance arrangements by
clarifying the role played by various departments and committees in
following and maintaining the CDS Policies.
With respect to the CDS Risk Policy and Back-Testing Policy
specifically, the Commission believes that the proposed rule change, in
incorporating an overall Board risk appetite and limit framework, would
help to clarify the governance around the risk appetite associated with
the CDS Risk Policy and Back-Testing Policy and make clear that the
policies are part of ICE Clear Europe's overall risk management. The
Commission similarly believes that the proposed rule change would help
improve the transparency of ICE Clear Europe's governance arrangements
in specifying that the models used to support the CDS Risk Policy and
Back-Testing Policy are subject to an annual independent validation and
governance oversight. The Commission further believes that the proposed
rule change would help ICE Clear Europe specify clear and direct
responsibility for the CDS Risk Policy and Back-Testing Policy by
assigning an owner for each policy and making that owner responsible
for ensuring that the policy remains up-to-date and is reviewed.
Similarly, the Commission believes that in making the clearing risk
department, with the support of the ROD, responsible for adherence to
the policies and relevant appetite metrics, the proposed rule change
would specify who is responsible for compliance with the polices.
Finally, the Commission believes that, in amending the CDS Risk Policy
and Back-Testing Policy to provide a new process for escalation and
reporting of any deviations from the policies, as well as compliance
with regulatory reporting and filing requirements (and make the policy
owner responsible for both), the proposed rule change would clarify the
governance arrangements with respect to deviations from the policies.
This proposed change would also make the process for escalation and
reporting consistent across all of the CDS Policies, thus further
contributing to clarity and transparency of ICE Clear Europe's
governance arrangements.
With respect to the Stress-Testing Policy, the Commission also
believes that the proposed rule change, in
[[Page 8352]]
specifically requiring that the Board Risk Committee be sufficiently
informed to advise the Board on the safety and soundness of the risk
management approach, would help to ensure that the Board Risk Committee
is sufficiently informed to carry out its roll under the Policy,
thereby helping to ensure that the Board Risk Committee has a clear and
direct responsibility under the Policy.
Finally, the Commission believes that in correcting typographical
errors and updating cross-references, as discussed above, the proposed
rule change would clarify ICE Clear Europe's governance arrangements by
helping to ensure that the CDS Policies correctly reference the
positions, departments, and/or committees responsible under the CDS
Policies.
Therefore, for the above reasons the Commission finds that the
proposed rule change is consistent with Rules 17Ad-22(e)(2)(i) and
(v).\32\
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\32\ 17 CFR 240.17Ad-22(e)(2)(i) and (v).
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C. Consistency With Rule 17Ad-22(e)(4)(vi)
Rule 17Ad-22(e)(4)(vi) requires that ICE Clear Europe 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 testing the
sufficiency of its total financial resources available to meet the
minimum financial resource requirements under Rule 17Ad-22(e)(4)(i)
through (iii), as applicable, by (i) conducting stress testing of its
total financial resources once each day using standard predetermined
parameters and assumptions; (ii) conducting a comprehensive analysis on
at least a monthly basis of the existing stress testing scenarios,
models, and underlying parameters and assumptions, and considering
modifications to ensure they are appropriate for determining the
required level of default protection in light of current and evolving
market conditions; (iii) conducting a comprehensive analysis of stress
testing scenarios, models, and underlying parameters and assumptions
more frequently than monthly when the products cleared or markets
served display high volatility or become less liquid, or when the size
or concentration of positions held by its participants increases
significantly; and (iv) reporting the results of its analyses to
appropriate decision makers at ICE Clear Europe, including but not
limited to, its risk management committee or board of directors.\33\
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\33\ 17 CFR 240.17Ad-22(e)(4)(vi).
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As discussed above, ICE Clear Europe's policies do not currently
require that stress testing be conducted daily or that it use standard
predetermined parameters and assumptions. The proposed rule change
would amend the CDS Risk Policy and Stress-Testing Policy to require
that ICE Clear Europe's clearing risk department conduct stress testing
at least once each day using standard predetermined parameters and
assumptions, which are reviewed on at least a monthly basis and more
frequently when the relevant products cleared or markets served display
high volatility or become less liquid or when the size or concentration
of positions held by Clearing Members increases or decreases
significantly. Moreover, the proposed rule change would amend the CDS
Risk Policy to provide greater detail with respect to ICE Clear
Europe's periodic reviews, including second-line review and reporting,
of margin requirements, related methodology, and parameters.
The Commission believes that these proposed amendments would help
ensure that ICE Clear Europe complies with the requirements of Rule
17Ad-22(e)(4)(vi) by establishing standards for frequency of testing
and review and use of standard predetermined parameters and assumptions
consistent with those of the rule. Therefore, the Commission finds that
the proposed rule change is consistent with Rule 17Ad-22(e)(4)(vi).\34\
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\34\ 17 CFR 240.17Ad-22(e)(4)(vi).
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D. Consistency With Rule 17Ad-22(e)(6)(vi)
Rule 17Ad-22(e)(6)(vi) requires that ICE Clear Europe 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 is
monitored by management on an ongoing basis and is regularly reviewed,
tested, and verified by (i) conducting backtests of its margin model at
least once each day using standard predetermined parameters and
assumptions; (ii) conducting a sensitivity analysis of its margin model
and a review of its parameters and assumptions for backtesting on at
least a monthly basis, and considering modifications to ensure the
backtesting practices are appropriate for determining the adequacy of
its margin resources; (iii) conducting a sensitivity analysis of its
margin model and a review of its parameters and assumptions for
backtesting more frequently than monthly during periods of time when
the products cleared or markets served display high volatility or
become less liquid, or when the size or concentration of positions held
by participants increases or decreases significantly; and (iv)
reporting the results of its analyses under to appropriate decision
makers, including but not limited to, its risk management committee or
board of directors, and using these results to evaluate the adequacy of
and adjust its margin methodology, model parameters, and any other
relevant aspects of its credit risk management framework.\35\
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\35\ 17 CFR 240.17Ad-22(e)(6)(vi).
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As discussed above, ICE Clear Europe's policies do not currently
require that ICE Clear Europe use standard predetermined parameters and
assumptions in conducting backtesting nor do they provide detail
regarding sensitivity analysis. The proposed rule change would amend
the CDS Risk Policy and Back-Testing Policy to require that (i) ICE
Clear Europe's clearing risk department conduct backtesting at least
once each day using standard predetermined parameters and assumptions
and (ii) ICE Clear Europe conduct sensitivity analyses of its margin
models and review parameters and assumptions for backtesting on at
least a monthly basis, and more frequently than monthly when the
relevant products cleared or markets served display high volatility or
become less liquid or when the size or concentration of positions held
by Clearing Members increases or decreases significantly. Moreover, the
proposed rule change would amend the CDS Risk Policy to provide greater
detail with respect to ICE Clear Europe's periodic reviews, including
second-line review and reporting, of margin requirements, related
methodology, and parameters.
The Commission believes that these proposed amendments would help
ensure that ICE Clear Europe complies with the requirements of Rule
17Ad-22(e)(6)(vi) by establishing standards for frequency of testing
and review, use of standard predetermined parameters and assumptions,
and use of sensitivity analysis consistent with those of the rule.
Therefore, the Commission finds that the proposed rule change is
consistent with Rule 17Ad-22(e)(6)(vi).\36\
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\36\ 17 CFR 240.17Ad-22(e)(6)(vi).
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[[Page 8353]]
IV. Conclusion
On the basis of the foregoing, the Commission finds that the
proposal is consistent with the requirements of the Act, and in
particular, with the requirements of Section 17A(b)(3)(F) of the Act
\37\ and Rules 17Ad-22(e)(2)(i) and (v), (e)(4)(vi), and (e)(6)(vi)
thereunder.\38\
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\37\ 15 U.S.C. 78q-1(b)(3)(F).
\38\ 17 CFR 240.17Ad-22(e)(2)(i) and (v), (e)(4)(vi), and
(e)(6)(vi).
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It is therefore ordered pursuant to Section 19(b)(2) of the Act
\39\ that the proposed rule change (SR-ICEEU-2018-010) be, and hereby
is, approved.\40\
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\39\ 15 U.S.C. 78s(b)(2).
\40\ In approving the proposed rule change, the Commission
considered the proposal's impact on efficiency, competition, and
capital formation. 15 U.S.C. 78c(f).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\41\
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\41\ 17 CFR 200.30-3(a)(12).
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Eduardo A. Aleman,
Deputy Secretary.
[FR Doc. 2019-04085 Filed 3-6-19; 8:45 am]
BILLING CODE 8011-01-P