Self-Regulatory Organizations; the Options Clearing Corporation; Order Approving Proposed Rule Change Related to the Introduction of a New Liquidation Cost Model in the Options Clearing Corporation's Margin Methodology, 29267-29270 [2019-13113]
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Federal Register / Vol. 84, No. 120 / Friday, June 21, 2019 / Notices
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
No written comments were solicited
or received with respect to the proposed
rule change.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
The foregoing rule change is effective
upon filing pursuant to Section
19(b)(3)(A) 24 of the Act and
subparagraph (f)(2) of Rule 19b–4 25
thereunder, because it establishes a due,
fee, or other charge imposed by the
Exchange.
At any time within 60 days of the
filing of such proposed rule change, the
Commission summarily may
temporarily suspend such rule change if
it appears to the Commission that such
action is necessary or appropriate in the
public interest, for the protection of
investors, or otherwise in furtherance of
the purposes of the Act. If the
Commission takes such action, the
Commission shall institute proceedings
under Section 19(b)(2)(B) 26 of the Act to
determine whether the proposed rule
change should be approved or
disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
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Electronic Comments
• Use the Commission’s internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
NYSENAT–2019–14 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE,
Washington, DC 20549–1090.
All submissions should refer to File
Number SR–NYSENAT–2019–14. This
file number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
internet website (https://www.sec.gov/
24 15
U.S.C. 78s(b)(3)(A).
CFR 240.19b–4(f)(2).
26 15 U.S.C. 78s(b)(2)(B).
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for website viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE,
Washington, DC 20549 on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing also will be available for
inspection and copying at the principal
offices of the Exchange. All comments
received will be posted without change.
Persons submitting comments are
cautioned that we do not redact or edit
personal identifying information from
comment submissions. You should
submit only information that you wish
to make available publicly. All
submissions should refer to File
Number SR–NYSENAT–2019–14, and
should be submitted on or before July
12, 2019.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.27
Vanessa A. Countryman,
Acting Secretary.
[FR Doc. 2019–13115 Filed 6–20–19; 8:45 am]
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SECURITIES AND EXCHANGE
COMMISSION
Self-Regulatory Organizations; the
Options Clearing Corporation; Order
Approving Proposed Rule Change
Related to the Introduction of a New
Liquidation Cost Model in the Options
Clearing Corporation’s Margin
Methodology
June 17, 2019.
I. Introduction
On April 18, 2019, the Options
Clearing Corporation (‘‘OCC’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change SR–OCC–2019–
004 (‘‘Proposed Rule Change’’) pursuant
to Section 19(b) of the Securities
Exchange Act of 1934 (‘‘Exchange
25 17
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Act’’) 1 and Rule 19b–4 2 thereunder to
propose changes to OCC’s margin
methodology to introduce a new model
to estimate the liquidation cost for all
options and futures, as well as the
securities in margin collateral.3
The Proposed Rule Change was
published for public comment in the
Federal Register on May 6, 2019,4 and
the Commission received no comments
regarding the Proposed Rule Change.
This order approves the Proposed Rule
Change.
II. Background
The System for Theoretical Analysis
and Numerical Simulations (‘‘STANS’’)
is OCC’s methodology for calculating
margin requirements. OCC uses the
STANS methodology to measure the
exposure of portfolios of options and
futures cleared by OCC and of cash
instruments that are part of margin
collateral. STANS margin requirements
are intended to cover potential losses
due to price movements over a two-day
risk horizon; however, the current
STANS margin requirements do not
cover the potential additional
liquidation costs OCC may incur in
closing out a defaulted Clearing
Member’s portfolio.5 Closing out
positions in a defaulted Clearing
Member’s portfolio could entail selling
longs at the bid price and covering
shorts at the ask price. Additionally,
even well-hedged portfolios consisting
of offsetting longs and shorts would
require some cost to liquidate in the
event of a default. The process of
modeling liquidation costs is, therefore,
relevant to ensuring that OCC holds
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Notice of Filing infra note 4, at 84 FR 19815.
4 Securities Exchange Act Release No. 85755
(Apr. 30, 2019), 84 FR 19815 (May 6, 2019) (SR–
OCC–2019–004) (‘‘Notice of Filing’’). OCC also filed
a related advance notice (SR–OCC–2019–802)
(‘‘Advance Notice’’) with the Commission 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 and Rule 19b–4(n)(1)(i)
under the Exchange Act. 12 U.S.C. 5465(e)(1). 15
U.S.C. 78s(b)(1) and 17 CFR 240.19b–4,
respectively. The Advance Notice was published in
the Federal Register on May 21, 2019. Securities
Exchange Act Release No. 85863 (May 15, 2019), 84
FR 23090 (May 21, 2019) (SR–OCC–2019–802).
5 OCC previously introduced a liquidation cost
model into STANS for risk managing only longdated options on the Standard & Poor’s (‘‘S&P’’) 500
index (‘‘SPX’’) that have a tenor of three-years or
more. See Securities Exchange Act Release No.
70719 (October 18, 2013), 78 FR 63548 (October 24,
2013) (SR–OCC–2013–16). Under the proposal
described in the Proposed Rule Change, OCC would
replace the existing liquidation model for longdated SPX options with the proposed model. Longdated SPX options, however, constituted less than
0.5 percent of open interest in SPX options open
interest at the time of filing. See Notice of Filing,
84 FR at 19816, note 7.
2 17
[Release No. 34–86119; File No. SR–OCC–
2019–004]
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sufficient financial resources to closeout the portfolio of a defaulted Clearing
Member.
OCC is proposing to introduce a new
model to its margin methodology to
estimate the liquidation cost for all
options and futures, as well as cash
instruments that are part of margin
collateral. According to OCC, the
purpose of this proposal is to collect
additional financial resources to guard
against potential shortfalls in margin
requirements that may arise due to the
costs of liquidating the portfolio of a
defaulted Clearing Member.6 The
liquidation cost charge would be an
add-on to all accounts incurring a
STANS margin charge. At a high level,
the proposed model would estimate the
cost to liquidate a portfolio based on the
mid-points of the bid-ask spreads for the
financial instruments within the
portfolio, and would scale up such
liquidation costs for large or
concentrated positions that would likely
be more expensive to close out.
OCC’s proposed liquidation cost
model would calculate liquidation costs
based on risk measures, gross contract
volumes, and market bid-ask spreads.
As described in the Proposed Rule
Change, the liquidation cost model
would include the following
components: (1) Calculation of
liquidation costs for each sub-portfolio
(as described below), which would then
be aggregated at the portfolio level; (2)
calculation of concentration charges that
would be applied to scale-up the
liquidation costs as appropriate; and (3)
establishment of the liquidation cost as
a floor on a Clearing Member’s margin
requirement.7
A. Liquidation Costs
The proposed model would calculate
two risk-based liquidation costs for a
portfolio: (1) The Vega 8 liquidation cost
(‘‘Vega LC’’), and (2) the Delta 9
liquidation cost (‘‘Delta LC’’). Options
products would incur both a Vega LC
and a Delta LC, while Delta-one
products,10 such as futures contracts,
Treasury securities, and equity
securities, would incur only a Delta LC.
6 See
Notice of Filing, 84 FR at 19816.
also proposes a conforming change to its
Margin Policy, which would reference OCC’s model
documentation.
8 The Vega of an option represents the sensitivity
of the option price to the volatility of the
underlying security.
9 The Delta of an option represents the sensitivity
of the option price to the price of the underlying
security.
10 A ‘‘Delta-one product’’ refers to a product for
which a change in the value of the underlying asset
results in a change of the same, or nearly the same,
proportion in the value of the product.
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7 OCC
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The process of calculating the Vega
LC and the Delta LC for each portfolio
would require a series of steps,
beginning with the decomposition of
each portfolio into a set of sub-portfolios
based on the asset underlying each
instrument in the portfolio. Each subportfolio would represent a class of
instruments. As proposed, the model
would include 14 potential classes of
underlying assets based on the liquidity
of the assets within each class.11
a. Vega Liquidation Cost
To calculate the Vega LC of a subportfolio, OCC would group contracts
within a sub-portfolio into ‘‘buckets’’
based on each contract’s combination of
tenor and Delta.12 OCC would then net
the long and the short positions down
to a single net Vega within each bucket.
Next, OCC would estimate the average
volatility spread (i.e., the estimated bidask spread on implied volatility) of the
contracts in each bucket.13 The Vega LC
of each bucket would be the net Vega
multiplied by the average volatility
spread of the bucket. The Vega LC of a
sub-portfolio would be the aggregated
Vega LCs of the buckets within that subportfolio. Similarly, the Vega LC of the
full portfolio would be the aggregated
Vega LCs of the sub-portfolios within
that portfolio.14
Under the proposed model, the Vega
LC calculation process could result in a
portfolio-level Vega LC of zero because
the process permits offsets between
contracts. To prevent such a result, OCC
11 For example, equity securities would be
divided based on membership in commonly used
market indices (e.g., the S&P 100) or other market
liquidity measures, into liquidity classes (which
could include, but would not be limited to, High
Liquid Equities, Medium Liquid Equities, and Low
Liquid Equities).
12 For example, those options contracts with a
tenor of 1 month and a Delta between 0.25 and 0.75
could be grouped in one bucket within a subportfolio, while option contracts with a tenor of 3
month and a Delta between 0.25 and 0.75 would be
grouped in another bucket. The proposed model
would provide for 25 buckets (based on
combinations of tenor and Delta) for each subportfolio.
13 Rather than recalibrate the volatility spread of
each bucket as current market conditions change,
the estimated volatility spread of each bucket
within a sub-portfolio would be calibrated based on
data from historical periods of market stress.
14 The process for aggregating Vega LCs, of both
sub-portfolios and portfolios, under the proposed
model, is based on the correlations of either the
bucket or the sub-portfolio being aggregated. To
simplify the portfolio-level aggregation, the
proposed model would use a single correlation
value across all sub-portfolios in a given portfolio
rather than a correlation matrix. To account for
potential errors that could arise out of such a
simplification, the proposed model would require
the calculation of three portfolio-level Vega LCs
based on the three different correlation values (i.e.,
minimum, maximum, and average). The portfolio
Vega LC would be the highest of the three Vega LCs
calculated in this manner.
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proposes including a minimum Vega LC
based on the number of contracts in
each sub-portfolio. The minimum Vega
LC of a sub-portfolio would be the total
number of option contracts in the subportfolio multiplied by a fixed dollar
amount.15
b. Delta Liquidation Cost
Similar to the Vega LC process, the
model would calculate Delta LC for each
sub-portfolio, which would then be
aggregated at the portfolio level. OCC
would first identify and net down the
Delta of the positions within each subportfolio. For each sub-portfolio, OCC
would estimate a bid-ask price spread
(as a percentage). Such a percentage
would represent the cost of liquidating
one dollar unit of the underlying
security during a period of market
stress. The sub-portfolio Delta LC would
be the net dollar Delta of the subportfolio multiplied by the bid-ask price
spread percentage.16 The portfolio-level
Delta LC would be the simple sum of
the sub-portfolio Delta LCs.
B. Concentration Charges
The proposed model would also
address the potential risks involved in
closing out large or concentrated
positions in a portfolio. The size of an
open position is typically measured
against the relevant instrument’s
average daily trading volume (‘‘ADV’’).
Closing out a position in excess of the
ADV would be expected to increase the
cost of liquidation. To account for such
considerations, the proposed model
incorporates a Vega concentration factor
and a Delta concentration factor. The
concentration factors would be used to
scale the Vega LCs and the Delta LCs of
each sub-portfolio and to take into
account the additional risk posed by
large or concentrated positions. The
concentration factor could increase, but
would not decrease the Vega LCs and
the Delta LCs.
C. Margin Floor
As noted above, the liquidation cost
charge (i.e., sum of the portfolio-level
Vega LC and Delta LC) would be applied
as an add-on to the STANS margin
requirement for each account. Because
STANS margin requirements are
15 Specifically, the minimum cost rate would
initially be set as two dollars per contract, unless
the position is long and the net asset value per
contract is less than $2.00. (For a typical option
with a contract size of 100, this would occur if the
option was priced below $0.02.)
16 As described in the Notice of Filing, the
process for determining the Delta LC of a subportfolio of U.S. dollar Treasury bonds would be
different. Specifically, it would be based on the sum
of Delta LCs across six tenor buckets. See Notice of
Filing, 84 FR at 19818.
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intended to cover potential losses due to
price movements over a two-day risk
horizon, the STANS requirement for
well-hedged portfolios may be positive,
which could result in a margin credit
instead of a charge.
To account for the risk of potentially
liquidating a portfolio at current
(instead of two-day ahead) prices, OCC
proposes to design the model such that
it would not permit a margin credit to
offset a portfolio’s liquidation cost.
Under the proposal, therefore, the final
margin requirement for a portfolio could
not be lower than its liquidation cost
charge.
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III. Discussion and Commission
Findings
Section 19(b)(2)(C) of the Exchange
Act directs the Commission to approve
a proposed rule change of a selfregulatory organization if it finds that
such proposed rule change is consistent
with the requirements of the Exchange
Act and the rules and regulations
thereunder applicable to such
organization.17 After carefully
considering the Proposed Rule Change,
the Commission finds the proposal is
consistent with the requirements of the
Exchange Act and the rules and
regulations thereunder applicable to
OCC. More specifically, the Commission
finds that the proposal is consistent
with Section 17A(b)(3)(F) of the
Exchange Act 18 and Rule 17Ad–
22(e)(6)(i) thereunder.19
A. Consistency With Section
17A(b)(3)(F) of the Exchange Act
Section 17A(b)(3)(F) of the Exchange
Act requires that the rules of a clearing
agency be designed to, among other
things, assure the safeguarding of
securities and funds which are in the
custody or control of the clearing agency
or for which it is responsible.20 Based
on its review of the record, the
Commission believes that the proposed
changes are designed to assure the
safeguarding of securities and funds
which are in OCC’s custody or control
for the reasons set forth below.
OCC manages its credit exposure to
Clearing Members, in part, through the
collection of collateral based on OCC’s
margin methodology. As noted above,
OCC’s current margin methodology is
not designed to account for liquidation
costs that OCC could incur in the
process of closing out a defaulted
Clearing Member’s portfolio. OCC
proposes to adopt a model designed to
17 15
U.S.C. 78s(b)(2)(C).
18 15 U.S.C. 78q–1(b)(3)(F).
19 17 CFR 240.17Ad–22(e)(6)(i).
20 15 U.S.C. 78q–1(b)(3)(F).
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estimate the margin necessary to cover
liquidation costs that OCC could incur
when closing out a defaulted Clearing
Member’s portfolio. The Commission
believes that adopting a model designed
to identify and measure a risk not
addressed elsewhere in OCC’s margin
methodology—namely, the cost to
liquidate a defaulted Clearing Member’s
portfolio during periods of market
stress—would improve OCC’s margin
methodology by generating margin
requirements designed to more fully
cover OCC’s credit exposure to each of
its Clearing Members.
Moreover, the Commission believes
that the inclusion of concentration
charges in the proposed liquidation cost
model would enhance the measurement
of risk described above. The cost of
liquidating a defaulted Clearing
Member’s portfolio is, in part, a function
of market prices and market depth
present at the time of the Clearing
Member’s default. The process of
liquidating on a compressed timeframe
a large or concentrated position during
such a period could negatively affect
such market prices for OCC. In
recognition of such costs, OCC proposes
to use concentration factors to scale up
both the Vega LCs and Delta LCs based
on the size of a defaulted Clearing
Member’s positions relative to the
average daily volume of the financial
instruments in the defaulted Clearing
Member’s portfolio. Including
concentration charges in OCC’s
proposed liquidation cost model would
further facilitate the generation of
requirements designed to more fully
cover OCC’s credit exposure to each of
its Clearing Members.
The Commission also believes that the
use of the proposed liquidation cost
model to create a margin floor would
improve the management of OCC’s
credit exposures through the collection
of margin. OCC’s margin methodology
may produce a credit for well-hedged
portfolios because it is focused on the
potential losses resulting from price
movements over a two-day risk horizon.
OCC could, however, incur costs in the
process of closing out a defaulted
Clearing Member’s portfolio at current
prices, rather than prices two days into
the future. OCC’s proposal
acknowledges this potential gap by
requiring that a Clearing Member post,
at a minimum, margin to cover the
liquidation cost of its portfolio.
As discussed above, OCC proposes to
identify and manage the potential cost
of liquidating a defaulted Clearing
Member’s portfolio. OCC’s estimation of
such potential costs would be calibrated
based on historical periods of market
stress. OCC proposes to collect
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29269
resources designed to cover such costs
in the form of margin. Collecting
additional margin to support OCC’s
ability to close out a default Clearing
Member’s portfolio during a period of
market stress could reduce the
potentiality that OCC would mutualize
a loss arising out of the close-out
process. While unavoidable under
certain circumstances, reducing the
potentiality of loss mutualization during
periods of market stress could reduce
the potential knock-on effects to nondefaulting Clearing Members, their
customers and the broader options
market arising out of a Clearing Member
default. The Commission believes,
therefore, that adoption of a liquidation
cost model calibrated based on periods
of market stress would be consistent
with assuring the safeguarding of
securities and funds which are in OCC’s
custody or control or for which it is
responsible consistent with the
requirements of Section 17A(b)(3)(F) of
the Exchange Act.21
B. Consistency With Rule 17Ad–
22(e)(6)(i) Under the Exchange Act
Rule 17Ad–22(e)(6)(i) under the
Exchange Act requires, in part, that a
covered clearing agency establish,
implement, maintain, and enforce
written policies and procedures
reasonably designed to cover, if the
covered clearing agency provides
central counterparty services, 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.22
As described above, the liquidation
cost that OCC could incur in the process
of closing out a Clearing Member’s
portfolio is, in part, a function of the
spread between the bid and the ask
prices of financial instruments within
the portfolio. The STANS methodology
attempts to address potential losses
resulting from changes in price over a
two-day period. As described above,
however, STANS is not designed to
account for liquidation costs. OCC’s
proposed model would be designed to
account for particular attributes of the
products in a defaulted Clearing
Member’s portfolio, including the bidask spreads and average daily volume of
such products.23 Further, the proposal
21 15
U.S.C. 78q–1(b)(3)(F).
CFR 240.17Ad–22(e)(6)(i).
23 As noted above, OCC proposes to incorporate
the proposed model into its margin methodology
documentation and to reference the margin add-on
in its Margin Policy.
22 17
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would acknowledge the purpose of the
proposed liquidation cost model as
distinct from the STANS methodology
by using the proposed liquidation cost
model as a floor on a Clearing Member’s
margin requirements.
OCC’s proposal would be tailored to
the particular attributes of products in a
Clearing Member’s portfolio. As
described above, OCC would use the
proposed model to calculate two riskbased liquidation costs for each
portfolio: (1) The Vega LC and (2) the
Delta LC. The Commission believes,
therefore, that the adoption of the
proposed liquidation cost model
designed to produce margin levels
commensurate with the risks of
liquidating a Clearing Member’s
portfolio is consistent with Exchange
Act Rule 17Ad–22(e)(6)(i).24
IV. Conclusion
On the basis of the foregoing, the
Commission finds that the Proposed
Rule Change is consistent with the
requirements of the Exchange Act, and
in particular, the requirements of
Section 17A of the Exchange Act 25 and
the rules and regulations thereunder.
It is therefore ordered, pursuant to
Section 19(b)(2) of the Exchange Act,26
that the Proposed Rule Change (SR–
OCC–2019–004) be, and hereby is,
approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.27
Vanessa A. Countryman,
Acting Secretary.
[FR Doc. 2019–13113 Filed 6–20–19; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[SEC File No. 270–339, OMB Control No.
3235–0382]
Submission for OMB Review;
Comment Request
Upon Written Request Copies Available
From: Securities and Exchange
Commission, Office of FOIA Services,
100 F Street NE, Washington, DC
20549–2736
Extension:
Schedule 14D–9F
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Notice is hereby given that, pursuant
to the Paperwork Reduction Act of 1995
24 17
CFR 240.17Ad–22(e)(6)(i).
25 In approving this Proposed Rule Change, the
Commission has considered the proposed rules’
impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
26 15 U.S.C. 78s(b)(2).
27 17 CFR 200.30–3(a)(12).
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(44 U.S.C. 3501 et seq.), the Securities
and Exchange Commission
(‘‘Commission’’) has submitted to the
Office of Management and Budget this
request for extension of the previously
approved collection of information
discussed below.
Schedule 14D–9F (17 CFR 240.14d–
103) under the Securities Exchange Act
of 1934 (15 U.S.C. 78 et seq.) is used by
any foreign private issuer incorporated
or organized under the laws of Canada
or by any director or officer of such
issuer, where the issuer is the subject of
a cash tender or exchange offer for a
class of securities filed on Schedule
14D–1F. The information required to be
filed with the Commission is intended
to permit verification of compliance
with the securities law requirements
and assures the public availability of
such information. The information
provided is mandatory and all
information is made available to the
public upon request. We estimate that
Schedule 14D–9F takes approximately 2
hours per response to prepare and is
filed by approximately 6 respondents
annually for a total reporting burden of
12 hours (2 hours per response × 6
responses).
An agency may not conduct or
sponsor, and a person is not required to
respond to, a collection of information
unless it displays a currently valid
control number.
The public may view the background
documentation for this information
collection at the following website,
www.reginfo.gov. Comments should be
directed to: (i) Desk Officer for the
Securities and Exchange Commission,
Office of Information and Regulatory
Affairs, Office of Management and
Budget, Room 10102, New Executive
Office Building, Washington, DC 20503,
or by sending an email to:
Lindsay.M.Abate@omb.eop.gov; and (ii)
Charles Riddle, Acting Director/Chief
Information Officer, Securities and
Exchange Commission, c/o Candace
Kenner, 100 F Street NE, Washington,
DC 20549 or send an email to: PRA_
Mailbox@sec.gov. Comments must be
submitted to OMB within 30 days of
this notice.
Dated: June 18, 2019.
Eduardo A. Aleman,
Deputy Secretary.
[FR Doc. 2019–13279 Filed 6–20–19; 8:45 am]
BILLING CODE 8011–01–P
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[Release No. 34–86120; File No. SR–BX–
2019–019]
Self-Regulatory Organizations; Nasdaq
BX, Inc.; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change To Amend the
Exchange’s Credits at Equity 7,
Section 118(a)
June 17, 2019.
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 June 4,
2019, Nasdaq BX, Inc. (‘‘BX’’ or
‘‘Exchange’’) filed with the Securities
and Exchange Commission (‘‘SEC’’ or
‘‘Commission’’) the proposed rule
change as described in Items I, II, and
III, below, which Items have been
prepared by the Exchange. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to amend the
Exchange’s credits at Equity 7, Section
118(a), as described further below.
The text of the proposed rule change
is available on the Exchange’s website at
https://nasdaqbx.cchwallstreet.com/, at
the principal office of the Exchange, 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
The Exchange operates on the ‘‘takermaker’’ model, whereby it pays credits
to members that take liquidity and
1 15
2 17
Frm 00114
Fmt 4703
Sfmt 4703
E:\FR\FM\21JNN1.SGM
U.S.C. 78s(b)(1).
CFR 240.19b–4.
21JNN1
Agencies
[Federal Register Volume 84, Number 120 (Friday, June 21, 2019)]
[Notices]
[Pages 29267-29270]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-13113]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-86119; File No. SR-OCC-2019-004]
Self-Regulatory Organizations; the Options Clearing Corporation;
Order Approving Proposed Rule Change Related to the Introduction of a
New Liquidation Cost Model in the Options Clearing Corporation's Margin
Methodology
June 17, 2019.
I. Introduction
On April 18, 2019, the Options Clearing Corporation (``OCC'') filed
with the Securities and Exchange Commission (``Commission'') the
proposed rule change SR-OCC-2019-004 (``Proposed Rule Change'')
pursuant to Section 19(b) of the Securities Exchange Act of 1934
(``Exchange Act'') \1\ and Rule 19b-4 \2\ thereunder to propose changes
to OCC's margin methodology to introduce a new model to estimate the
liquidation cost for all options and futures, as well as the securities
in margin collateral.\3\
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Notice of Filing infra note 4, at 84 FR 19815.
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The Proposed Rule Change was published for public comment in the
Federal Register on May 6, 2019,\4\ and the Commission received no
comments regarding the Proposed Rule Change. This order approves the
Proposed Rule Change.
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\4\ Securities Exchange Act Release No. 85755 (Apr. 30, 2019),
84 FR 19815 (May 6, 2019) (SR-OCC-2019-004) (``Notice of Filing'').
OCC also filed a related advance notice (SR-OCC-2019-802) (``Advance
Notice'') with the Commission 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 and Rule 19b-4(n)(1)(i) under the Exchange Act. 12 U.S.C.
5465(e)(1). 15 U.S.C. 78s(b)(1) and 17 CFR 240.19b-4, respectively.
The Advance Notice was published in the Federal Register on May 21,
2019. Securities Exchange Act Release No. 85863 (May 15, 2019), 84
FR 23090 (May 21, 2019) (SR-OCC-2019-802).
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II. Background
The System for Theoretical Analysis and Numerical Simulations
(``STANS'') is OCC's methodology for calculating margin requirements.
OCC uses the STANS methodology to measure the exposure of portfolios of
options and futures cleared by OCC and of cash instruments that are
part of margin collateral. STANS margin requirements are intended to
cover potential losses due to price movements over a two-day risk
horizon; however, the current STANS margin requirements do not cover
the potential additional liquidation costs OCC may incur in closing out
a defaulted Clearing Member's portfolio.\5\ Closing out positions in a
defaulted Clearing Member's portfolio could entail selling longs at the
bid price and covering shorts at the ask price. Additionally, even
well-hedged portfolios consisting of offsetting longs and shorts would
require some cost to liquidate in the event of a default. The process
of modeling liquidation costs is, therefore, relevant to ensuring that
OCC holds
[[Page 29268]]
sufficient financial resources to close-out the portfolio of a
defaulted Clearing Member.
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\5\ OCC previously introduced a liquidation cost model into
STANS for risk managing only long-dated options on the Standard &
Poor's (``S&P'') 500 index (``SPX'') that have a tenor of three-
years or more. See Securities Exchange Act Release No. 70719
(October 18, 2013), 78 FR 63548 (October 24, 2013) (SR-OCC-2013-16).
Under the proposal described in the Proposed Rule Change, OCC would
replace the existing liquidation model for long-dated SPX options
with the proposed model. Long-dated SPX options, however,
constituted less than 0.5 percent of open interest in SPX options
open interest at the time of filing. See Notice of Filing, 84 FR at
19816, note 7.
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OCC is proposing to introduce a new model to its margin methodology
to estimate the liquidation cost for all options and futures, as well
as cash instruments that are part of margin collateral. According to
OCC, the purpose of this proposal is to collect additional financial
resources to guard against potential shortfalls in margin requirements
that may arise due to the costs of liquidating the portfolio of a
defaulted Clearing Member.\6\ The liquidation cost charge would be an
add-on to all accounts incurring a STANS margin charge. At a high
level, the proposed model would estimate the cost to liquidate a
portfolio based on the mid-points of the bid-ask spreads for the
financial instruments within the portfolio, and would scale up such
liquidation costs for large or concentrated positions that would likely
be more expensive to close out.
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\6\ See Notice of Filing, 84 FR at 19816.
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OCC's proposed liquidation cost model would calculate liquidation
costs based on risk measures, gross contract volumes, and market bid-
ask spreads. As described in the Proposed Rule Change, the liquidation
cost model would include the following components: (1) Calculation of
liquidation costs for each sub-portfolio (as described below), which
would then be aggregated at the portfolio level; (2) calculation of
concentration charges that would be applied to scale-up the liquidation
costs as appropriate; and (3) establishment of the liquidation cost as
a floor on a Clearing Member's margin requirement.\7\
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\7\ OCC also proposes a conforming change to its Margin Policy,
which would reference OCC's model documentation.
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A. Liquidation Costs
The proposed model would calculate two risk-based liquidation costs
for a portfolio: (1) The Vega \8\ liquidation cost (``Vega LC''), and
(2) the Delta \9\ liquidation cost (``Delta LC''). Options products
would incur both a Vega LC and a Delta LC, while Delta-one
products,\10\ such as futures contracts, Treasury securities, and
equity securities, would incur only a Delta LC.
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\8\ The Vega of an option represents the sensitivity of the
option price to the volatility of the underlying security.
\9\ The Delta of an option represents the sensitivity of the
option price to the price of the underlying security.
\10\ A ``Delta-one product'' refers to a product for which a
change in the value of the underlying asset results in a change of
the same, or nearly the same, proportion in the value of the
product.
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The process of calculating the Vega LC and the Delta LC for each
portfolio would require a series of steps, beginning with the
decomposition of each portfolio into a set of sub-portfolios based on
the asset underlying each instrument in the portfolio. Each sub-
portfolio would represent a class of instruments. As proposed, the
model would include 14 potential classes of underlying assets based on
the liquidity of the assets within each class.\11\
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\11\ For example, equity securities would be divided based on
membership in commonly used market indices (e.g., the S&P 100) or
other market liquidity measures, into liquidity classes (which could
include, but would not be limited to, High Liquid Equities, Medium
Liquid Equities, and Low Liquid Equities).
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a. Vega Liquidation Cost
To calculate the Vega LC of a sub-portfolio, OCC would group
contracts within a sub-portfolio into ``buckets'' based on each
contract's combination of tenor and Delta.\12\ OCC would then net the
long and the short positions down to a single net Vega within each
bucket. Next, OCC would estimate the average volatility spread (i.e.,
the estimated bid-ask spread on implied volatility) of the contracts in
each bucket.\13\ The Vega LC of each bucket would be the net Vega
multiplied by the average volatility spread of the bucket. The Vega LC
of a sub-portfolio would be the aggregated Vega LCs of the buckets
within that sub-portfolio. Similarly, the Vega LC of the full portfolio
would be the aggregated Vega LCs of the sub-portfolios within that
portfolio.\14\
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\12\ For example, those options contracts with a tenor of 1
month and a Delta between 0.25 and 0.75 could be grouped in one
bucket within a sub-portfolio, while option contracts with a tenor
of 3 month and a Delta between 0.25 and 0.75 would be grouped in
another bucket. The proposed model would provide for 25 buckets
(based on combinations of tenor and Delta) for each sub-portfolio.
\13\ Rather than recalibrate the volatility spread of each
bucket as current market conditions change, the estimated volatility
spread of each bucket within a sub-portfolio would be calibrated
based on data from historical periods of market stress.
\14\ The process for aggregating Vega LCs, of both sub-
portfolios and portfolios, under the proposed model, is based on the
correlations of either the bucket or the sub-portfolio being
aggregated. To simplify the portfolio-level aggregation, the
proposed model would use a single correlation value across all sub-
portfolios in a given portfolio rather than a correlation matrix. To
account for potential errors that could arise out of such a
simplification, the proposed model would require the calculation of
three portfolio-level Vega LCs based on the three different
correlation values (i.e., minimum, maximum, and average). The
portfolio Vega LC would be the highest of the three Vega LCs
calculated in this manner.
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Under the proposed model, the Vega LC calculation process could
result in a portfolio-level Vega LC of zero because the process permits
offsets between contracts. To prevent such a result, OCC proposes
including a minimum Vega LC based on the number of contracts in each
sub-portfolio. The minimum Vega LC of a sub-portfolio would be the
total number of option contracts in the sub-portfolio multiplied by a
fixed dollar amount.\15\
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\15\ Specifically, the minimum cost rate would initially be set
as two dollars per contract, unless the position is long and the net
asset value per contract is less than $2.00. (For a typical option
with a contract size of 100, this would occur if the option was
priced below $0.02.)
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b. Delta Liquidation Cost
Similar to the Vega LC process, the model would calculate Delta LC
for each sub-portfolio, which would then be aggregated at the portfolio
level. OCC would first identify and net down the Delta of the positions
within each sub-portfolio. For each sub-portfolio, OCC would estimate a
bid-ask price spread (as a percentage). Such a percentage would
represent the cost of liquidating one dollar unit of the underlying
security during a period of market stress. The sub-portfolio Delta LC
would be the net dollar Delta of the sub-portfolio multiplied by the
bid-ask price spread percentage.\16\ The portfolio-level Delta LC would
be the simple sum of the sub-portfolio Delta LCs.
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\16\ As described in the Notice of Filing, the process for
determining the Delta LC of a sub-portfolio of U.S. dollar Treasury
bonds would be different. Specifically, it would be based on the sum
of Delta LCs across six tenor buckets. See Notice of Filing, 84 FR
at 19818.
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B. Concentration Charges
The proposed model would also address the potential risks involved
in closing out large or concentrated positions in a portfolio. The size
of an open position is typically measured against the relevant
instrument's average daily trading volume (``ADV''). Closing out a
position in excess of the ADV would be expected to increase the cost of
liquidation. To account for such considerations, the proposed model
incorporates a Vega concentration factor and a Delta concentration
factor. The concentration factors would be used to scale the Vega LCs
and the Delta LCs of each sub-portfolio and to take into account the
additional risk posed by large or concentrated positions. The
concentration factor could increase, but would not decrease the Vega
LCs and the Delta LCs.
C. Margin Floor
As noted above, the liquidation cost charge (i.e., sum of the
portfolio-level Vega LC and Delta LC) would be applied as an add-on to
the STANS margin requirement for each account. Because STANS margin
requirements are
[[Page 29269]]
intended to cover potential losses due to price movements over a two-
day risk horizon, the STANS requirement for well-hedged portfolios may
be positive, which could result in a margin credit instead of a charge.
To account for the risk of potentially liquidating a portfolio at
current (instead of two-day ahead) prices, OCC proposes to design the
model such that it would not permit a margin credit to offset a
portfolio's liquidation cost. Under the proposal, therefore, the final
margin requirement for a portfolio could not be lower than its
liquidation cost charge.
III. Discussion and Commission Findings
Section 19(b)(2)(C) of the Exchange 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 Exchange Act and the rules and regulations
thereunder applicable to such organization.\17\ After carefully
considering the Proposed Rule Change, the Commission finds the proposal
is consistent with the requirements of the Exchange Act and the rules
and regulations thereunder applicable to OCC. More specifically, the
Commission finds that the proposal is consistent with Section
17A(b)(3)(F) of the Exchange Act \18\ and Rule 17Ad-22(e)(6)(i)
thereunder.\19\
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\17\ 15 U.S.C. 78s(b)(2)(C).
\18\ 15 U.S.C. 78q-1(b)(3)(F).
\19\ 17 CFR 240.17Ad-22(e)(6)(i).
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A. Consistency With Section 17A(b)(3)(F) of the Exchange Act
Section 17A(b)(3)(F) of the Exchange Act requires that the rules of
a clearing agency be designed to, among other things, assure the
safeguarding of securities and funds which are in the custody or
control of the clearing agency or for which it is responsible.\20\
Based on its review of the record, the Commission believes that the
proposed changes are designed to assure the safeguarding of securities
and funds which are in OCC's custody or control for the reasons set
forth below.
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\20\ 15 U.S.C. 78q-1(b)(3)(F).
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OCC manages its credit exposure to Clearing Members, in part,
through the collection of collateral based on OCC's margin methodology.
As noted above, OCC's current margin methodology is not designed to
account for liquidation costs that OCC could incur in the process of
closing out a defaulted Clearing Member's portfolio. OCC proposes to
adopt a model designed to estimate the margin necessary to cover
liquidation costs that OCC could incur when closing out a defaulted
Clearing Member's portfolio. The Commission believes that adopting a
model designed to identify and measure a risk not addressed elsewhere
in OCC's margin methodology--namely, the cost to liquidate a defaulted
Clearing Member's portfolio during periods of market stress--would
improve OCC's margin methodology by generating margin requirements
designed to more fully cover OCC's credit exposure to each of its
Clearing Members.
Moreover, the Commission believes that the inclusion of
concentration charges in the proposed liquidation cost model would
enhance the measurement of risk described above. The cost of
liquidating a defaulted Clearing Member's portfolio is, in part, a
function of market prices and market depth present at the time of the
Clearing Member's default. The process of liquidating on a compressed
timeframe a large or concentrated position during such a period could
negatively affect such market prices for OCC. In recognition of such
costs, OCC proposes to use concentration factors to scale up both the
Vega LCs and Delta LCs based on the size of a defaulted Clearing
Member's positions relative to the average daily volume of the
financial instruments in the defaulted Clearing Member's portfolio.
Including concentration charges in OCC's proposed liquidation cost
model would further facilitate the generation of requirements designed
to more fully cover OCC's credit exposure to each of its Clearing
Members.
The Commission also believes that the use of the proposed
liquidation cost model to create a margin floor would improve the
management of OCC's credit exposures through the collection of margin.
OCC's margin methodology may produce a credit for well-hedged
portfolios because it is focused on the potential losses resulting from
price movements over a two-day risk horizon. OCC could, however, incur
costs in the process of closing out a defaulted Clearing Member's
portfolio at current prices, rather than prices two days into the
future. OCC's proposal acknowledges this potential gap by requiring
that a Clearing Member post, at a minimum, margin to cover the
liquidation cost of its portfolio.
As discussed above, OCC proposes to identify and manage the
potential cost of liquidating a defaulted Clearing Member's portfolio.
OCC's estimation of such potential costs would be calibrated based on
historical periods of market stress. OCC proposes to collect resources
designed to cover such costs in the form of margin. Collecting
additional margin to support OCC's ability to close out a default
Clearing Member's portfolio during a period of market stress could
reduce the potentiality that OCC would mutualize a loss arising out of
the close-out process. While unavoidable under certain circumstances,
reducing the potentiality of loss mutualization during periods of
market stress could reduce the potential knock-on effects to non-
defaulting Clearing Members, their customers and the broader options
market arising out of a Clearing Member default. The Commission
believes, therefore, that adoption of a liquidation cost model
calibrated based on periods of market stress would be consistent with
assuring the safeguarding of securities and funds which are in OCC's
custody or control or for which it is responsible consistent with the
requirements of Section 17A(b)(3)(F) of the Exchange Act.\21\
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\21\ 15 U.S.C. 78q-1(b)(3)(F).
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B. Consistency With Rule 17Ad-22(e)(6)(i) Under the Exchange Act
Rule 17Ad-22(e)(6)(i) under the Exchange Act requires, in part,
that a covered clearing agency establish, implement, maintain, and
enforce written policies and procedures reasonably designed to cover,
if the covered clearing agency provides central counterparty services,
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.\22\
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\22\ 17 CFR 240.17Ad-22(e)(6)(i).
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As described above, the liquidation cost that OCC could incur in
the process of closing out a Clearing Member's portfolio is, in part, a
function of the spread between the bid and the ask prices of financial
instruments within the portfolio. The STANS methodology attempts to
address potential losses resulting from changes in price over a two-day
period. As described above, however, STANS is not designed to account
for liquidation costs. OCC's proposed model would be designed to
account for particular attributes of the products in a defaulted
Clearing Member's portfolio, including the bid-ask spreads and average
daily volume of such products.\23\ Further, the proposal
[[Page 29270]]
would acknowledge the purpose of the proposed liquidation cost model as
distinct from the STANS methodology by using the proposed liquidation
cost model as a floor on a Clearing Member's margin requirements.
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\23\ As noted above, OCC proposes to incorporate the proposed
model into its margin methodology documentation and to reference the
margin add-on in its Margin Policy.
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OCC's proposal would be tailored to the particular attributes of
products in a Clearing Member's portfolio. As described above, OCC
would use the proposed model to calculate two risk-based liquidation
costs for each portfolio: (1) The Vega LC and (2) the Delta LC. The
Commission believes, therefore, that the adoption of the proposed
liquidation cost model designed to produce margin levels commensurate
with the risks of liquidating a Clearing Member's portfolio is
consistent with Exchange Act Rule 17Ad-22(e)(6)(i).\24\
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\24\ 17 CFR 240.17Ad-22(e)(6)(i).
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IV. Conclusion
On the basis of the foregoing, the Commission finds that the
Proposed Rule Change is consistent with the requirements of the
Exchange Act, and in particular, the requirements of Section 17A of the
Exchange Act \25\ and the rules and regulations thereunder.
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\25\ In approving this Proposed Rule Change, the Commission has
considered the proposed rules' impact on efficiency, competition,
and capital formation. See 15 U.S.C. 78c(f).
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It is therefore ordered, pursuant to Section 19(b)(2) of the
Exchange Act,\26\ that the Proposed Rule Change (SR-OCC-2019-004) be,
and hereby is, approved.
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\26\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\27\
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\27\ 17 CFR 200.30-3(a)(12).
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Vanessa A. Countryman,
Acting Secretary.
[FR Doc. 2019-13113 Filed 6-20-19; 8:45 am]
BILLING CODE 8011-01-P