Self-Regulatory Organizations; the Options Clearing Corporation; Order Approving Proposed Rule Change Related to Proposed Changes to the Options Clearing Corporation's Rules, Clearing Fund Methodology Policy, and Clearing Fund and Stress Testing Methodology, 68985-68989 [2019-27081]
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Federal Register / Vol. 84, No. 242 / Tuesday, December 17, 2019 / Notices
securities exchange under the Exchange
Act and having its principal place of
business at 101 Arch Street, St. 610,
Boston, Massachusetts 02110.
• [Chicago Board Options Exchange,
Incorporated. (‘‘CBOE’’)]Cboe Exchange,
Inc., registered as a national securities
exchange under the Exchange Act and
having its principal place of business at
400 South LaSalle Street, Chicago,
Illinois 60605.
• [C2 Options Exchange, Incorporated
(‘‘C2’’)]Cboe C2 Exchange, Inc.,
registered as a national securities
exchange under the Exchange Act and
having its principal place of business at
400 South LaSalle Street, Chicago,
Illinois 60605.
• [EDGX Exchange, Inc.
(‘‘EDGX’’)]Cboe EDGX Exchange, Inc.,
registered as a national securities
exchange under the Exchange Act and
having its principal place of business at
[8050 Marshall Dr., Suite 120, Lenexa,
Kansas 66214]400 South LaSalle Street,
Chicago, Illinois 60605.
• [International Securities Exchange
LLC (‘‘ISE’’)]Nasdaq ISE, LLC, registered
as a national securities exchange under
the Exchange Act and having its
principal place of business at [60 Broad
Street, New York, New York 10004]One
Liberty Plaza, 50th Floor, New York,
New York 10006.
• [ISE Mercury, LLC (‘‘ISE
Mercury’’)]Nasdaq MRX, LLC, registered
as a national securities exchange under
the Exchange Act and having its
principal place of business at [60 Broad
Street, New York, New York 10004]One
Liberty Plaza, 50th Floor, New York,
New York 10006.
• Miami International Securities
Exchange, LLC (‘‘MIAX’’), registered as
a national securities exchange under the
Exchange Act and having its principal
place of business at 7 Roszel Road, Fifth
Floor, Princeton, New Jersey 08540.
• MIAX Emerald, LLC (‘‘MIAX
Emerald’’), registered as a national
securities exchange under the Exchange
Act and having its principal place of
business at 7 Roszel Road, Fifth Floor,
Princeton, New Jersey 08540.
• MIAX PEARL, LLC (‘‘MIAX
PEARL’’), registered as a national
securities exchange under the Exchange
Act and having its principal place of
business at 7 Roszel Road, Fifth Floor,
Princeton, New Jersey 08540.
• The [NASDAQ]Nasdaq Stock
Market LLC, registered as a national
securities exchange under the Exchange
Act and having its principal place of
business at One Liberty Plaza, 50th
Floor, New York, New York 10006.
• [NASDAQ OMX BX, Inc.,
(‘‘BX’’)]Nasdaq BX, Inc., registered as a
national securities exchange under the
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Exchange Act and having its principal
place of business at One Liberty Plaza,
50th Floor, New York, New York 10006.
• The Options Clearing Corporation
(‘‘OCC’’), registered as a clearing agency
under the Exchange Act and having its
principal place of business at [440
South LaSalle Street, Chicago, Illinois
60605]125 South Franklin Street, Suite
1200, Chicago, Illinois 60606.
• [Pacific Exchange, Inc.
(‘‘PCX’’)]NYSE Arca, Inc., registered as
a national securities exchange under the
Exchange Act and having its principal
place of business at [301 Pine Street,
San Francisco, California 94104]11 Wall
Street, New York, NY 10005.
• [Philadelphia Stock Exchange, Inc.
(‘‘PHLX’’)]Nasdaq PHLX LLC, registered
as a national securities exchange under
the Exchange Act and having its
principal place of business at [1900
Market Street, Philadelphia,
Pennsylvania 19103]FMC Tower, Level
8, 2929 Walnut Street, Philadelphia,
Pennsylvania 19104.
• [Topaz Exchange, LLC
(‘‘Topaz’’)]Nasdaq GEMX, LLC,
registered as a national securities
exchange under the Exchange Act and
having its principal place of business at
[60 Broad Street, New York, New York
10004]One Liberty Plaza, 50th Floor,
New York, New York 10006.
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[FR Doc. 2019–26816 Filed 12–16–19; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–87717; File No. SR–OCC–
2019–009]
and stress testing rules and
methodology.3 The Proposed Rule
Change was published for public
comment in the Federal Register on
October 29, 2019.4 The Commission has
received no comments regarding the
Proposed Rule Change.5 This order
approves the Proposed Rule Change.
II. Background 6
As noted above, OCC proposes to
revise its Clearing Fund and stress
testing rules and methodology.
Specifically, OCC proposes to: (1)
Incorporate a new set of stress test
scenarios to be used in the monthly
sizing of OCC’s Clearing Fund that are
designed to capture the risks of extreme
moves in individual or small subsets of
securities; (2) revise OCC’s stress testing
methodology for modeling certain
volatility index futures; (3) modify
OCC’s methodology for allocating
Clearing Fund contribution
requirements to standardize the margin
risk component of the allocation
formula for all Clearing Members; and
(4) adopt an additional threshold for
notifying senior management of intraday margin calls based on certain stress
test results. OCC also proposes to
correct certain rules concerning OCC’s
cooling-off period and replenishment/
assessment powers.7
A. Sizing Stress Test Scenarios
On a monthly basis, OCC establishes
the size of its Clearing Fund at the level
it believes is necessary to maintain
sufficient financial resources to cover
losses arising from the default of the two
Clearing Member Groups that would
3 See
Notice of Filing infra note 4, at 84 FR 57911.
Exchange Act Release No. 87386 (Oct.
23, 2019), 84 FR 57911 (Oct. 29, 2019) (SR–OCC–
2019–009) (‘‘Notice of Filing’’). OCC also filed a
related advance notice (SR–OCC–2019–806)
(‘‘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 November 12, 2019.
Securities Exchange Act Release No. 87475 (Nov. 6,
2019), 84 FR 61120 (Nov. 12, 2019) (SR–OCC–2019–
806).
5 Since the proposal contained in the Proposed
Rule Change was also filed as an advance notice,
all public comments received on the proposal are
considered regardless of whether the comments are
submitted on the Proposed Rule Change or Advance
Notice.
6 Capitalized terms used but not defined herein
have the meanings specified in OCC’s Rules and ByLaws, available at https://www.theocc.com/about/
publications/bylaws.jsp.
7 Additionally, OCC proposes clarifying and
conforming changes to its Rules, Clearing Fund
Methodology Policy (‘‘Policy’’), and Stress Testing
and Clearing Fund Methodology Description
(‘‘Methodology Description’’).
4 Securities
Self-Regulatory Organizations; the
Options Clearing Corporation; Order
Approving Proposed Rule Change
Related to Proposed Changes to the
Options Clearing Corporation’s Rules,
Clearing Fund Methodology Policy,
and Clearing Fund and Stress Testing
Methodology
December 11, 2019.
I. Introduction
On October 10, 2019, the Options
Clearing Corporation (‘‘OCC’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change SR–OCC–2019–
009 (‘‘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
make changes to OCC’s Clearing Fund
1 15
2 17
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CFR 240.19b–4.
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potentially cause the largest aggregate
credit exposure to OCC under certain
stress scenarios.8 OCC determines the
size of its Clearing Fund each month
through an approach based on broadbased market and systemic shocks
(‘‘Systemic Scenarios’’).9 OCC proposes
to incorporate an additional set of stress
test scenarios to be used in the monthly
sizing of OCC’s Clearing Fund that are
designed to capture the risks of extreme
moves in individual or small subsets of
securities (‘‘Idiosyncratic Scenarios’’).
The Idiosyncratic Scenarios would be in
addition to the existing Systemic
Scenarios. Because OCC’s monthly
Clearing Fund sizing process is
designed to cover OCC’s largest
aggregate stress test exposures, the
expansion of the set of Clearing Fund
sizing stress tests could not result in a
smaller Clearing Fund than would be
the case without such an expansion.
In constructing the Idiosyncratic
Scenarios, OCC would shock each
single-name equity (i.e., excluding
exchange-traded funds, exchange-traded
notes, indices, and non-equity
products). OCC would evaluate the
effects of such shocks on every Clearing
Member Group’s portfolios. Within each
Clearing Member Group’s portfolio,
OCC would identify the four singlename equities for which such shocks
would result in the largest losses. OCC
would then identify the two Clearing
Member Groups with the largest
aggregate losses. The combined losses of
the two identified Clearing Member
Groups would represent the loss that
OCC would seek to cover in its monthly
Clearing Fund sizing process. OCC
believes that implementing the
proposed Idiosyncratic Scenarios would
enhance OCC’s stress testing
methodology and overall resiliency by
providing a more comprehensive suite
of sizing stress tests to ensure that OCC
maintains an appropriate level of
financial resources to cover its credit
exposures under scenarios addressing
both systemic market risks and
idiosyncratic risks.10
B. Volatility Index Futures
Under OCC’s current stress testing
methodology, prices shocks for futures
based on the Cboe Volatility Index
8 See
Notice of Filing, 84 FR at 57912.
Notice of Filing, 84 FR at 57913. See also,
Securities Exchange Act Release No. 83735 (Jul. 27,
2018), 83 FR 37855, 37857 (Aug. 2, 2019) (SR–OCC–
2018–008) (describing OCC’s Clearing Fund sizing
stress test scenarios as an approach based on
hypothetical stress scenarios that assume shocks to
the Cboe S&P 500 Index (‘‘SPX’’) associated with a
1-in-80-year market event).
10 See Notice of Filing, 84 FR at 57913.
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9 See
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(‘‘VIX’’) 11 are equivalent to a price
shock for the underlying. Because the
VIX has no term structure, this process
produces a uniform shock across
expirations of the VIX futures contracts.
Futures contracts for different
expirations, however, generally trade at
different prices reflecting the differing
future price expectations of the
underlying asset.12 OCC believes that
applying a uniform shock across
expirations is unrealistic, and that it
would lead to an overestimation of VIX
futures price shocks, particularly in
market decline scenarios.13 As noted
above, OCC proposes to revise its stress
testing methodology for modeling
certain volatility index futures.
Specifically, the proposed change
would produce differing price shocks
for VIX futures across the term
structure. The proposed methodology
would be based on SPX volatility shocks
across different expirations, as opposed
to the current methodology’s reliance on
a single shock to the VIX. OCC believes
that implementation of the proposed
methodology would improve pricing for
VIX futures as well as VIX options.14
C. Clearing Fund Allocation
OCC allocates Clearing Fund
contribution requirements to individual
Clearing Members, in part, based on
each Clearing Member’s proportionate
share of risk margin, which OCC refers
to as ‘‘total risk.’’ 15 The majority of
Clearing Member margin requirements
are based on OCC’s System for
Theoretical Analysis and Numerical
Simulations (‘‘STANS’’), which is OCC’s
proprietary risk management system.
The margin requirement for certain
Clearing Members’ accounts, however,
is calculated using the Standard
Portfolio Analysis of Risk Margin
Calculation System (‘‘SPAN’’), which
reflects customer gross margining.16
11 The VIX is an index designed to measure the
30-day expected volatility of the SPX.
12 When there is a large shock to the VIX it has
consistently been observed that the change in price
of near-term VIX future contracts is much larger
than for further out expirations. See Notice of
Filing, 84 FR at 57913, n. 11.
13 See Notice of Filing, 84 FR at 57913.
14 See Notice of Filing, 84 FR at 57914. OCC uses
VIX futures to calculate theoretical values for VIX
options.
15 Currently, OCC uses the following weighting in
its allocation of clearing fund requirements: 70
percent total risk, 15 percent open interest, and 15
percent volume. See Securities Exchange Act
Release No. 83735 (Jul. 27, 2018), 83 FR 37855,
37863 (Aug. 2, 2019) (SR–OCC–2018–008).
16 See Notice of Filing, 84 FR at 57914, n. 16
(stating that ‘‘OCC calculates margin requirements
for segregated futures accounts using both SPAN on
a gross basis and STANS on a net basis, and if at
any time OCC staff observes a segregated futures
account where initial margin calculated pursuant to
STANS on a net basis exceeds the initial margin
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OCC proposes to define ‘‘total risk’’ as
based on the same margin model for all
Clearing Members.17 OCC believes it is
more appropriate to use the same
margin risk measurement for all
Clearing Members when allocating
Clearing Fund contribution
requirements to allow for a more
equitable comparison across all
accounts.18
D. Margin Call Notification
On a daily basis, OCC evaluates the
sufficiency of its financial resources
based on OCC’s potential exposure to
Clearing Member Groups under certain
stress test scenarios (‘‘Sufficiency Stress
Tests’’). Based on the results of the
Sufficiency Stress Tests, OCC may call
for additional collateral to ensure that it
maintains sufficient financial resources
to guard against potential losses. For
example, OCC is authorized to make an
intra-day margin call against a Clearing
Member Group whose Sufficiency Stress
Test exposures breach a pre-determined
threshold. Currently, OCC’s rules
require that written notification of such
intra-day margin calls in excess of $500
million be provided to OCC’s Executive
Chairman, Chief Executive Officer, and
Chief Operating Officer (‘‘Office of the
CEO’’). OCC proposes to revise its rules
to require that written notification of
stress test-related intra-day margin calls
also be sent to the Office of the CEO
when a stress test-related intra-day
margin call would exceed 75 percent of
the Clearing Member’s excess net
capital. OCC believes that this
additional notification requirement is
appropriate because it would allow
OCC’s senior management to be
informed as soon as practicable of, and
to subsequently monitor, circumstances
where a margin call may strain a
particular Clearing Member’s ability to
meet such requirements based on its
financial condition or the amount of
collateral it has available to pledge
when certain pre-identified thresholds
have been exceeded.19
E. Cooling-Off Period
In 2018, OCC implemented a set of
recovery tools, including revisions to
OCC’s authority to assess its Clearing
Members for funds to replenish OCC’s
calculated pursuant to SPAN on a gross basis, OCC
collateralizes this risk exposure by applying an
additional margin charge in the amount of such
difference to the account’’ (citation omitted)).
17 Specifically, OCC proposes to use STANS plus
certain add-on charges as the basis for determining
each Clearing Member’s proportionate share of total
risk.
18 See Notice of Filing, 84 FR at 57914.
19 See Notice of Filing, 84 FR at 57914.
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Clearing Fund.20 For example, OCC
implemented a ‘‘cooling-off period’’
during which its authority to levy such
assessments is capped, which provides
certainty to Clearing Members regarding
their potential obligations to OCC. In
proposing such revisions, OCC intended
that the cooling-off period would be
triggered by any proportionate Clearing
Fund charges to Clearing Members
related to the default of a Clearing
Member.21 OCC’s current rules,
however, do not provide for a coolingoff period based on proportionate
Clearing Fund charges arising out of two
specific sets of circumstances: (1) In
connection with protective transactions
effected for the account of OCC
pursuant to Chapter XI of OCC’s Rules
and (2) as a result of a failure of any
Clearing Member to make any other
required payment or render any other
required performance (as provided in
clauses (v) and (vi) of OCC Rule
1006(a)). OCC proposes to revise its
rules such that any proportionate
Clearing Fund charges to Clearing
Members related to the default of a
Clearing Member, including the two
listed above, would trigger a cooling-off
period.
III. Discussion and Commission
Findings
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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.22 After carefully
considering the Proposed Rule Change,
the Commission finds that 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 23 and Rules 17Ad–
22(e)(2) and (4) thereunder.24
20 See Securities Exchange Act Release No. 83916
(Aug. 23, 2018), 83 FR 44076 (Aug. 29, 2018) (SR–
OCC–2017–020).
21 See Notice of Filing, 84 FR at 57915. Such
triggers include the assessments arising out of a
Clearing Member’s failure to meet its obligations
regarding confirmed trades, exercised or assigned
contracts, stock loan transactions, or the liquidation
of a Clearing Member’s open positions. See id. at
n. 22.
22 15 U.S.C. 78s(b)(2)(C).
23 15 U.S.C. 78q–1(b)(3)(F).
24 17 CFR 240.17Ad–22(e)(2) and 17 CFR
240.17Ad–22(e)(4).
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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, among other things, that
the rules of a clearing agency be
designed to (i) promote the prompt and
accurate clearance and settlement of
securities transactions, and to the extent
applicable, derivatives agreements,
contracts, and transactions; (ii) assure
the safeguarding of securities and funds
which are in the custody or control of
the clearing agency or for which it is
responsible; and (iii), in general, protect
investors and promote the public
interest.25 Based on its review of the
record, the Commission believes that
the proposed changes are designed to
promote prompt and accurate clearance
and settlement, assure the safeguarding
of securities and funds which are in
OCC’s custody or control or for which
OCC is responsible, and, in general,
protect investors and promote the
public interest for the reasons set forth
below.
The Commission believes that the
proposed changes to OCC’s stress testing
methodology are designed to promote
the prompt and accurate clearance and
settlement of securities transactions. As
an initial matter, OCC is the only
clearing agency for standardized U.S.
securities options listed on
Commission-registered national
securities exchanges (‘‘listed
options’’).26 OCC provides central
counterparty services for the listedoptions markets.27 OCC’s role as the sole
CCP for all listed options contracts in
the U.S. makes it an integral part of the
national system for clearance and
settlement.28 As described above, OCC
proposes to expand the suite of stress
tests it uses to size the Clearing Fund
each month, and to revise OCC’s
estimation of VIX futures prices for
stress testing. The introduction of the
Idiosyncratic Scenarios to the monthly
sizing of OCC’s Clearing Fund would be
in addition to the Systemic Scenarios
OCC already uses to size its Clearing
Fund and would help OCC address risks
not currently contemplated by OCC’s
Systemic Scenarios, which in turn
should enhance OCC’s ability to
accurately and appropriately size its
Clearing Fund. Additionally, OCC
proposes to revise its process for
shocking VIX futures prices to reflect
the actual term structure dynamics of
such futures. OCC’s current use of a
25 15
U.S.C. 78q–1(b)(3)(F).
Securities Exchange Act Release No. 85121
(Feb. 13, 2019), 84 FR 5157 (Feb. 20, 2019) (File No.
SR–OCC–2015–02).
27 See id., 84 FR at 5158.
28 See id.
26 See
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uniform shock for VIX futures contracts,
regardless of tenure, is not consistent
with OCC’s observation that futures
contracts with different expirations
generally trade at different prices
reflecting the differing future price
expectations of the underlying asset. By
enhancing its methodology for modeling
price shocks for VIX futures, OCC
should be able to produce more
appropriate VIX futures price shocks in
its stress scenarios, which in turn also
should enhance OCC’s ability to
accurately and appropriately size its
Clearing Fund. OCC relies on the
resources in its Clearing Fund to
manage the potential losses arising out
of the default of a Clearing Member
under extreme but plausible market
conditions. Strengthening the
methodology that OCC uses to manage
its financial resources by enhancing its
ability to accurately and appropriately
size the Clearing Fund, therefore, would
enhance OCC’s ability to manage
Clearing Member defaults, which, in
turn, facilitates the continued clearance
and settlement of listed options. The
Commission believes, therefore, that the
proposed changes to OCC’s stress testing
methodology, taken together, are
consistent with the promotion of
prompt and accurate clearance and
settlement of derivatives contracts.
The Commission believes that the
proposed changes regarding notice of
intra-day margin requirements and
allocation of Clearing Fund
requirements are consistent with
assuring the safeguarding of securities
and funds. Currently, OCC notifies its
Office of the CEO when intra-day
margin calls generated in response to
OCC’s daily stress tests are large in
absolute terms (i.e., in excess of $500
million). OCC proposes to also notify its
Office of the CEO when such margin
calls are large relative to the Clearing
Member against which they are made
(i.e., in excess of 75 percent of the
Clearing Member’s excess net capital).
The Commission believes that such
notification would provide OCC’s senior
management with additional risk
management information, which in turn
could be used to inform critical
decisions related to margin or other
protective measures that could help
OCC avoid drawing on resources from
surviving Clearing Members to manage
a Clearing Member default. In the
Commission’s view, such measures
would be consistent with assuring the
safeguarding of securities and funds
which are in OCC’s custody or control
or for which OCC is responsible.
Additionally, OCC proposes to revise
its method of allocating Clearing Fund
contribution requirements across
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Clearing Members. OCC proposes to
redefine the ‘‘total risk’’ component of
its Clearing Fund allocation formula
such that it would rely on the same
underlying model for all Clearing
Members when calculating total risk (as
opposed to using different models for
different Clearing Members depending
on their cleared positions). The
proposed change would not alter the
allocation weighting, but, in the
Commission’s view, it would provide a
more consistent metric by which to
assess risks across Clearing Members
and determine how much risk each
Clearing Member should bear in terms
of Clearing Fund requirements.29 The
Commission believes that these changes
as well are consistent with assuring the
safeguarding of securities and funds
which are in OCC’s custody or control
or for which OCC is responsible.
Finally, the Commission believes that
the proposed expansion of triggers for
the cooling-off period is designed, in
general, to protect investors and
promote the public interest. The
Commission continues to believe that
the cooling-off period provides certainty
and predictability regarding Clearing
Members’ maximum liability for
Clearing Fund contributions.30
Currently, however, the cooling-off
period would be triggered by some, but
not all proportionate Clearing Fund
charges to Clearing Members arising out
of a Clearing Member’s failure to meet
certain obligations under OCC’s rules.
OCC proposes to expand the set of
events that would trigger the cooling-off
period to include certain protective
transactions and the failure of a Clearing
Member to meets its obligations under
certain of OCC’s rules. The two events
to be added as cooling-off period
triggers are similar to the current
triggers in that they pertain to
proportionate Clearing Fund charges
designed to manage the failure of a
Clearing Member to meet its obligations
to OCC. The Commission believes that
including these two additional events as
cooling-off period triggers would
provide Clearing Members with
additional certainty and predictability
regarding their potential maximum
liability for Clearing Fund
contributions, which in turn is
consistent with the protection investors
and promotion of the public interest.
The Commission believes, therefore,
that the Proposed Rule Change is
29 While the proposed change would not affect
the total size of the Clearing Fund, it would result
in changes to Clearing Members’ proportionate
share of the Clearing Fund.
30 See Securities Exchange Act Release No. 83916
(Aug. 23, 2018), 83 FR 44076, 44082 (Aug. 29, 2018)
(SR–OCC–2017–020).
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consistent with the requirements of
Section 17A(b)(3)(F) of the Exchange
Act.31
B. Consistency With Rule 17Ad–22(e)(2)
Under the Exchange Act
Rule 17Ad–22(e)(2)(v) under the
Exchange Act requires that a covered
clearing agency establish, implement,
maintain, and enforce written policies
and procedures reasonably designed to
provide for governance arrangements
that, among other things, specify clear
and direct lines of responsibility.32
As described above, OCC proposes to
add a new internal reporting
requirement regarding certain intra-day
margin calls. OCC may call for
additional margin from Clearing
Members based on the results of its
Sufficiency Stress Tests. In addition to
notifying its Office of the CEO when
such margin calls are large in absolute
terms (i.e., in excess of $500 million),
OCC now proposes to also notify to its
Office of the CEO when such margin
calls are large relative to the Clearing
Member against which they are made
(i.e., in excess of 75 percent of the
Clearing Member’s excess net capital).
The Commission believes that such
notification would inform OCC’s senior
management, who could then monitor
circumstances as appropriate, when an
intra-day margin call could strain the
resources of a particular Clearing
Member based on its financial
condition. Accordingly, the Commission
believes that the adoption of such a
notification requirement is consistent
with Rule 17Ad–22(e)(2)(v) under the
Exchange Act.33
C. Consistency With Rule 17Ad–22(e)(4)
Under the Exchange Act
Rule 17Ad–22(e)(4) under the
Exchange Act requires, in part, that a
covered clearing agency establish,
implement, maintain, and enforce
written policies and procedures
reasonably designed to effectively
identify, measure, monitor, and manage
its credit exposures to participants and
those arising from its payment, clearing,
and settlement processes.34 Based on its
review of the record, the Commission
believes that the proposed rule change
is consistent with Rule 17Ad–22(e)(4)
under the Exchange Act.
1. Stress Testing
Rules 17Ad–22(e)(4)(i) and (iii) under
the Exchange Act require that a covered
clearing agency’s policies and
31 15
U.S.C. 78q–1(b)(3)(F).
32 17 CFR 240.17Ad–22(e)(2)(v).
33 17 CFR 240.17Ad–22(e)(2)(v).
34 17 CFR 240.17Ad–22(e)(4).
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Fmt 4703
Sfmt 4703
procedures meet the requirements of
Rule 17Ad–22(e)(4) by maintaining
financial resources at the minimum to
enable OCC to cover a wide range of
foreseeable stress scenarios that include,
but are not limited to, the default of the
participant family that would
potentially cause the largest aggregate
credit exposure for OCC in extreme but
plausible market conditions.35 Further,
Rule 17Ad–22(e)(4)(vi) under the
Exchange Act requires that a covered
clearing agency’s policies and
procedures meet the requirements of
Rule 17Ad–22(e)(4) by testing the
sufficiency of a covered clearing
agency’s total financial resources
available to meet the minimum financial
resource requirements under Rules
17Ad–22(e)(4)(i) through (iii).36
As described above, OCC proposes to
expand the set of stress tests that it uses
to size the Clearing Fund by adding the
Idiosyncratic Scenarios to its current
suite of stress tests. The Idiosyncratic
Scenarios are designed to capture the
risk of extreme moves in individual
securities or small subsets of securities,
while the current Systemic Scenarios
are based on broad-based market and
systemic shocks. Consistent with the
general view that expanding the types of
scenarios that a clearing agency uses in
its monthly sizing process makes the
clearing agency’s risk management
robust to a broader range of shocks, the
Commission believes that OCC’s
proposal to add the Idiosyncratic
Scenarios to its suite of stress tests
would be a strengthening change—
meaning it would enhance OCC’s ability
to accurately and appropriately size its
Clearing Fund—that is consistent with
the requirements of Rules 17Ad–
22(e)(4)(i) and (iii) under the Exchange
Act.37
Additionally, OCC proposes to revise
its stress testing methodology to
produce differing price shocks for VIX
futures across the term structure. The
proposed methodology would be based
on SPX volatility shocks across different
expirations, as opposed to the current
methodology’s reliance on a single
shock to the VIX. As discussed above,
these changes would help OCC produce
VIX futures price shocks in its stress
scenarios that are consistent with OCC’s
observation that futures contracts with
different expirations generally trade at
different prices reflecting the differing
future price expectations of the
underlying asset, which in turn should
35 17 CFR 240.17Ad–22(e)(4)(i) and 17 CFR
240.17Ad–22(e)(4)(iii).
36 17 CFR 240.17Ad–22(e)(4)(vi).
37 17 CFR 240.17Ad–22(e)(4)(i) and 17 CFR
240.17Ad–22(e)(4)(iii).
E:\FR\FM\17DEN1.SGM
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Federal Register / Vol. 84, No. 242 / Tuesday, December 17, 2019 / Notices
enhance OCC’s ability to accurately and
appropriately size its Clearing Fund,
consistent with the requirements of Rule
17Ad–22(e)(4)(vi).
Accordingly, the Commission believes
that, taken together, OCC’s proposed
changes to its stress testing methodology
would be consistent with the
requirements of Rules 17Ad–22(e)(4)(i),
(iii), and (vi).38
2. Clearing Fund Allocation
jbell on DSKJLSW7X2PROD with NOTICES
As noted above, Rule 17Ad–22(e)(4)
under the Exchange Act generally
requires that a covered clearing agency
establish, implement, maintain, and
enforce written policies and procedures
reasonably designed to effectively
identify, measure, monitor, and manage
its credit exposures to participants and
those arising from its payment, clearing,
and settlement processes.39
OCC relies on the Clearing Fund as a
source of mutualized resources available
to manage losses arising out of a
Clearing Member’s default. OCC’s
method for allocating contributions to
the Clearing Fund among Clearing
Members is aligned primarily with the
credit risk posed by each Clearing
Member.40 OCC proposes to redefine the
margin risk component of its Clearing
Fund allocation formula such that it
would rely on the same underlying
model—STANS—for all Clearing
Members (as opposed to relying on
STANS for most Clearing Members and
SPAN for certain Clearing Members
with segregated futures accounts). The
proposed change would not change the
overall allocation weighting (i.e., margin
risk would still account for 70 percent
of the Clearing Fund allocation among
Clearing Members), but the Commission
believes it would provide a more
consistent metric by which to assess
margin risk across Clearing Members.
Accordingly, the Commission believes
that the proposed change is reasonably
designed to support the management of
OCC’s credit exposures to its
participants. The Commission believes,
therefore, that OCC’s proposed change
to its Clearing Fund allocation
methodology is consistent with the
requirements of Rule 17Ad–22(e)(4).41
38 17 CFR 240.17Ad–22(e)(4)(i); 17 CFR
240.17Ad–22(e)(4)(iii); and 17 CFR 240.17Ad–
22(e)(4)(vi).
39 17 CFR 240.17Ad–22(e)(4).
40 Clearing Fund allocations are based on a
weighting of 70 percent margin risk, what OCC
refers to as the ‘‘total risk’’ component of its
Clearing Fund allocation formula, with open
interest and cleared volume weighted at 15 percent
each.
41 17 CFR 240.17Ad–22(e)(4).
VerDate Sep<11>2014
18:15 Dec 16, 2019
Jkt 250001
3. Cooling-Off Period
Rule 17Ad–22(e)(4)(ix) under the
Exchange Act requires, in part, that a
covered clearing agency establish,
implement, maintain, and enforce
written policies and procedures
reasonably designed to describe its
process to replenish any financial
resources it may use following a default
or other event in which use of resources
is contemplated.42
As noted above, OCC’s current
recovery tools include a cooling-off
period, during which OCC’s authority to
assess Clearing Members for funds to
replenish OCC’s Clearing Fund is
limited. Recognizing the limit that such
a cooling-off period places on the
financial resources available to OCC, the
Commission continues to believe that
the cooling-off period provides certainty
and predictability regarding Clearing
Members’ maximum liability for
Clearing Fund contributions.43 OCC
proposes to expand the set of events that
would start the cooling-off period to
include proportionate Clearing Fund
charges to Clearing Members triggered
by certain protective transactions or the
failure of a Clearing Member to meet
certain obligations under OCC’s rules,
consistent with OCC’s original intention
with its prior filing. The two events to
be added as triggers for the cooling-off
period are similar to the current triggers
in that they pertain to amounts paid out
of the Clearing Fund to manage the
failure of a Clearing Member to meet its
obligations to OCC. Consistent with the
Commission’s statements regarding the
current formulation of the cooling-off
period, the Commission believes that
the proposed expansion is consistent
with OCC’s obligations to describe its
process to replenish any financial
resources it may use following a default
or other event in which use of resources
is contemplated as required under Rule
17Ad–22(e)(4)(ix).44
Accordingly, and for the reasons
stated above, the Commission believes
the changes proposed in the Proposed
Rule Change are consistent with Rule
17Ad–22(e)(4) under the Exchange
Act.45
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
42 17
CFR 240.17Ad–22(e)(4)(ix).
Securities Exchange Act Release No. 83916
(Aug. 23, 2018), 83 FR 44076, 44082 (Aug. 29, 2018)
(SR–OCC–2017–020).
44 17 CFR 240.17Ad–22(e)(4)(ix).
45 17 CFR 240.17Ad–22(e)(4).
43 See
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Fmt 4703
Sfmt 4703
68989
Section 17A of the Exchange Act 46 and
the rules and regulations thereunder.
It is therefore ordered, pursuant to
Section 19(b)(2) of the Exchange Act,47
that the Proposed Rule Change (SR–
OCC–2019–009) be, and hereby is,
approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.48
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2019–27081 Filed 12–16–19; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–87720; File No. SR–LCH
SA–2019–008]
Self-Regulatory Organizations; LCH
SA; Order Approving Rule Change
Relating to the Updated 2018 Version
of the Recovery Plan
December 11, 2019.
I. Introduction
On October 8, 2019, Banque Centrale
de Compensation, which conducts
business under the name LCH SA (‘‘LCH
SA’’), filed with the Securities and
Exchange Commission (‘‘Commission’’),
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder 2 a
proposed rule change (‘‘the ‘‘Proposed
Rule Change’’) to adopt an updated
recovery plan (the ‘‘RP’’). The proposed
rule change was published for comment
in the Federal Register on October 29,
2019.3 The Commission has not
received any comments on the proposed
rule change. For the reasons discussed
below, the Commission is approving the
proposed rule change.
II. Description of the Proposed Rule
Change
The purpose of LCH SA’s RP is to
maintain the continuity of critical
services in times of extreme stress and
to facilitate its recovery.4 Generally, the
RP identifies if and to what level LCH
SA’s services are critical for the market
46 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).
47 15 U.S.C. 78s(b)(2).
48 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. 34–87388
(October 23, 2019), 84 FR 57897 (October 29, 2019)
(SR–LCH SA–2018–008) (‘‘Notice’’).
4 The description herein is substantially
excerpted from the Notice, 84 FR 57897.
E:\FR\FM\17DEN1.SGM
17DEN1
Agencies
[Federal Register Volume 84, Number 242 (Tuesday, December 17, 2019)]
[Notices]
[Pages 68985-68989]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-27081]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-87717; File No. SR-OCC-2019-009]
Self-Regulatory Organizations; the Options Clearing Corporation;
Order Approving Proposed Rule Change Related to Proposed Changes to the
Options Clearing Corporation's Rules, Clearing Fund Methodology Policy,
and Clearing Fund and Stress Testing Methodology
December 11, 2019.
I. Introduction
On October 10, 2019, the Options Clearing Corporation (``OCC'')
filed with the Securities and Exchange Commission (``Commission'') the
proposed rule change SR-OCC-2019-009 (``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 make changes to
OCC's Clearing Fund and stress testing rules and methodology.\3\ The
Proposed Rule Change was published for public comment in the Federal
Register on October 29, 2019.\4\ The Commission has received no
comments regarding the Proposed Rule Change.\5\ This order approves the
Proposed Rule Change.
---------------------------------------------------------------------------
\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 57911.
\4\ Securities Exchange Act Release No. 87386 (Oct. 23, 2019),
84 FR 57911 (Oct. 29, 2019) (SR-OCC-2019-009) (``Notice of
Filing''). OCC also filed a related advance notice (SR-OCC-2019-806)
(``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 November 12, 2019. Securities Exchange Act
Release No. 87475 (Nov. 6, 2019), 84 FR 61120 (Nov. 12, 2019) (SR-
OCC-2019-806).
\5\ Since the proposal contained in the Proposed Rule Change was
also filed as an advance notice, all public comments received on the
proposal are considered regardless of whether the comments are
submitted on the Proposed Rule Change or Advance Notice.
---------------------------------------------------------------------------
II. Background 6
---------------------------------------------------------------------------
\6\ Capitalized terms used but not defined herein have the
meanings specified in OCC's Rules and By-Laws, available at https://www.theocc.com/about/publications/bylaws.jsp.
---------------------------------------------------------------------------
As noted above, OCC proposes to revise its Clearing Fund and stress
testing rules and methodology. Specifically, OCC proposes to: (1)
Incorporate a new set of stress test scenarios to be used in the
monthly sizing of OCC's Clearing Fund that are designed to capture the
risks of extreme moves in individual or small subsets of securities;
(2) revise OCC's stress testing methodology for modeling certain
volatility index futures; (3) modify OCC's methodology for allocating
Clearing Fund contribution requirements to standardize the margin risk
component of the allocation formula for all Clearing Members; and (4)
adopt an additional threshold for notifying senior management of intra-
day margin calls based on certain stress test results. OCC also
proposes to correct certain rules concerning OCC's cooling-off period
and replenishment/assessment powers.\7\
---------------------------------------------------------------------------
\7\ Additionally, OCC proposes clarifying and conforming changes
to its Rules, Clearing Fund Methodology Policy (``Policy''), and
Stress Testing and Clearing Fund Methodology Description
(``Methodology Description'').
---------------------------------------------------------------------------
A. Sizing Stress Test Scenarios
On a monthly basis, OCC establishes the size of its Clearing Fund
at the level it believes is necessary to maintain sufficient financial
resources to cover losses arising from the default of the two Clearing
Member Groups that would
[[Page 68986]]
potentially cause the largest aggregate credit exposure to OCC under
certain stress scenarios.\8\ OCC determines the size of its Clearing
Fund each month through an approach based on broad-based market and
systemic shocks (``Systemic Scenarios'').\9\ OCC proposes to
incorporate an additional set of stress test scenarios to be used in
the monthly sizing of OCC's Clearing Fund that are designed to capture
the risks of extreme moves in individual or small subsets of securities
(``Idiosyncratic Scenarios''). The Idiosyncratic Scenarios would be in
addition to the existing Systemic Scenarios. Because OCC's monthly
Clearing Fund sizing process is designed to cover OCC's largest
aggregate stress test exposures, the expansion of the set of Clearing
Fund sizing stress tests could not result in a smaller Clearing Fund
than would be the case without such an expansion.
---------------------------------------------------------------------------
\8\ See Notice of Filing, 84 FR at 57912.
\9\ See Notice of Filing, 84 FR at 57913. See also, Securities
Exchange Act Release No. 83735 (Jul. 27, 2018), 83 FR 37855, 37857
(Aug. 2, 2019) (SR-OCC-2018-008) (describing OCC's Clearing Fund
sizing stress test scenarios as an approach based on hypothetical
stress scenarios that assume shocks to the Cboe S&P 500 Index
(``SPX'') associated with a 1-in-80-year market event).
---------------------------------------------------------------------------
In constructing the Idiosyncratic Scenarios, OCC would shock each
single-name equity (i.e., excluding exchange-traded funds, exchange-
traded notes, indices, and non-equity products). OCC would evaluate the
effects of such shocks on every Clearing Member Group's portfolios.
Within each Clearing Member Group's portfolio, OCC would identify the
four single-name equities for which such shocks would result in the
largest losses. OCC would then identify the two Clearing Member Groups
with the largest aggregate losses. The combined losses of the two
identified Clearing Member Groups would represent the loss that OCC
would seek to cover in its monthly Clearing Fund sizing process. OCC
believes that implementing the proposed Idiosyncratic Scenarios would
enhance OCC's stress testing methodology and overall resiliency by
providing a more comprehensive suite of sizing stress tests to ensure
that OCC maintains an appropriate level of financial resources to cover
its credit exposures under scenarios addressing both systemic market
risks and idiosyncratic risks.\10\
---------------------------------------------------------------------------
\10\ See Notice of Filing, 84 FR at 57913.
---------------------------------------------------------------------------
B. Volatility Index Futures
Under OCC's current stress testing methodology, prices shocks for
futures based on the Cboe Volatility Index (``VIX'') \11\ are
equivalent to a price shock for the underlying. Because the VIX has no
term structure, this process produces a uniform shock across
expirations of the VIX futures contracts. Futures contracts for
different expirations, however, generally trade at different prices
reflecting the differing future price expectations of the underlying
asset.\12\ OCC believes that applying a uniform shock across
expirations is unrealistic, and that it would lead to an overestimation
of VIX futures price shocks, particularly in market decline
scenarios.\13\ As noted above, OCC proposes to revise its stress
testing methodology for modeling certain volatility index futures.
Specifically, the proposed change would produce differing price shocks
for VIX futures across the term structure. The proposed methodology
would be based on SPX volatility shocks across different expirations,
as opposed to the current methodology's reliance on a single shock to
the VIX. OCC believes that implementation of the proposed methodology
would improve pricing for VIX futures as well as VIX options.\14\
---------------------------------------------------------------------------
\11\ The VIX is an index designed to measure the 30-day expected
volatility of the SPX.
\12\ When there is a large shock to the VIX it has consistently
been observed that the change in price of near-term VIX future
contracts is much larger than for further out expirations. See
Notice of Filing, 84 FR at 57913, n. 11.
\13\ See Notice of Filing, 84 FR at 57913.
\14\ See Notice of Filing, 84 FR at 57914. OCC uses VIX futures
to calculate theoretical values for VIX options.
---------------------------------------------------------------------------
C. Clearing Fund Allocation
OCC allocates Clearing Fund contribution requirements to individual
Clearing Members, in part, based on each Clearing Member's
proportionate share of risk margin, which OCC refers to as ``total
risk.'' \15\ The majority of Clearing Member margin requirements are
based on OCC's System for Theoretical Analysis and Numerical
Simulations (``STANS''), which is OCC's proprietary risk management
system. The margin requirement for certain Clearing Members' accounts,
however, is calculated using the Standard Portfolio Analysis of Risk
Margin Calculation System (``SPAN''), which reflects customer gross
margining.\16\ OCC proposes to define ``total risk'' as based on the
same margin model for all Clearing Members.\17\ OCC believes it is more
appropriate to use the same margin risk measurement for all Clearing
Members when allocating Clearing Fund contribution requirements to
allow for a more equitable comparison across all accounts.\18\
---------------------------------------------------------------------------
\15\ Currently, OCC uses the following weighting in its
allocation of clearing fund requirements: 70 percent total risk, 15
percent open interest, and 15 percent volume. See Securities
Exchange Act Release No. 83735 (Jul. 27, 2018), 83 FR 37855, 37863
(Aug. 2, 2019) (SR-OCC-2018-008).
\16\ See Notice of Filing, 84 FR at 57914, n. 16 (stating that
``OCC calculates margin requirements for segregated futures accounts
using both SPAN on a gross basis and STANS on a net basis, and if at
any time OCC staff observes a segregated futures account where
initial margin calculated pursuant to STANS on a net basis exceeds
the initial margin calculated pursuant to SPAN on a gross basis, OCC
collateralizes this risk exposure by applying an additional margin
charge in the amount of such difference to the account'' (citation
omitted)).
\17\ Specifically, OCC proposes to use STANS plus certain add-on
charges as the basis for determining each Clearing Member's
proportionate share of total risk.
\18\ See Notice of Filing, 84 FR at 57914.
---------------------------------------------------------------------------
D. Margin Call Notification
On a daily basis, OCC evaluates the sufficiency of its financial
resources based on OCC's potential exposure to Clearing Member Groups
under certain stress test scenarios (``Sufficiency Stress Tests'').
Based on the results of the Sufficiency Stress Tests, OCC may call for
additional collateral to ensure that it maintains sufficient financial
resources to guard against potential losses. For example, OCC is
authorized to make an intra-day margin call against a Clearing Member
Group whose Sufficiency Stress Test exposures breach a pre-determined
threshold. Currently, OCC's rules require that written notification of
such intra-day margin calls in excess of $500 million be provided to
OCC's Executive Chairman, Chief Executive Officer, and Chief Operating
Officer (``Office of the CEO''). OCC proposes to revise its rules to
require that written notification of stress test-related intra-day
margin calls also be sent to the Office of the CEO when a stress test-
related intra-day margin call would exceed 75 percent of the Clearing
Member's excess net capital. OCC believes that this additional
notification requirement is appropriate because it would allow OCC's
senior management to be informed as soon as practicable of, and to
subsequently monitor, circumstances where a margin call may strain a
particular Clearing Member's ability to meet such requirements based on
its financial condition or the amount of collateral it has available to
pledge when certain pre-identified thresholds have been exceeded.\19\
---------------------------------------------------------------------------
\19\ See Notice of Filing, 84 FR at 57914.
---------------------------------------------------------------------------
E. Cooling-Off Period
In 2018, OCC implemented a set of recovery tools, including
revisions to OCC's authority to assess its Clearing Members for funds
to replenish OCC's
[[Page 68987]]
Clearing Fund.\20\ For example, OCC implemented a ``cooling-off
period'' during which its authority to levy such assessments is capped,
which provides certainty to Clearing Members regarding their potential
obligations to OCC. In proposing such revisions, OCC intended that the
cooling-off period would be triggered by any proportionate Clearing
Fund charges to Clearing Members related to the default of a Clearing
Member.\21\ OCC's current rules, however, do not provide for a cooling-
off period based on proportionate Clearing Fund charges arising out of
two specific sets of circumstances: (1) In connection with protective
transactions effected for the account of OCC pursuant to Chapter XI of
OCC's Rules and (2) as a result of a failure of any Clearing Member to
make any other required payment or render any other required
performance (as provided in clauses (v) and (vi) of OCC Rule 1006(a)).
OCC proposes to revise its rules such that any proportionate Clearing
Fund charges to Clearing Members related to the default of a Clearing
Member, including the two listed above, would trigger a cooling-off
period.
---------------------------------------------------------------------------
\20\ See Securities Exchange Act Release No. 83916 (Aug. 23,
2018), 83 FR 44076 (Aug. 29, 2018) (SR-OCC-2017-020).
\21\ See Notice of Filing, 84 FR at 57915. Such triggers include
the assessments arising out of a Clearing Member's failure to meet
its obligations regarding confirmed trades, exercised or assigned
contracts, stock loan transactions, or the liquidation of a Clearing
Member's open positions. See id. at n. 22.
---------------------------------------------------------------------------
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.\22\ After carefully
considering the Proposed Rule Change, the Commission finds that 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 \23\ and Rules 17Ad-22(e)(2)
and (4) thereunder.\24\
---------------------------------------------------------------------------
\22\ 15 U.S.C. 78s(b)(2)(C).
\23\ 15 U.S.C. 78q-1(b)(3)(F).
\24\ 17 CFR 240.17Ad-22(e)(2) and 17 CFR 240.17Ad-22(e)(4).
---------------------------------------------------------------------------
A. Consistency With Section 17A(b)(3)(F) of the Exchange Act
Section 17A(b)(3)(F) of the Exchange Act requires, among other
things, that the rules of a clearing agency be designed to (i) promote
the prompt and accurate clearance and settlement of securities
transactions, and to the extent applicable, derivatives agreements,
contracts, and transactions; (ii) assure the safeguarding of securities
and funds which are in the custody or control of the clearing agency or
for which it is responsible; and (iii), in general, protect investors
and promote the public interest.\25\ Based on its review of the record,
the Commission believes that the proposed changes are designed to
promote prompt and accurate clearance and settlement, assure the
safeguarding of securities and funds which are in OCC's custody or
control or for which OCC is responsible, and, in general, protect
investors and promote the public interest for the reasons set forth
below.
---------------------------------------------------------------------------
\25\ 15 U.S.C. 78q-1(b)(3)(F).
---------------------------------------------------------------------------
The Commission believes that the proposed changes to OCC's stress
testing methodology are designed to promote the prompt and accurate
clearance and settlement of securities transactions. As an initial
matter, OCC is the only clearing agency for standardized U.S.
securities options listed on Commission-registered national securities
exchanges (``listed options'').\26\ OCC provides central counterparty
services for the listed-options markets.\27\ OCC's role as the sole CCP
for all listed options contracts in the U.S. makes it an integral part
of the national system for clearance and settlement.\28\ As described
above, OCC proposes to expand the suite of stress tests it uses to size
the Clearing Fund each month, and to revise OCC's estimation of VIX
futures prices for stress testing. The introduction of the
Idiosyncratic Scenarios to the monthly sizing of OCC's Clearing Fund
would be in addition to the Systemic Scenarios OCC already uses to size
its Clearing Fund and would help OCC address risks not currently
contemplated by OCC's Systemic Scenarios, which in turn should enhance
OCC's ability to accurately and appropriately size its Clearing Fund.
Additionally, OCC proposes to revise its process for shocking VIX
futures prices to reflect the actual term structure dynamics of such
futures. OCC's current use of a uniform shock for VIX futures
contracts, regardless of tenure, is not consistent with OCC's
observation that futures contracts with different expirations generally
trade at different prices reflecting the differing future price
expectations of the underlying asset. By enhancing its methodology for
modeling price shocks for VIX futures, OCC should be able to produce
more appropriate VIX futures price shocks in its stress scenarios,
which in turn also should enhance OCC's ability to accurately and
appropriately size its Clearing Fund. OCC relies on the resources in
its Clearing Fund to manage the potential losses arising out of the
default of a Clearing Member under extreme but plausible market
conditions. Strengthening the methodology that OCC uses to manage its
financial resources by enhancing its ability to accurately and
appropriately size the Clearing Fund, therefore, would enhance OCC's
ability to manage Clearing Member defaults, which, in turn, facilitates
the continued clearance and settlement of listed options. The
Commission believes, therefore, that the proposed changes to OCC's
stress testing methodology, taken together, are consistent with the
promotion of prompt and accurate clearance and settlement of
derivatives contracts.
---------------------------------------------------------------------------
\26\ See Securities Exchange Act Release No. 85121 (Feb. 13,
2019), 84 FR 5157 (Feb. 20, 2019) (File No. SR-OCC-2015-02).
\27\ See id., 84 FR at 5158.
\28\ See id.
---------------------------------------------------------------------------
The Commission believes that the proposed changes regarding notice
of intra-day margin requirements and allocation of Clearing Fund
requirements are consistent with assuring the safeguarding of
securities and funds. Currently, OCC notifies its Office of the CEO
when intra-day margin calls generated in response to OCC's daily stress
tests are large in absolute terms (i.e., in excess of $500 million).
OCC proposes to also notify its Office of the CEO when such margin
calls are large relative to the Clearing Member against which they are
made (i.e., in excess of 75 percent of the Clearing Member's excess net
capital). The Commission believes that such notification would provide
OCC's senior management with additional risk management information,
which in turn could be used to inform critical decisions related to
margin or other protective measures that could help OCC avoid drawing
on resources from surviving Clearing Members to manage a Clearing
Member default. In the Commission's view, such measures would be
consistent with assuring the safeguarding of securities and funds which
are in OCC's custody or control or for which OCC is responsible.
Additionally, OCC proposes to revise its method of allocating
Clearing Fund contribution requirements across
[[Page 68988]]
Clearing Members. OCC proposes to redefine the ``total risk'' component
of its Clearing Fund allocation formula such that it would rely on the
same underlying model for all Clearing Members when calculating total
risk (as opposed to using different models for different Clearing
Members depending on their cleared positions). The proposed change
would not alter the allocation weighting, but, in the Commission's
view, it would provide a more consistent metric by which to assess
risks across Clearing Members and determine how much risk each Clearing
Member should bear in terms of Clearing Fund requirements.\29\ The
Commission believes that these changes as well are consistent with
assuring the safeguarding of securities and funds which are in OCC's
custody or control or for which OCC is responsible.
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\29\ While the proposed change would not affect the total size
of the Clearing Fund, it would result in changes to Clearing
Members' proportionate share of the Clearing Fund.
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Finally, the Commission believes that the proposed expansion of
triggers for the cooling-off period is designed, in general, to protect
investors and promote the public interest. The Commission continues to
believe that the cooling-off period provides certainty and
predictability regarding Clearing Members' maximum liability for
Clearing Fund contributions.\30\ Currently, however, the cooling-off
period would be triggered by some, but not all proportionate Clearing
Fund charges to Clearing Members arising out of a Clearing Member's
failure to meet certain obligations under OCC's rules. OCC proposes to
expand the set of events that would trigger the cooling-off period to
include certain protective transactions and the failure of a Clearing
Member to meets its obligations under certain of OCC's rules. The two
events to be added as cooling-off period triggers are similar to the
current triggers in that they pertain to proportionate Clearing Fund
charges designed to manage the failure of a Clearing Member to meet its
obligations to OCC. The Commission believes that including these two
additional events as cooling-off period triggers would provide Clearing
Members with additional certainty and predictability regarding their
potential maximum liability for Clearing Fund contributions, which in
turn is consistent with the protection investors and promotion of the
public interest.
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\30\ See Securities Exchange Act Release No. 83916 (Aug. 23,
2018), 83 FR 44076, 44082 (Aug. 29, 2018) (SR-OCC-2017-020).
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The Commission believes, therefore, that the Proposed Rule Change
is consistent with the requirements of Section 17A(b)(3)(F) of the
Exchange Act.\31\
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\31\ 15 U.S.C. 78q-1(b)(3)(F).
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B. Consistency With Rule 17Ad-22(e)(2) Under the Exchange Act
Rule 17Ad-22(e)(2)(v) under the Exchange Act requires that a
covered clearing agency establish, implement, maintain, and enforce
written policies and procedures reasonably designed to provide for
governance arrangements that, among other things, specify clear and
direct lines of responsibility.\32\
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\32\ 17 CFR 240.17Ad-22(e)(2)(v).
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As described above, OCC proposes to add a new internal reporting
requirement regarding certain intra-day margin calls. OCC may call for
additional margin from Clearing Members based on the results of its
Sufficiency Stress Tests. In addition to notifying its Office of the
CEO when such margin calls are large in absolute terms (i.e., in excess
of $500 million), OCC now proposes to also notify to its Office of the
CEO when such margin calls are large relative to the Clearing Member
against which they are made (i.e., in excess of 75 percent of the
Clearing Member's excess net capital). The Commission believes that
such notification would inform OCC's senior management, who could then
monitor circumstances as appropriate, when an intra-day margin call
could strain the resources of a particular Clearing Member based on its
financial condition. Accordingly, the Commission believes that the
adoption of such a notification requirement is consistent with Rule
17Ad-22(e)(2)(v) under the Exchange Act.\33\
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\33\ 17 CFR 240.17Ad-22(e)(2)(v).
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C. Consistency With Rule 17Ad-22(e)(4) Under the Exchange Act
Rule 17Ad-22(e)(4) under the Exchange Act requires, in part, that a
covered clearing agency establish, implement, maintain, and enforce
written policies and procedures reasonably designed to effectively
identify, measure, monitor, and manage its credit exposures to
participants and those arising from its payment, clearing, and
settlement processes.\34\ Based on its review of the record, the
Commission believes that the proposed rule change is consistent with
Rule 17Ad-22(e)(4) under the Exchange Act.
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\34\ 17 CFR 240.17Ad-22(e)(4).
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1. Stress Testing
Rules 17Ad-22(e)(4)(i) and (iii) under the Exchange Act require
that a covered clearing agency's policies and procedures meet the
requirements of Rule 17Ad-22(e)(4) by maintaining financial resources
at the minimum to enable OCC to cover a wide range of foreseeable
stress scenarios that include, but are not limited to, the default of
the participant family that would potentially cause the largest
aggregate credit exposure for OCC in extreme but plausible market
conditions.\35\ Further, Rule 17Ad-22(e)(4)(vi) under the Exchange Act
requires that a covered clearing agency's policies and procedures meet
the requirements of Rule 17Ad-22(e)(4) by testing the sufficiency of a
covered clearing agency's total financial resources available to meet
the minimum financial resource requirements under Rules 17Ad-
22(e)(4)(i) through (iii).\36\
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\35\ 17 CFR 240.17Ad-22(e)(4)(i) and 17 CFR 240.17Ad-
22(e)(4)(iii).
\36\ 17 CFR 240.17Ad-22(e)(4)(vi).
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As described above, OCC proposes to expand the set of stress tests
that it uses to size the Clearing Fund by adding the Idiosyncratic
Scenarios to its current suite of stress tests. The Idiosyncratic
Scenarios are designed to capture the risk of extreme moves in
individual securities or small subsets of securities, while the current
Systemic Scenarios are based on broad-based market and systemic shocks.
Consistent with the general view that expanding the types of scenarios
that a clearing agency uses in its monthly sizing process makes the
clearing agency's risk management robust to a broader range of shocks,
the Commission believes that OCC's proposal to add the Idiosyncratic
Scenarios to its suite of stress tests would be a strengthening
change--meaning it would enhance OCC's ability to accurately and
appropriately size its Clearing Fund--that is consistent with the
requirements of Rules 17Ad-22(e)(4)(i) and (iii) under the Exchange
Act.\37\
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\37\ 17 CFR 240.17Ad-22(e)(4)(i) and 17 CFR 240.17Ad-
22(e)(4)(iii).
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Additionally, OCC proposes to revise its stress testing methodology
to produce differing price shocks for VIX futures across the term
structure. The proposed methodology would be based on SPX volatility
shocks across different expirations, as opposed to the current
methodology's reliance on a single shock to the VIX. As discussed
above, these changes would help OCC produce VIX futures price shocks in
its stress scenarios that are consistent with OCC's observation that
futures contracts with different expirations generally trade at
different prices reflecting the differing future price expectations of
the underlying asset, which in turn should
[[Page 68989]]
enhance OCC's ability to accurately and appropriately size its Clearing
Fund, consistent with the requirements of Rule 17Ad-22(e)(4)(vi).
Accordingly, the Commission believes that, taken together, OCC's
proposed changes to its stress testing methodology would be consistent
with the requirements of Rules 17Ad-22(e)(4)(i), (iii), and (vi).\38\
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\38\ 17 CFR 240.17Ad-22(e)(4)(i); 17 CFR 240.17Ad-22(e)(4)(iii);
and 17 CFR 240.17Ad-22(e)(4)(vi).
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2. Clearing Fund Allocation
As noted above, Rule 17Ad-22(e)(4) under the Exchange Act generally
requires that a covered clearing agency establish, implement, maintain,
and enforce written policies and procedures reasonably designed to
effectively identify, measure, monitor, and manage its credit exposures
to participants and those arising from its payment, clearing, and
settlement processes.\39\
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\39\ 17 CFR 240.17Ad-22(e)(4).
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OCC relies on the Clearing Fund as a source of mutualized resources
available to manage losses arising out of a Clearing Member's default.
OCC's method for allocating contributions to the Clearing Fund among
Clearing Members is aligned primarily with the credit risk posed by
each Clearing Member.\40\ OCC proposes to redefine the margin risk
component of its Clearing Fund allocation formula such that it would
rely on the same underlying model--STANS--for all Clearing Members (as
opposed to relying on STANS for most Clearing Members and SPAN for
certain Clearing Members with segregated futures accounts). The
proposed change would not change the overall allocation weighting
(i.e., margin risk would still account for 70 percent of the Clearing
Fund allocation among Clearing Members), but the Commission believes it
would provide a more consistent metric by which to assess margin risk
across Clearing Members. Accordingly, the Commission believes that the
proposed change is reasonably designed to support the management of
OCC's credit exposures to its participants. The Commission believes,
therefore, that OCC's proposed change to its Clearing Fund allocation
methodology is consistent with the requirements of Rule 17Ad-
22(e)(4).\41\
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\40\ Clearing Fund allocations are based on a weighting of 70
percent margin risk, what OCC refers to as the ``total risk''
component of its Clearing Fund allocation formula, with open
interest and cleared volume weighted at 15 percent each.
\41\ 17 CFR 240.17Ad-22(e)(4).
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3. Cooling-Off Period
Rule 17Ad-22(e)(4)(ix) under the Exchange Act requires, in part,
that a covered clearing agency establish, implement, maintain, and
enforce written policies and procedures reasonably designed to describe
its process to replenish any financial resources it may use following a
default or other event in which use of resources is contemplated.\42\
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\42\ 17 CFR 240.17Ad-22(e)(4)(ix).
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As noted above, OCC's current recovery tools include a cooling-off
period, during which OCC's authority to assess Clearing Members for
funds to replenish OCC's Clearing Fund is limited. Recognizing the
limit that such a cooling-off period places on the financial resources
available to OCC, the Commission continues to believe that the cooling-
off period provides certainty and predictability regarding Clearing
Members' maximum liability for Clearing Fund contributions.\43\ OCC
proposes to expand the set of events that would start the cooling-off
period to include proportionate Clearing Fund charges to Clearing
Members triggered by certain protective transactions or the failure of
a Clearing Member to meet certain obligations under OCC's rules,
consistent with OCC's original intention with its prior filing. The two
events to be added as triggers for the cooling-off period are similar
to the current triggers in that they pertain to amounts paid out of the
Clearing Fund to manage the failure of a Clearing Member to meet its
obligations to OCC. Consistent with the Commission's statements
regarding the current formulation of the cooling-off period, the
Commission believes that the proposed expansion is consistent with
OCC's obligations to describe its process to replenish any financial
resources it may use following a default or other event in which use of
resources is contemplated as required under Rule 17Ad-22(e)(4)(ix).\44\
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\43\ See Securities Exchange Act Release No. 83916 (Aug. 23,
2018), 83 FR 44076, 44082 (Aug. 29, 2018) (SR-OCC-2017-020).
\44\ 17 CFR 240.17Ad-22(e)(4)(ix).
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Accordingly, and for the reasons stated above, the Commission
believes the changes proposed in the Proposed Rule Change are
consistent with Rule 17Ad-22(e)(4) under the Exchange Act.\45\
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\45\ 17 CFR 240.17Ad-22(e)(4).
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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 \46\ and the rules and regulations thereunder.
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\46\ 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,\47\ that the Proposed Rule Change (SR-OCC-2019-009) be,
and hereby is, approved.
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\47\ 15 U.S.C. 78s(b)(2).
\48\ 17 CFR 200.30-3(a)(12).
For the Commission, by the Division of Trading and Markets,
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pursuant to delegated authority.\48\
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2019-27081 Filed 12-16-19; 8:45 am]
BILLING CODE 8011-01-P