Self-Regulatory Organizations; Fixed Income Clearing Corporation; Order Approving a Proposed Rule Change To Require Confirmation of Cybersecurity Program, 68266-68269 [2019-26844]
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68266
Federal Register / Vol. 84, No. 240 / Friday, December 13, 2019 / Notices
provide additional clarity and detail in
the Exchange’s rules. The Exchange
does not believe that its proposal to
make non-substantive changes to update
internal cross-references in the
Exchange’s rulebook imposes any
burden on intramarket competition as
the rules of the Exchange apply equally
to all Exchange Members.
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
Written comments were neither
solicited nor received.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
Because the foregoing proposed rule
change does not: (i) Significantly affect
the protection of investors or the public
interest; (ii) impose any significant
burden on competition; and (iii) become
operative for 30 days after the date of
the filing, or such shorter time as the
Commission may designate, the
proposed rule change has become
effective pursuant to 19(b)(3)(A) of the
Act 15 and Rule 19b–4(f)(6) 16
thereunder.
A proposed rule change filed
pursuant to Rule 19b–4(f)(6) under the
Act 17 normally does not become
operative for 30 days after the date of its
filing. However, Rule 19b–4(f)(6)(iii)
under the Act 18 permits the
Commission to designate a shorter time
if such action is consistent with the
protection of investors and the public
interest. The Exchange has asked the
Commission to waive the 30-day
operative delay so that the proposal may
become operative immediately upon
filing. The Exchange states that waiver
of the operative delay would allow the
Exchange to immediately harmonize its
rules with the rules of the other Plan
Participants, which would promote
consistency in the interpretation and
application of rules under the Plan and
further the objectives of the Plan to
enable Participants to act jointly in
establishing a framework for providing
order protection and addressing Locked
and Crossed markets. The Commission
finds that it is consistent with the
protection of investors and the public
15 15
U.S.C. 78s(b)(3)(A).
CFR 240.19b–4(f)(6). In addition, Rule 19b–
4(f)(6) requires a self-regulatory organization to give
the Commission written notice of its intent to file
the proposed rule change at least five business days
prior to the date of filing of the proposed rule
change, or such shorter time as designated by the
Commission. The Exchange has satisfied this
requirement.
17 17 CFR 240.19b–4(f)(6).
18 17 CFR 240.19b–4(f)(6)(iii).
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16 17
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interest to waive the 30-day operative
delay to allow the Exchange to adopt a
definition of Complex Trade, which the
Exchange inadvertently omitted when it
adopted rules relating to the Plan. The
Commission notes that the proposed
change does not raise new or novel
regulatory issues because the
Exchange’s proposed definition of
Complex Trade is identical to the
definition of Complex Trade adopted by
one exchange 19 and substantially
similar to the definition of Complex
Trade adopted by other exchanges.20
Accordingly, the Commission hereby
waives the operative delay and
designates the proposal operative upon
filing.21
At any time within 60 days of the
filing of the proposed rule change, the
Commission summarily may
temporarily suspend such rule change if
it appears to the Commission that such
action is 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
to determine whether the proposed rule
should be approved or disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
Electronic Comments
• Use the Commission’s internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
MIAX–2019–48 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–MIAX–2019–48. 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
19 See
supra note 9.
supra note 5.
21 For purposes only of waiving the 30-day
operative delay, the Commission has also
considered the proposed rule’s impact on
efficiency, competition, and capital formation. See
15 U.S.C. 78c(f).
20 See
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internet website (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for website viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE,
Washington, DC 20549, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change.
Persons submitting comments are
cautioned that we do not redact or edit
personal identifying information from
comment submissions. You should
submit only information that you wish
to make available publicly. All
submissions should refer to File
Number SR–MIAX–2019–48 and should
be submitted on or before January 3,
2020.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.22
Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2019–26842 Filed 12–12–19; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–87697; File No. SR–FICC–
2019–005]
Self-Regulatory Organizations; Fixed
Income Clearing Corporation; Order
Approving a Proposed Rule Change To
Require Confirmation of Cybersecurity
Program
December 9, 2019.
I. Introduction
On October 15, 2019, FICC Clearing
Corporation (‘‘FICC’’) 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 proposed rule change SR–
22 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
1 15
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FICC–2019–005. The proposed rule
change was published for comment in
the Federal Register on October 30,
2019.3 The Commission did not receive
any comment letters 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
FICC proposes to modify its
Government Securities Division
(‘‘GSD’’) Rulebook (‘‘GSD Rules’’),
Mortgage-Backed Securities Division
(‘‘MBSD’’) Clearing Rules (‘‘MBSD
Rules’’), and the Electronic Pool
Notification (‘‘EPN’’) Rules of MBSD
(‘‘EPN Rules,’’ and, together with the
GSD Rules and the MBSD Rules, the
‘‘Rules’’) 4 in order to (1) define the term
‘‘Cybersecurity Confirmation’’ as a
written representation that addresses a
submitting entity’s cybersecurity
program (described more fully below);
and (2) require FICC’s members and
applicants for membership to submit to
FICC a Cybersecurity Confirmation
(both as part of an initial application for
membership, and on an ongoing basis
for members, at least every two years).
A. Background
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FICC plays a prominent role in the
fixed income markets as the sole
clearing agency in the United States
acting as a central counterparty and
provider of significant clearance and
settlement services for cash settled U.S.
treasury and agency securities and the
non-private label mortgage-backed
securities markets.5 In light of FICC’s
critical role in the marketplace, FICC
was designated a Systemically
Important Financial Market Utility
(‘‘SIFMU’’) under Title VIII of the DoddFrank Wall Street Reform and Consumer
Protection Act of 2010.6 Due to FICC’s
unique position in the marketplace, a
failure or a disruption to FICC could,
among other things, increase the risk of
3 Securities Exchange Act Release No. 87394
(October 24, 2019), 84 FR 58194 (October 30, 2019)
(SR–FICC–2019–005) (‘‘Notice’’).
4 Capitalized terms not defined herein are defined
in the Rules, available at https://www.dtcc.com/
legal/rules-and-procedures. References to
‘‘members’’ in this Order include the participants
of GSD and MBSD, including GSD Netting
Members, GSD Comparison-Only Members, GSD
Sponsoring Members, GSD CCIT Members, GSD
Funds-Only Settling Bank Members, MBSD
Clearing Members, MBSD Cash Settling Bank
Members, and MBSD EPN Users as such terms are
defined in the respective Rules.
5 See Financial Stability Oversight Counsel 2012
Annual Report, Appendix A (‘‘FSOC 2012 Report’’),
available at https://www.treasury.gov/initiatives/
fsoc/Documents/2012%20Annual%20Report.pdf.
6 12 U.S.C. 5465(e)(1). See FSOC 2012 Report,
supra note 5.
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significant liquidity problems spreading
among financial institutions or markets,
and thereby threaten the stability of the
financial system in the United States.7
FICC’s members connect to FICC,
either through the Securely Managed
and Reliable Technology (‘‘SMART’’)
network or through other electronic
means, such as a third party service
provider, service bureau, network, or
the internet. The SMART network is a
technology managed by FICC’s parent
company, The Depository Trust &
Clearing Corporation (‘‘DTCC’’), that
connects a nationwide complex of
networks, processing centers, and
control facilities. Currently, FICC does
not require its members or applicants
for membership to represent that they
maintain a cybersecurity program as a
condition for connecting to FICC via the
SMART network or other means.
FICC states that many of its members
and applicants for membership may
currently be subject to regulations that
are designed, in part, to protect against
cyberattacks.8 Accordingly, such
entities would currently be required to
follow standards established by national
or international organizations focused
on information security management,
and they would currently maintain
protocols for their senior management to
verify the existence of cybersecurity
programs sufficient to meet regulatory
obligations. FICC further believes that
some of its members and applicants for
membership might also currently follow
protocols substantially similar to the
regulations referred to earlier in this
paragraph in order to meet the evolving
cybersecurity expectations of regulators
and/or their own institutional
customers.9
Although FICC believes that its
members and applicants for
membership may currently maintain
robust cybersecurity programs, FICC
seeks to better ensure the protection of
its network by requiring its members
and applicants for membership to
7 See
FSOC 2012 Report, supra note 5.
example, depending on the type of entity,
FICC states that its members may be subject to one
or more of the following regulations: (1) Regulation
S–ID, which requires ‘‘financial institutions’’ or
‘‘creditors’’ under the rule to adopt programs to
identify and address the risk of identity theft of
individuals (17 CFR 248.201–202); (2) Regulation
S–P, which requires broker-dealers, investment
companies, and investment advisers to adopt
written policies and procedures that address
administrative, technical, and physical safeguards
for the protection of customer records and
information (17 CFR 248.1–30); and (3) Rule 15c3–
5 under the Act, known as the ‘‘Market Access
Rule,’’ which requires broker-dealers to establish,
document, and maintain a system for regularly
reviewing the effectiveness of its management
controls and supervisory procedures (17 CFR
240.15c3–5). Notice, supra note 3, at 58195.
9 Id.
8 For
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68267
confirm that they are meeting certain
cybersecurity standards in order to
connect to FICC via the SMART
network or other means. Therefore,
FICC proposes to require all members
and applicants for membership to
submit a written Cybersecurity
Confirmation that includes specific
representations regarding the submitting
entity’s cybersecurity program and
framework. FICC states that the
information contained in the
Cybersecurity Confirmation would help
FICC to better understand the
cybersecurity programs and frameworks
of entities seeking to connect to FICC,
and thereby identify possible cyber risk
exposures.10 As a result, FICC would be
better able to establish appropriate
controls to mitigate such risks and their
possible impacts on FICC’s operations.
B. Proposed Changes
FICC proposes to modify its Rules to:
(1) Provide a detailed definition of the
Cybersecurity Confirmation; and (2)
require FICC’s members and applicants
for membership to submit to FICC a
Cybersecurity Confirmation (both as
part of an initial application for
membership, and on an ongoing basis
for members, at least every two years).
Each of these proposed rule changes is
described in greater detail below.
1. Cybersecurity Confirmation
FICC proposes to define the term
‘‘Cybersecurity Confirmation’’ to mean a
written form, in a format provided by
FICC and signed by the submitting
entity’s designated senior executive
with the authority to attest to the
cybersecurity matters contained in the
form.11 The form would contain specific
representations regarding the submitting
entity’s cybersecurity program and
framework. Such representations would
cover the two years prior to the date of
the most recently provided
Cybersecurity Confirmation. The
Cybersecurity Confirmation would
include the following representations:
• The submitting entity has defined
and maintains a comprehensive
cybersecurity program and framework
that considers potential cyber threats
that impact the submitting entity’s
organization, and protects the
confidentiality, integrity, and
availability requirements of its systems
and information.
• The submitting entity has
implemented and maintains a written
10 Notice,
supra note 3, at 58194–95.
supra note 3, at 58195. See also FICC
Cybersecurity Confirmation Form, submitted as
Exhibit 3 to SR–FICC–2019–005, available at
https://www.sec.gov/rules/sro/ficc/2019/34-87394ex3.pdf.
11 Notice,
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enterprise cybersecurity policy or
policies approved by the submitting
entity’s senior management or board of
directors, and the submitting entity’s
cybersecurity framework is in alignment
with standard industry best practices
and guidelines.12
• If the submitting entity uses a third
party service provider or service
bureau(s) to connect or transact business
or to manage the connection with FICC,
the submitting entity has an appropriate
program to evaluate the cyber risks and
impact of these third parties and to
review the third party assurance reports.
• The submitting entity’s
cybersecurity program and framework
protects the segment of its system that
connects to and/or interacts with FICC.
• The submitting entity has in place
an established process to remediate
cyber issues identified to meet its
regulatory and/or statutory
requirements.
• The submitting entity periodically
updates the risk processes of its
cybersecurity program and framework
based on a risk assessment or changes
to technology, business, threat
ecosystem, and/or regulatory
environment.
• The submitting entity’s
cybersecurity program and framework
has been reviewed by one of the
following: (1) The submitting entity, if
it has filed and maintains a current
Certification of Compliance with the
Superintendent of the New York State
Department of Financial Services
confirming compliance with its
Cybersecurity Requirements for
Financial Services Companies; 13 (2) a
regulator who assesses the submitting
entity’s cybersecurity program and
framework against an industry
cybersecurity framework or industry
standard, including those that are listed
12 Examples of recognized frameworks, guidelines
and standards that FICC believes are adequate
include the Financial Services Sector Coordinating
Council Cybersecurity Profile, the National Institute
of Standards and Technology Cybersecurity
Framework (‘‘NIST CSF’’), International
Organization for Standardization (‘‘ISO’’) standard
27001/27002 (‘‘ISO 27001’’), Federal Financial
Institutions Examination Council (‘‘FFIEC’’)
Cybersecurity Assessment Tool, Critical Security
Controls Top 20, and Control Objectives for
Information and Related Technologies. FICC would
identify recognized frameworks, guidelines and
standards in the form of Cybersecurity Confirmation
and in an Important Notice that FICC would issue
from time to time. FICC would also consider
accepting other standards upon request. Notice,
supra note 3, at 58195.
13 23 N.Y. Comp. Codes R. & Regs. tit. 23, § 500
et seq. (2017). FICC states that this regulation
requires entities to confirm that they have
comprehensive cybersecurity programs as described
in the regulation, and FICC believes this regime is
sufficient to meet the objectives of the proposed
Cybersecurity Confirmation. Notice, supra note 3, at
58196.
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on the Cybersecurity Confirmation form
and in an Important Notice that is
issued by FICC from time to time; 14 (3)
an independent external entity with
cybersecurity domain expertise in
relevant industry standards and
practices, including those that are listed
on the Cybersecurity Confirmation form
and in an Important Notice that is
issued by FICC from time to time; 15 or
(4) an independent internal audit
function reporting directly to the
submitting entity’s board of directors or
designated board of directors
committee, such that the findings of that
review are shared with these governance
bodies.
FICC states that it designed the
representations in the Cybersecurity
Confirmation to provide information on
how each submitting entity manages
cybersecurity with respect to its
connectivity to FICC.16 FICC believes
that by requiring these representations
from members and applicants for
membership, the proposed
Cybersecurity Confirmation would
provide useful information designed to
enable FICC to make informed decisions
about risks or threats, perform
additional monitoring, target potential
vulnerabilities, and otherwise protect
the FICC network.17
2. Initial and Ongoing Membership
Requirement
FICC proposes to require new
applicants for FICC membership to
submit a Cybersecurity Confirmation as
part of their application materials. FICC
also proposes to require all FICC
members to submit a Cybersecurity
Confirmation at least every two years.
With respect to the requirement to
submit a Cybersecurity Confirmation at
least every two years, FICC would
provide all members with notice of the
date on which the Cybersecurity
14 FICC
states that current industry cybersecurity
frameworks and industry standards could include,
for example, the Office of the Comptroller of the
Currency or the FFIEC Cybersecurity Assessment
Tool. FICC would identify acceptable industry
cybersecurity frameworks and standards in the
Cybersecurity Confirmation form and in an
Important Notice that FICC would issue from time
to time. FICC would also consider accepting other
industry cybersecurity frameworks and standards
upon request. Notice, supra note 3, at 58196.
15 FICC states that a third party with cybersecurity
domain expertise is one that follows and
understands applicable industry standards,
practices, and regulations, such as ISO 27001
certification or NIST CSF assessment. FICC would
identify acceptable industry standards and practices
in the Cybersecurity Confirmation form and in an
Important Notice that FICC would issue from time
to time. FICC would also consider accepting other
industry standards and practices upon request.
Notice, supra note 3, at 58196.
16 Notice, supra note 3, at 58196.
17 Id.
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Confirmation would be due no later
than 180 calendar days prior to the due
date.
C. Implementation Timeframe
The proposed rule change would be
effective upon Commission approval.
New applicants for FICC membership
would be required to submit a
Cybersecurity Confirmation as part of
their application materials. The
requirement to submit a Cybersecurity
Confirmation would also apply to
applicants whose applications are
pending with FICC at the time the
Commission approves the proposed rule
change. For existing FICC members,
FICC would provide notice of the due
date to submit a Cybersecurity
Confirmation, not later than 180 days
prior to the due date. Finally, FICC
would provide such notice to its
members at least every two years going
forward.
III. Discussion and Commission
Findings
Section 19(b)(2)(C) of the Act 18
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 Act and
rules and regulations thereunder
applicable to such organization. After
carefully considering the proposed rule
change, the Commission finds that the
proposed rule change is consistent with
the requirements of the Act and the
rules and regulations thereunder
applicable to FICC. In particular, the
Commission finds that the proposed
rule change is consistent with Section
17A(b)(3)(F) of the Act,19 and Rules
17Ad–22(e)(17)(i) and (e)(17)(ii)
promulgated under the Act,20 for the
reasons described below.
A. Consistency With Section
17A(b)(3)(F) of the Act
Section 17A(b)(3)(F) of the Act
requires that the rules of a clearing
agency be designed to, among other
things, promote the prompt and
accurate clearance and settlement of
securities transactions and assure the
safeguarding of securities and funds
which are in the custody or control of
the clearing agency or for which it is
responsible.21
As described above, FICC proposes to
require its members and applicants for
membership to submit a Cybersecurity
Confirmation, confirming the existence
18 15
U.S.C. 78s(b)(2)(C).
U.S.C. 78q–1(b)(3)(F).
20 17 CFR 240.17Ad–22(e)(17)(i) and (e)(17)(ii).
21 15 U.S.C. 78q–1(b)(3)(F).
19 15
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and nature of their cybersecurity
programs. The Cybersecurity
Confirmations should provide FICC
with useful information regarding the
cybersecurity programs of the
submitting entities. By conditioning an
entity’s connectivity to FICC via the
SMART network or other means on the
submission of a Cybersecurity
Confirmation, FICC should be better
enabled to reduce the cyber risks of
electronically connecting to entities that
have not confirmed the existence and
nature of their cybersecurity programs.
Accordingly, the proposed
Cybersecurity Confirmation requirement
should provide FICC with information
to better identify its exposure to cyber
risks and to take steps to mitigate those
risks.
If not adequately addressed, the risk
of cyberattacks and other cyber
vulnerabilities could affect FICC’s
network and FICC’s ability to clear and
settle securities transactions, or to
safeguard the securities and funds
which are in FICC’s custody or control,
or for which it is responsible. The
proposed Cybersecurity Confirmation
requirement is a tool designed to
address those risks as described above.
Therefore, the Commission finds the
proposed Cybersecurity Confirmation
requirement would promote the prompt
and accurate clearance and settlement of
securities transactions and assure the
safeguarding of securities and funds
which are in the custody or control of
FICC or for which it is responsible,
consistent with the requirements of
Section 17A(b)(3)(F) of the Act.22
B. Consistency With Rule 17Ad–
22(e)(17)(i) Under the Act
Rule 17Ad–22(e)(17)(i) under the Act
requires that each covered clearing
agency establish, implement, maintain
and enforce written policies and
procedures reasonably designed to
manage the covered clearing agency’s
operational risks by identifying the
plausible sources of operational risk,
both internal and external, and
mitigating their impact through the use
of appropriate systems, policies,
procedures, and controls.23 FICC’s
operational risks include protecting its
electronic systems from cyber risks.
As described above, entities connect
electronically to FICC via the SMART
network or other means. The proposed
Cybersecurity Confirmation requirement
should reduce cyber risks to FICC by
requiring members and applicants for
membership to confirm that they have
defined and maintain cybersecurity
22 Id.
23 17
programs and frameworks that meet
standard industry best practices and
guidelines. The representations in each
submitting entity’s Cybersecurity
Confirmation would provide
information that should help FICC to
mitigate its exposure to cyber risks, and
thereby decrease the operational risks
presented to FICC by its connections to
such entities. Thus, the proposed
Cybersecurity Confirmations should
enable FICC to better identify potential
sources of external operational risks and
mitigate the possible impacts of those
risks. Because the proposed changes
would help FICC identify and mitigate
plausible sources of external operational
risk, the Commission finds the proposed
changes are consistent with the
requirements of Rule 17Ad–22(e)(17)(i)
under the Act.24
C. Consistency With Rule 17Ad–
22(e)(17)(ii) Under the Act
Rule 17Ad–22(e)(17)(ii) under the Act
requires that each covered clearing
agency establish, implement, maintain
and enforce written policies and
procedures reasonably designed to
manage the covered clearing agency’s
operational risks by ensuring, in part,
that systems have a high degree of
security, resiliency, and operational
reliability.25 As noted above, FICC’s
operational risks include protecting its
electronic systems from cyber risks.
Although FICC believes that its
members and applicants for
membership may currently maintain
robust cybersecurity programs, FICC
currently does not require those entities
to represent that they maintain a
cybersecurity program as a condition for
connecting to FICC via the SMART
network or other means. FICC designed
the proposed Cybersecurity
Confirmation requirement to reduce
cyber risks by requiring its members and
applicants for membership to confirm
that they have defined and maintain
cybersecurity programs and frameworks
that meet standard industry best
practices and guidelines. The
representations in each submitting
entity’s Cybersecurity Confirmation
would provide more security for FICC’s
SMART network and other systems by
providing FICC with information
designed to help manage its cyberrelated operational risks, which in turn,
would enable FICC to take steps
necessary to strengthen the security of
its network to mitigate those risks. Since
the proposal would enhance FICC’s
ability to ensure that its systems have a
high degree of security, resiliency, and
24 Id.
CFR 240.17Ad–22(e)(17)(i).
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CFR 240.17Ad–22(e)(17)(ii).
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68269
operational reliability, the Commission
finds the proposed changes are
consistent with the requirements of Rule
17Ad–22(e)(17)(ii) under the Act.26
IV. Conclusion
On the basis of the foregoing, the
Commission finds that the proposed
rule change is consistent with the
requirements of the Act and, in
particular, with the requirements of
Section 17A of the Act 27 and the rules
and regulations promulgated
thereunder.
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act 28 that
proposed rule change SR–FICC–2019–
005, be, and hereby is, APPROVED.29
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.30
Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2019–26844 Filed 12–12–19; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–87698; File No. SR–DTC–
2019–008]
Self-Regulatory Organizations; The
Depository Trust Company; Order
Approving a Proposed Rule Change To
Require Confirmation of Cybersecurity
Program
December 9, 2019.
I. Introduction
On October 15, 2019, The Depository
Trust Company (‘‘DTC’’) 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 proposed rule change SR–
DTC–2019–008. The proposed rule
change was published for comment in
the Federal Register on October 30,
2019.3 The Commission did not receive
any comment letters on the proposed
rule change. For the reasons discussed
26 Id.
27 15
U.S.C. 78q–1.
U.S.C. 78s(b)(2).
29 In approving the proposed rule change, the
Commission considered the proposals’ impact on
efficiency, competition, and capital formation. 15
U.S.C. 78c(f).
30 17 CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 Securities Exchange Act Release No. 87393
(October 24, 2019), 84 FR 58189 (October 30, 2019)
(SR–DTC–2019–008) (‘‘Notice’’).
28 15
E:\FR\FM\13DEN1.SGM
13DEN1
Agencies
[Federal Register Volume 84, Number 240 (Friday, December 13, 2019)]
[Notices]
[Pages 68266-68269]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-26844]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-87697; File No. SR-FICC-2019-005]
Self-Regulatory Organizations; Fixed Income Clearing Corporation;
Order Approving a Proposed Rule Change To Require Confirmation of
Cybersecurity Program
December 9, 2019.
I. Introduction
On October 15, 2019, FICC Clearing Corporation (``FICC'') 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\ proposed rule change SR-
[[Page 68267]]
FICC-2019-005. The proposed rule change was published for comment in
the Federal Register on October 30, 2019.\3\ The Commission did not
receive any comment letters on the proposed rule change. For the
reasons discussed below, the Commission is approving the proposed rule
change.
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ Securities Exchange Act Release No. 87394 (October 24,
2019), 84 FR 58194 (October 30, 2019) (SR-FICC-2019-005)
(``Notice'').
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II. Description of the Proposed Rule Change
FICC proposes to modify its Government Securities Division
(``GSD'') Rulebook (``GSD Rules''), Mortgage-Backed Securities Division
(``MBSD'') Clearing Rules (``MBSD Rules''), and the Electronic Pool
Notification (``EPN'') Rules of MBSD (``EPN Rules,'' and, together with
the GSD Rules and the MBSD Rules, the ``Rules'') \4\ in order to (1)
define the term ``Cybersecurity Confirmation'' as a written
representation that addresses a submitting entity's cybersecurity
program (described more fully below); and (2) require FICC's members
and applicants for membership to submit to FICC a Cybersecurity
Confirmation (both as part of an initial application for membership,
and on an ongoing basis for members, at least every two years).
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\4\ Capitalized terms not defined herein are defined in the
Rules, available at https://www.dtcc.com/legal/rules-and-procedures.
References to ``members'' in this Order include the participants of
GSD and MBSD, including GSD Netting Members, GSD Comparison-Only
Members, GSD Sponsoring Members, GSD CCIT Members, GSD Funds-Only
Settling Bank Members, MBSD Clearing Members, MBSD Cash Settling
Bank Members, and MBSD EPN Users as such terms are defined in the
respective Rules.
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A. Background
FICC plays a prominent role in the fixed income markets as the sole
clearing agency in the United States acting as a central counterparty
and provider of significant clearance and settlement services for cash
settled U.S. treasury and agency securities and the non-private label
mortgage-backed securities markets.\5\ In light of FICC's critical role
in the marketplace, FICC was designated a Systemically Important
Financial Market Utility (``SIFMU'') under Title VIII of the Dodd-Frank
Wall Street Reform and Consumer Protection Act of 2010.\6\ Due to
FICC's unique position in the marketplace, a failure or a disruption to
FICC could, among other things, increase the risk of significant
liquidity problems spreading among financial institutions or markets,
and thereby threaten the stability of the financial system in the
United States.\7\
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\5\ See Financial Stability Oversight Counsel 2012 Annual
Report, Appendix A (``FSOC 2012 Report''), available at https://www.treasury.gov/initiatives/fsoc/Documents/2012%20Annual%20Report.pdf.
\6\ 12 U.S.C. 5465(e)(1). See FSOC 2012 Report, supra note 5.
\7\ See FSOC 2012 Report, supra note 5.
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FICC's members connect to FICC, either through the Securely Managed
and Reliable Technology (``SMART'') network or through other electronic
means, such as a third party service provider, service bureau, network,
or the internet. The SMART network is a technology managed by FICC's
parent company, The Depository Trust & Clearing Corporation (``DTCC''),
that connects a nationwide complex of networks, processing centers, and
control facilities. Currently, FICC does not require its members or
applicants for membership to represent that they maintain a
cybersecurity program as a condition for connecting to FICC via the
SMART network or other means.
FICC states that many of its members and applicants for membership
may currently be subject to regulations that are designed, in part, to
protect against cyberattacks.\8\ Accordingly, such entities would
currently be required to follow standards established by national or
international organizations focused on information security management,
and they would currently maintain protocols for their senior management
to verify the existence of cybersecurity programs sufficient to meet
regulatory obligations. FICC further believes that some of its members
and applicants for membership might also currently follow protocols
substantially similar to the regulations referred to earlier in this
paragraph in order to meet the evolving cybersecurity expectations of
regulators and/or their own institutional customers.\9\
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\8\ For example, depending on the type of entity, FICC states
that its members may be subject to one or more of the following
regulations: (1) Regulation S-ID, which requires ``financial
institutions'' or ``creditors'' under the rule to adopt programs to
identify and address the risk of identity theft of individuals (17
CFR 248.201-202); (2) Regulation S-P, which requires broker-dealers,
investment companies, and investment advisers to adopt written
policies and procedures that address administrative, technical, and
physical safeguards for the protection of customer records and
information (17 CFR 248.1-30); and (3) Rule 15c3-5 under the Act,
known as the ``Market Access Rule,'' which requires broker-dealers
to establish, document, and maintain a system for regularly
reviewing the effectiveness of its management controls and
supervisory procedures (17 CFR 240.15c3-5). Notice, supra note 3, at
58195.
\9\ Id.
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Although FICC believes that its members and applicants for
membership may currently maintain robust cybersecurity programs, FICC
seeks to better ensure the protection of its network by requiring its
members and applicants for membership to confirm that they are meeting
certain cybersecurity standards in order to connect to FICC via the
SMART network or other means. Therefore, FICC proposes to require all
members and applicants for membership to submit a written Cybersecurity
Confirmation that includes specific representations regarding the
submitting entity's cybersecurity program and framework. FICC states
that the information contained in the Cybersecurity Confirmation would
help FICC to better understand the cybersecurity programs and
frameworks of entities seeking to connect to FICC, and thereby identify
possible cyber risk exposures.\10\ As a result, FICC would be better
able to establish appropriate controls to mitigate such risks and their
possible impacts on FICC's operations.
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\10\ Notice, supra note 3, at 58194-95.
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B. Proposed Changes
FICC proposes to modify its Rules to: (1) Provide a detailed
definition of the Cybersecurity Confirmation; and (2) require FICC's
members and applicants for membership to submit to FICC a Cybersecurity
Confirmation (both as part of an initial application for membership,
and on an ongoing basis for members, at least every two years). Each of
these proposed rule changes is described in greater detail below.
1. Cybersecurity Confirmation
FICC proposes to define the term ``Cybersecurity Confirmation'' to
mean a written form, in a format provided by FICC and signed by the
submitting entity's designated senior executive with the authority to
attest to the cybersecurity matters contained in the form.\11\ The form
would contain specific representations regarding the submitting
entity's cybersecurity program and framework. Such representations
would cover the two years prior to the date of the most recently
provided Cybersecurity Confirmation. The Cybersecurity Confirmation
would include the following representations:
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\11\ Notice, supra note 3, at 58195. See also FICC Cybersecurity
Confirmation Form, submitted as Exhibit 3 to SR-FICC-2019-005,
available at https://www.sec.gov/rules/sro/ficc/2019/34-87394-ex3.pdf.
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The submitting entity has defined and maintains a
comprehensive cybersecurity program and framework that considers
potential cyber threats that impact the submitting entity's
organization, and protects the confidentiality, integrity, and
availability requirements of its systems and information.
The submitting entity has implemented and maintains a
written
[[Page 68268]]
enterprise cybersecurity policy or policies approved by the submitting
entity's senior management or board of directors, and the submitting
entity's cybersecurity framework is in alignment with standard industry
best practices and guidelines.\12\
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\12\ Examples of recognized frameworks, guidelines and standards
that FICC believes are adequate include the Financial Services
Sector Coordinating Council Cybersecurity Profile, the National
Institute of Standards and Technology Cybersecurity Framework
(``NIST CSF''), International Organization for Standardization
(``ISO'') standard 27001/27002 (``ISO 27001''), Federal Financial
Institutions Examination Council (``FFIEC'') Cybersecurity
Assessment Tool, Critical Security Controls Top 20, and Control
Objectives for Information and Related Technologies. FICC would
identify recognized frameworks, guidelines and standards in the form
of Cybersecurity Confirmation and in an Important Notice that FICC
would issue from time to time. FICC would also consider accepting
other standards upon request. Notice, supra note 3, at 58195.
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If the submitting entity uses a third party service
provider or service bureau(s) to connect or transact business or to
manage the connection with FICC, the submitting entity has an
appropriate program to evaluate the cyber risks and impact of these
third parties and to review the third party assurance reports.
The submitting entity's cybersecurity program and
framework protects the segment of its system that connects to and/or
interacts with FICC.
The submitting entity has in place an established process
to remediate cyber issues identified to meet its regulatory and/or
statutory requirements.
The submitting entity periodically updates the risk
processes of its cybersecurity program and framework based on a risk
assessment or changes to technology, business, threat ecosystem, and/or
regulatory environment.
The submitting entity's cybersecurity program and
framework has been reviewed by one of the following: (1) The submitting
entity, if it has filed and maintains a current Certification of
Compliance with the Superintendent of the New York State Department of
Financial Services confirming compliance with its Cybersecurity
Requirements for Financial Services Companies; \13\ (2) a regulator who
assesses the submitting entity's cybersecurity program and framework
against an industry cybersecurity framework or industry standard,
including those that are listed on the Cybersecurity Confirmation form
and in an Important Notice that is issued by FICC from time to time;
\14\ (3) an independent external entity with cybersecurity domain
expertise in relevant industry standards and practices, including those
that are listed on the Cybersecurity Confirmation form and in an
Important Notice that is issued by FICC from time to time; \15\ or (4)
an independent internal audit function reporting directly to the
submitting entity's board of directors or designated board of directors
committee, such that the findings of that review are shared with these
governance bodies.
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\13\ 23 N.Y. Comp. Codes R. & Regs. tit. 23, Sec. 500 et seq.
(2017). FICC states that this regulation requires entities to
confirm that they have comprehensive cybersecurity programs as
described in the regulation, and FICC believes this regime is
sufficient to meet the objectives of the proposed Cybersecurity
Confirmation. Notice, supra note 3, at 58196.
\14\ FICC states that current industry cybersecurity frameworks
and industry standards could include, for example, the Office of the
Comptroller of the Currency or the FFIEC Cybersecurity Assessment
Tool. FICC would identify acceptable industry cybersecurity
frameworks and standards in the Cybersecurity Confirmation form and
in an Important Notice that FICC would issue from time to time. FICC
would also consider accepting other industry cybersecurity
frameworks and standards upon request. Notice, supra note 3, at
58196.
\15\ FICC states that a third party with cybersecurity domain
expertise is one that follows and understands applicable industry
standards, practices, and regulations, such as ISO 27001
certification or NIST CSF assessment. FICC would identify acceptable
industry standards and practices in the Cybersecurity Confirmation
form and in an Important Notice that FICC would issue from time to
time. FICC would also consider accepting other industry standards
and practices upon request. Notice, supra note 3, at 58196.
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FICC states that it designed the representations in the
Cybersecurity Confirmation to provide information on how each
submitting entity manages cybersecurity with respect to its
connectivity to FICC.\16\ FICC believes that by requiring these
representations from members and applicants for membership, the
proposed Cybersecurity Confirmation would provide useful information
designed to enable FICC to make informed decisions about risks or
threats, perform additional monitoring, target potential
vulnerabilities, and otherwise protect the FICC network.\17\
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\16\ Notice, supra note 3, at 58196.
\17\ Id.
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2. Initial and Ongoing Membership Requirement
FICC proposes to require new applicants for FICC membership to
submit a Cybersecurity Confirmation as part of their application
materials. FICC also proposes to require all FICC members to submit a
Cybersecurity Confirmation at least every two years. With respect to
the requirement to submit a Cybersecurity Confirmation at least every
two years, FICC would provide all members with notice of the date on
which the Cybersecurity Confirmation would be due no later than 180
calendar days prior to the due date.
C. Implementation Timeframe
The proposed rule change would be effective upon Commission
approval. New applicants for FICC membership would be required to
submit a Cybersecurity Confirmation as part of their application
materials. The requirement to submit a Cybersecurity Confirmation would
also apply to applicants whose applications are pending with FICC at
the time the Commission approves the proposed rule change. For existing
FICC members, FICC would provide notice of the due date to submit a
Cybersecurity Confirmation, not later than 180 days prior to the due
date. Finally, FICC would provide such notice to its members at least
every two years going forward.
III. Discussion and Commission Findings
Section 19(b)(2)(C) of the Act \18\ 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 rules and regulations thereunder applicable
to such organization. After carefully considering the proposed rule
change, the Commission finds that the proposed rule change is
consistent with the requirements of the Act and the rules and
regulations thereunder applicable to FICC. In particular, the
Commission finds that the proposed rule change is consistent with
Section 17A(b)(3)(F) of the Act,\19\ and Rules 17Ad-22(e)(17)(i) and
(e)(17)(ii) promulgated under the Act,\20\ for the reasons described
below.
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\18\ 15 U.S.C. 78s(b)(2)(C).
\19\ 15 U.S.C. 78q-1(b)(3)(F).
\20\ 17 CFR 240.17Ad-22(e)(17)(i) and (e)(17)(ii).
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A. Consistency With Section 17A(b)(3)(F) of the Act
Section 17A(b)(3)(F) of the Act requires that the rules of a
clearing agency be designed to, among other things, promote the prompt
and accurate clearance and settlement of securities transactions and
assure the safeguarding of securities and funds which are in the
custody or control of the clearing agency or for which it is
responsible.\21\
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\21\ 15 U.S.C. 78q-1(b)(3)(F).
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As described above, FICC proposes to require its members and
applicants for membership to submit a Cybersecurity Confirmation,
confirming the existence
[[Page 68269]]
and nature of their cybersecurity programs. The Cybersecurity
Confirmations should provide FICC with useful information regarding the
cybersecurity programs of the submitting entities. By conditioning an
entity's connectivity to FICC via the SMART network or other means on
the submission of a Cybersecurity Confirmation, FICC should be better
enabled to reduce the cyber risks of electronically connecting to
entities that have not confirmed the existence and nature of their
cybersecurity programs. Accordingly, the proposed Cybersecurity
Confirmation requirement should provide FICC with information to better
identify its exposure to cyber risks and to take steps to mitigate
those risks.
If not adequately addressed, the risk of cyberattacks and other
cyber vulnerabilities could affect FICC's network and FICC's ability to
clear and settle securities transactions, or to safeguard the
securities and funds which are in FICC's custody or control, or for
which it is responsible. The proposed Cybersecurity Confirmation
requirement is a tool designed to address those risks as described
above. Therefore, the Commission finds the proposed Cybersecurity
Confirmation requirement would promote the prompt and accurate
clearance and settlement of securities transactions and assure the
safeguarding of securities and funds which are in the custody or
control of FICC or for which it is responsible, consistent with the
requirements of Section 17A(b)(3)(F) of the Act.\22\
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\22\ Id.
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B. Consistency With Rule 17Ad-22(e)(17)(i) Under the Act
Rule 17Ad-22(e)(17)(i) under the Act requires that each covered
clearing agency establish, implement, maintain and enforce written
policies and procedures reasonably designed to manage the covered
clearing agency's operational risks by identifying the plausible
sources of operational risk, both internal and external, and mitigating
their impact through the use of appropriate systems, policies,
procedures, and controls.\23\ FICC's operational risks include
protecting its electronic systems from cyber risks.
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\23\ 17 CFR 240.17Ad-22(e)(17)(i).
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As described above, entities connect electronically to FICC via the
SMART network or other means. The proposed Cybersecurity Confirmation
requirement should reduce cyber risks to FICC by requiring members and
applicants for membership to confirm that they have defined and
maintain cybersecurity programs and frameworks that meet standard
industry best practices and guidelines. The representations in each
submitting entity's Cybersecurity Confirmation would provide
information that should help FICC to mitigate its exposure to cyber
risks, and thereby decrease the operational risks presented to FICC by
its connections to such entities. Thus, the proposed Cybersecurity
Confirmations should enable FICC to better identify potential sources
of external operational risks and mitigate the possible impacts of
those risks. Because the proposed changes would help FICC identify and
mitigate plausible sources of external operational risk, the Commission
finds the proposed changes are consistent with the requirements of Rule
17Ad-22(e)(17)(i) under the Act.\24\
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\24\ Id.
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C. Consistency With Rule 17Ad-22(e)(17)(ii) Under the Act
Rule 17Ad-22(e)(17)(ii) under the Act requires that each covered
clearing agency establish, implement, maintain and enforce written
policies and procedures reasonably designed to manage the covered
clearing agency's operational risks by ensuring, in part, that systems
have a high degree of security, resiliency, and operational
reliability.\25\ As noted above, FICC's operational risks include
protecting its electronic systems from cyber risks.
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\25\ 17 CFR 240.17Ad-22(e)(17)(ii).
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Although FICC believes that its members and applicants for
membership may currently maintain robust cybersecurity programs, FICC
currently does not require those entities to represent that they
maintain a cybersecurity program as a condition for connecting to FICC
via the SMART network or other means. FICC designed the proposed
Cybersecurity Confirmation requirement to reduce cyber risks by
requiring its members and applicants for membership to confirm that
they have defined and maintain cybersecurity programs and frameworks
that meet standard industry best practices and guidelines. The
representations in each submitting entity's Cybersecurity Confirmation
would provide more security for FICC's SMART network and other systems
by providing FICC with information designed to help manage its cyber-
related operational risks, which in turn, would enable FICC to take
steps necessary to strengthen the security of its network to mitigate
those risks. Since the proposal would enhance FICC's ability to ensure
that its systems have a high degree of security, resiliency, and
operational reliability, the Commission finds the proposed changes are
consistent with the requirements of Rule 17Ad-22(e)(17)(ii) under the
Act.\26\
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\26\ Id.
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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 Act
and, in particular, with the requirements of Section 17A of the Act
\27\ and the rules and regulations promulgated thereunder.
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\27\ 15 U.S.C. 78q-1.
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It is therefore ordered, pursuant to Section 19(b)(2) of the Act
\28\ that proposed rule change SR-FICC-2019-005, be, and hereby is,
APPROVED.\29\
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\28\ 15 U.S.C. 78s(b)(2).
\29\ In approving the proposed rule change, the Commission
considered the proposals' 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.\30\
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\30\ 17 CFR 200.30-3(a)(12).
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Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2019-26844 Filed 12-12-19; 8:45 am]
BILLING CODE 8011-01-P