Self-Regulatory Organizations; National Securities Clearing Corporation; Order Approving a Proposed Rule Change To Enhance National Securities Clearing Corporation's Haircut-Based Volatility Charge Applicable to Municipal Bonds, 9843-9847 [2020-03317]
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Federal Register / Vol. 85, No. 34 / Thursday, February 20, 2020 / Notices
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–CboeBZX–2019–097 and
should be submitted by March 12, 2020.
Rebuttal comments should be submitted
by March 26, 2020.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.51
Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2020–03328 Filed 2–19–20; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–88191; File No. SR–NSCC–
2019–004]
Self-Regulatory Organizations;
National Securities Clearing
Corporation; Order Approving a
Proposed Rule Change To Enhance
National Securities Clearing
Corporation’s Haircut-Based Volatility
Charge Applicable to Municipal Bonds
February 13, 2020.
lotter on DSKBCFDHB2PROD with NOTICES
On December 13, 2019, National
Securities Clearing Corporation
(‘‘NSCC’’) 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–NSCC–2019–
004 to revise NSCC’s methodology for
calculating margin amounts applicable
to municipal bonds.3 The proposed rule
change was published for comment in
the Federal Register on January 2,
2020,4 and the Commission received no
comment letters regarding the changes
51 17 CFR 200.30–3(a)(12) & 17 CFR 200.30–
3(a)(57).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 NSCC also filed the proposals contained in the
proposed rule change as advance notice SR–NSCC–
2019–801 with the Commission pursuant to Section
806(e)(1) of the Dodd-Frank Wall Street Reform and
Consumer Protection Act entitled the Payment,
Clearing, and Settlement Supervision Act of 2010
(‘‘Clearing Supervision Act’’), 12 U.S.C. 5465(e)(1),
and Rule 19b–4(n)(1)(i) of the Act, 17 CFR 240.19b–
4(n)(1)(i). Notice of Filing of the Advance Notice
was published for comment in the Federal Register
on January 14, 2020. Securities Exchange Act
Release No. 87911 (January 8, 2020), 85 FR 2197
(January 14, 2020) (File No. SR–NSCC–2019–801).
4 Securities Exchange Act Release No. 87858
(December 26, 2019), 85 FR 149 (January 2, 2020)
(‘‘Notice of Filing’’).
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proposed in the proposed rule change.5
For the reasons discussed below, the
Commission is approving the proposed
rule change.
I. Description of the Proposed Rule
Change
The proposed rule change would
revise NSCC’s Rules and Procedures
(‘‘Rules’’) 6 to change the methodology
NSCC uses for calculating the haircutbased margin charge applicable to
municipal bonds.
A. Background
NSCC provides clearing, settlement,
risk management, central counterparty
services, and a guarantee of completion
for virtually all broker-to-broker trades
involving equity securities, corporate
and municipal debt securities, and
certain other securities. NSCC manages
its credit exposure to its members by
determining an appropriate Required
Fund Deposit (i.e., margin) for each
member.7 NSCC collects each member’s
Required Fund Deposit to mitigate
potential losses to NSCC associated with
the liquidation of the member’s
portfolio in the event of the member’s
default.8 The aggregate of all NSCC
members’ Required Fund Deposits
(together with certain other deposits
required under the Rules) constitutes
NSCC’s Clearing Fund, which NSCC
would access should a defaulting
member’s own Required Fund Deposit
be insufficient to satisfy losses to NSCC
caused by the liquidation of the
defaulting member’s portfolio.9
Each member’s Required Fund
Deposit consists of a number of
applicable components, which are
calculated to address specific risks that
the member’s portfolio presents to
NSCC.10 Generally, the largest
component of a member’s Required
Fund Deposit is the volatility
component.11 The volatility component
5 As the proposals contained in the proposed rule
change were also filed as an advance notice, all
public comments received on the proposals are
considered regardless of whether the comments are
submitted on the proposed rule change or the
advance notice.
6 Capitalized terms not defined herein are defined
in NSCC’s Rules, available at https://dtcc.com/∼/
media/Files/Downloads/legal/rules/nscc_rules.pdf.
7 See Rule 4 (Clearing Fund) and Procedure XV
(Clearing Fund Formula and Other Matters) of the
Rules (‘‘Procedure XV’’), supra note 6.
8 The Rules identify when NSCC may cease to act
for a member and the types of actions NSCC may
take. For example, NSCC may suspend a firm’s
membership with NSCC or prohibit or limit a
member’s access to NSCC’s services in the event
that member defaults on a financial or other
obligation to NSCC. See Rule 46 (Restrictions on
Access to Services), supra note 6.
9 See id.
10 Procedure XV, supra note 6.
11 See id.
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9843
is designed to calculate the potential
losses on a portfolio over a given period
of time assumed necessary to liquidate
the portfolio, within a 99% confidence
level.
The methodology for calculating the
volatility component of the Required
Fund Deposit depends on the type of
security.12 Specifically, for certain
securities, including municipal bonds,
NSCC calculates a haircut-based
volatility component by multiplying the
absolute value of a member’s positions
in such securities by a certain
percentage designated by NSCC.13
NSCC’s current methodology for
designating the percentages used in
calculating the haircut-based volatility
component for municipal bonds
involves distinguishing between
municipal bonds based on tenor (i.e.,
remaining time to maturity), municipal
sector (e.g., general obligation,
transportation, healthcare, etc.), and
credit rating.14 Pursuant to that
methodology, NSCC assigns each tenorbased group a percentage.15 For
municipal bonds rated higher than
BBB+, the tenor-based percentage is the
percentage NSCC uses to calculate the
haircut-based volatility component.16
However, for municipal bonds rated
BBB+ or lower, NSCC multiplies the
tenor-based percentage by a sector-based
risk factor, resulting in a larger
percentage for the haircut.17 The
additional sector-based risk factors
12 For most securities (e.g., equity securities),
NSCC calculates the volatility component as the
greater of (1) the larger of two separate calculations
that utilize a parametric Value at Risk (‘‘VaR’’)
model, (2) a gap risk measure calculation based on
the largest non-index position in a portfolio that
exceeds a concentration threshold, which addresses
concentration risk that can be present in a member’s
portfolio, and (3) a portfolio margin floor
calculation based on the market values of the long
and short positions in the portfolio, which
addresses risks that might not be adequately
addressed with the other volatility component
calculations. See id.; see also Securities Exchange
Act Release No. 82780 (February 26, 2018), 83 FR
9035 (March 2, 2018) (File No. SR–NSCC–2017–
808); Securities Exchange Act Release No. 82781
(February 26, 2018), 83 FR 9042 (March 2, 2018)
(File No. SR–NSCC–2017–020).
13 Procedure XV, supra note 6.
14 Id.
15 Id.
16 Id. For example, a $10MM short position in a
municipal bond rated above BBB+ with 3 years to
maturity is subject to the 2–5 years tenor-based
group haircut of 5%, which applies to the absolute
market value of the positions, resulting in a haircutbased volatility component of $500,000. Notice of
Filing, supra note 4 at 150.
17 Procedure XV, supra note 6. For example, a
$10MM short position in a healthcare sector
municipal bond rated BBB+ or lower with 3 years
to maturity is subject to the 2–5 years tenor-based
group haircut (5%) multiplied by the sector-based
factor of 1.2, resulting in a 6% haircut-based
volatility component of $600,000. Notice of Filing,
supra note 4 at 151.
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Federal Register / Vol. 85, No. 34 / Thursday, February 20, 2020 / Notices
account for the variable risks between
municipal sectors associated with the
various industries in which the bonds
are issued and the sources of bond
repayment.18
In all cases, the percentage used to
calculate the municipal bond haircutbased volatility component is not less
than 2%, regardless of a municipal
bond’s credit rating.19
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B. Changes to NSCC’s Methodology for
Calculating Municipal Bond Haircut
Percentages
NSCC states that it regularly assesses
its margining methodologies to evaluate
whether margin levels are
commensurate with the particular risk
attributes of the various products,
portfolios, and markets that NSCC
serves.20 NSCC further states that based
on recent impact studies, the margin
levels generated from municipal bonds
using the current methodology exceed
the levels necessary to mitigate the risk
associated with those securities.21 In the
proposed rule change, NSCC seeks to
change the methodology for calculating
the municipal bond haircut-based
volatility component so that the amount
of margin NSCC collects is more
commensurate with the risk attributes of
those securities.
As proposed, NSCC would retain the
current provision that in all cases the
percentage used to calculate the
municipal bond haircut-based volatility
component is not less than 2%,
regardless of a municipal bond’s credit
rating. NSCC would also continue to
distinguish between municipal bonds
based on tenor, credit rating, and
municipal sector. However, NSCC
would calculate the haircut percentages
for various groups of municipal bonds
based on the historical returns of one or
more benchmark indices over a lookback period not shorter than 10 years,
using a minimum 99% calibration
percentile.
The proposal would change the
manner in which NSCC addresses the
risk presented by lower-rated municipal
bonds. Instead of the current
methodology’s approach which applies
a sector-based straight risk factor to the
tenor-based haircut resulting in a larger
haircut percentage, the proposed
approach would allow the calculation to
be more precisely tailored to the risks
18 Notice
of Filing, supra note 4 at 151.
19 Procedure XV, supra note 6.
20 Notice of Filing, supra note 4 at 151.
21 Notice of Filing, supra note 4 at 151–52. As
part of the proposed rule change, NSCC filed
Exhibit 3—NSCC Impact Studies, comparing the
current and proposed methodologies. Pursuant to
17 CFR 240.24b–2, NSCC requested confidential
treatment of Exhibit 3.
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presented by particular municipal
bonds. Specifically, the new approach
would base the haircut percentage on
the historical returns of one or more
benchmark indices, such as tenor-based
indices, municipal bond sector-based
indices, and high-yield indices, over a
look-back period of at least ten years,
and would no longer use a sector-based
straight risk factor for lower-rated
municipal bonds. This approach should
allow NSCC to more accurately
calculate margin amounts appropriate
for the risks presented by such
municipal bonds by allowing NSCC to
take into account a broader range of risk
characteristics associated with
municipal bonds. NSCC notes that,
based on recent impact studies
comparing the current and proposed
methodologies, the proposed
methodology would manage NSCC’s
applicable risks well above the 99%
confidence level, although it would
generate lower overall margin
amounts.22
NSCC states that for municipal bonds
rated higher than BBB+, NSCC would
use the percentage derived from a tenorbased index as the haircut for the
purpose of calculating the volatility
component.23 For municipal bonds
rated BBB+ or lower (or not rated),
NSCC states that it would use a
percentage that is the highest of: (1) The
applicable tenor-based index, (2)
municipal bond sector-based indices,
and (3) a high-yield index.24 For all
municipal bonds, when deriving the
haircut percentage from the applicable
indices, NSCC would use a look-back
period of a 10-year rolling window plus
a 1-year ‘‘worst case scenario’’ stress
period.25 NSCC would identify the
largest 3-day price return movement
(reflected as a percentage) within the
99th percentile of all 3-day price return
movements during the look-back period.
Additionally, NSCC proposes to recalibrate the municipal bond haircut
percentages no less frequently than
annually.
As proposed, NSCC would have the
ability to modify certain aspects of the
application of the proposed
methodology consistent with NSCC’s
relevant governance procedures and
based on NSCC’s determination that
such modifications are necessary to
manage the applicable risks above the
99% confidence level. Specifically,
based on NSCC’s regular review of its
margin methodologies, NSCC would be
able to modify: The frequency of recalibrating the municipal bond haircut
percentages; which benchmark indices
to use; the applicable period for the
price return used in the calculations;
and the look-back period. NSCC states
that any such modifications would be
subject to the governance procedures
applicable to all of NSCC’s margin
methodologies, as set forth in NSCC’s
Clearing Agency Model Risk
Management Framework, which the
Commission has approved.26
Finally, NSCC proposes a method to
address extraordinary circumstances in
which a certain municipality or issuer
may present unique risks not otherwise
captured by the proposed
methodology’s use of a percentage
derived from the maximum of the
applicable tenor-based index, municipal
bond sector-based indices, and highyield indices.27 In such scenarios, NSCC
proposes to have the ability to use the
highest percentage generated for any
municipal bond group when calculating
the haircut-based volatility component
for municipal bonds issued by the
municipality or issuer presenting such
unique risks.
II. Discussion and Commission
Findings
Section 19(b)(2)(C) of the Act 28
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 NSCC. In particular, the
Commission finds that the proposed
rule change is consistent with Section
22 Id.
23 Notice
of Filing, supra note 4 at 151.
24 Id.
25 NSCC believes that a 10-year window plus 1year stress period would capture relevant data and
cover sufficient market data without diluting the
‘‘tail’’ with an abundance of data. NSCC believes
this look-back period is typically long enough to
capture at least two recent market cycles, whereas
a longer look-back period might ‘‘flatten’’ out the
results because recent volatile periods might be
offset by non-volatile periods, making the more
recent volatility appear less significant. Notice of
Filing, supra note 4 at 152.
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26 Notice of Filing, supra note 4 at 151–52; See
also Securities Exchange Act Release No. 81485
(August 25, 2017), 82 FR 41433 (August 31, 2017)
(File No. SR–NSCC–2017–008); Securities Exchange
Act Release No. 84458 (October 19, 2018), 83 FR
53925 (October 25, 2018) (File No. SR–NSCC–2018–
009).
27 For example, the market price risk for issues of
a municipality facing technical default following a
natural disaster may not be fully captured by the
proposed methodology due to the liquidity profile
of municipal securities.
28 15 U.S.C. 78s(b)(2)(C).
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17A(b)(3)(F) 29 of the Act and Rules
17Ad–22(e)(4) and (e)(6) thereunder.30
A. Consistency With Section
17A(b)(3)(F)
Section 17A(b)(3)(F) of the Act
requires, in part, that the rules of a
clearing agency, such as NSCC, be
designed to 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.31
First, as described above in Section
I.A., NSCC’s current methodology
calculates municipal bond haircut
percentages using tenor-based
percentages and sector-based risk
factors. NSCC states that the current
methodology generates margin amounts
greater than necessary to mitigate
NSCC’s risks associated with municipal
bonds.32 NSCC proposes to replace the
current methodology with one that
would calculate the haircut percentages
based on the historical returns of one or
more benchmark indices over a lookback period of not shorter than 10 years,
using a minimum 99% calibration
percentile. These changes would result
in margin amounts that are more
commensurate with the risk attributes of
municipal bonds. As noted above, while
the proposed methodology would
reduce margin requirements for
members holding positions in
municipal bonds, NSCC states that
based on recent impact studies, the
proposed methodology would fully
manage NSCC’s applicable risks well
above the 99% confidence level.33
NSCC’s collection of margin amounts
with respect to municipal bonds in a
manner that fully manages NSCC’s
applicable credit exposures should help
ensure that, in the event of a member
default, NSCC’s operations would not be
disrupted and non-defaulting members
would not be exposed to losses that they
cannot anticipate or control.
Accordingly, the Commission finds that
NSCC’s proposed methodology for
calculating municipal bond haircut
percentages would promote the prompt
and accurate clearance and settlement of
securities transactions, consistent with
Section 17A(b)(3)(F) of the Act.34
Moreover, NSCC’s collection of margin
amounts with respect to municipal
bonds in a manner that fully manages
29 15
U.S.C. 78q–1(b)(3)(F).
CFR 240.17Ad–22(e)(4) and (e)(6).
31 15 U.S.C. 78q–1(b)(3)(F).
32 Notice of Filing, supra note 4 at 151–52.
33 Notice of Filing, supra note 4 at 151–52, 154.
34 15 U.S.C. 78q–1(b)(3)(F).
30 17
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NSCC’s applicable credit exposures
would help ensure that NSCC maintains
adequate funds necessary to manage the
risks associated with performing its
clearance and settlement functions,
which could, in turn, help reduce the
amount of credit losses that would
potentially be charged to the Clearing
Fund contributions of non-defaulting
members in the event of a default.
Accordingly, the Commission finds that
NSCC’s proposed methodology for
calculating municipal bond haircut
percentages should safeguard the
securities and funds that are in NSCC’s
custody or control or for which NSCC is
responsible, consistent with Section
17A(b)(3)(F).35
Second, as described above in Section
I.B., NSCC proposes to re-calibrate the
municipal bond haircut percentages no
less frequently than annually. Regular
re-calibration of the municipal bond
haircut percentages is necessary to
ensure that the relevant calculations and
resulting margin levels take into account
any changes over time to the risk
attributes of municipal bonds. The
proposal to re-calibrate the municipal
bond haircut percentages no less
frequently than annually would require
NSCC to regularly review the municipal
bond haircut percentages, thus helping
to ensure that NSCC collects margin
amounts commensurate with the
particular risk attributes of municipal
bonds. By enabling NSCC to continue to
collect margin amounts sufficient to
manage the risks associated with
municipal bonds, NSCC’s proposal to
re-calibrate the municipal bond haircut
percentages no less frequently than
annually should help limit NSCC’s
applicable credit exposures such that, in
the event of a default of a member with
positions in municipal bonds, NSCC’s
operations would not be disrupted and
non-defaulting members would not be
exposed to losses that they cannot
anticipate or control. Accordingly, the
Commission believes that NSCC’s
proposal to re-calibrate the municipal
bond haircut percentages no less
frequently than annually would
promote the prompt and accurate
clearance and settlement of securities
transactions, consistent with Section
17A(b)(3)(F).36
Third, as described above in Section
I.B., a certain municipality or issuer
may present unique risks to NSCC not
otherwise captured by the proposed
methodology’s use of a percentage
derived from the maximum of the
applicable tenor-based index, municipal
bond sector-based indices, and high-
yield indices. In such scenarios, NSCC
proposes to have the ability to use the
highest percentage generated for any
municipal bond group when calculating
the haircut-based volatility component
for municipal bonds issued by the
municipality or issuer presenting such
unique risks. By enabling NSCC to
increase margin requirements in such
scenarios, the proposed rule change
should help limit NSCC’s exposure such
that, in the event of a default of a
member with positions in uniquely
risky municipal bonds, NSCC’s
operations would not be disrupted and
non-defaulting members would not be
exposed to losses that they cannot
anticipate or control. Accordingly, the
Commission believes that NSCC’s
proposed discretion to increase margin
requirements in scenarios where
municipal bonds present unique risks
should promote the prompt and
accurate clearance and settlement of
securities transactions, consistent with
Section 17A(b)(3)(F).37 Moreover, by
enabling NSCC to increase margin
requirements in scenarios where
municipal bonds present unique risks,
the proposed rule change would help
ensure that NSCC maintains adequate
funds necessary to manage the risks
associated with performing its clearance
and settlement functions, which could,
in turn, help reduce the amount of
credit losses that would potentially be
charged to the Clearing Fund
contributions of non-defaulting
members in the event of a default.
Accordingly, the Commission finds that
NSCC’s proposed discretion to increase
margin requirements in scenarios where
municipal bonds present unique risks
should safeguard the securities and
funds that are in NSCC’s custody or
control or for which NSCC is
responsible, consistent with Section
17A(b)(3)(F) of the Act.38
B. Consistency With Rule 17Ad–
22(e)(4)(i)
Rule 17Ad–22(e)(4)(i) requires that
NSCC establish, implement, maintain
and enforce written policies and
procedures reasonably designed to
effectively identify, measure, monitor,
and manage its credit exposures to
participants and those arising from its
payment, clearing, and settlement
processes, including by maintaining
sufficient financial resources to cover its
credit exposure to each participant fully
with a high degree of confidence.39
As described above in Section I.B.,
NSCC proposes to replace the current
37 Id.
35 Id.
38 Id.
36 Id.
39 17
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CFR 240.17Ad–22(e)(4)(i).
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methodology for calculating municipal
bond haircut percentages with a
methodology that would utilize the
historical returns of one or more
benchmark indices over a look-back
period of not shorter than 10 years,
using a minimum 99% calibration
percentile. These changes would result
in more precisely determined margin
amounts, while still managing NSCC’s
applicable risks well above the 99%
confidence level.40 Accordingly, the
Commission believes that the proposed
methodology is consistent with Rule
17Ad–22(e)(4)(i) because it should
enable NSCC to effectively identify,
measure, monitor, and manage its credit
exposures to members with positions in
municipal bonds, including by
maintaining sufficient financial
resources to cover NSCC’s credit
exposure to such members fully with a
high degree of confidence.41
As described above in Section I.B.,
NSCC proposes to re-calibrate the
municipal bond haircut percentages no
less frequently than annually. The
proposal would require NSCC to
regularly review the municipal bond
haircut percentages, thereby helping to
ensure that the haircut percentages and
resulting margin levels take into account
any changes over time to the risk
attributes of municipal bonds.
Accordingly, the Commission believes
that the proposal to re-calibrate the
municipal bond haircut percentages no
less frequently than annually is
consistent with Rule 17Ad–22(e)(4)(i)
because it should allow NSCC to
effectively identify, measure, monitor,
and manage its credit exposures to
members with positions in municipal
bonds, including by maintaining
sufficient financial resources to cover
NSCC’s credit exposure to such
members fully with a high degree of
confidence.42
As described above in Section I.B.,
NSCC proposes to have the ability to use
the highest percentage generated for any
municipal bond group when calculating
the haircut-based volatility component
for municipal bonds issued by a
municipality or issuer presenting
unique risks not otherwise captured by
the calculations in the proposed
methodology. Such discretion should
help ensure that NSCC collects
sufficient margin amounts with respect
to those securities. Accordingly, the
Commission believes that the proposed
ability to apply the highest percentage
to such municipal bonds is consistent
with Rule 17Ad–22(e)(4)(i) because it
should better enable NSCC to effectively
identify, measure, monitor, and manage
its credit exposures to members with
positions in such municipal bonds,
including by maintaining sufficient
financial resources to cover NSCC’s
credit exposure to such members fully
with a high degree of confidence.43
C. Consistency With Rules 17Ad–
22(e)(6)(i) and (v)
Rule 17Ad–22(e)(6)(i) requires that
NSCC establish, implement, maintain
and enforce written policies and
procedures reasonably designed to cover
its credit exposures to its participants by
establishing a risk-based margin system
that, at a minimum, considers, and
produces margin levels commensurate
with, the risks and particular attributes
of each relevant product, portfolio, and
market.44 Rule 17Ad–22(e)(6)(v)
requires that NSCC establish,
implement, maintain and enforce
written policies and procedures
reasonably designed to cover its credit
exposures to its participants by
establishing a risk-based margin system
that, at a minimum, uses an appropriate
method for measuring credit exposure
that accounts for relevant product risk
factors and portfolio effects across
products.45
As described above in Section I.B.,
NSCC proposes to replace the current
methodology for calculating municipal
bond haircut percentages with a
methodology that would utilize the
historical returns of one or more
benchmark indices over a look-back
period of not shorter than 10 years,
using a minimum 99% calibration
percentile. NSCC designed the proposed
methodology to generate margin
amounts that are more commensurate
with the risk attributes of municipal
bonds than the current methodology.
Accordingly, the Commission believes
that the proposed methodology is
consistent with Rules 17Ad–22(e)(6)(i)
and (v) because it is designed to
establish a risk-based margin system
that (1) considers and produces relevant
margin levels commensurate with the
risks and particular attributes of
municipal bonds, and (2) uses an
appropriate method for measuring credit
exposure that accounts for municipal
bond risk factors and portfolio effects.46
As described above in Section I.B.,
NSCC proposes to re-calibrate the
municipal bond haircut percentages no
less frequently than annually. The
proposal would require NSCC to
44 17
41 17
of Filing, supra note 4 at 151–52.
CFR 240.17Ad–22(e)(4)(i).
45 17
42 Id.
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CFR 240.17Ad–22(e)(6)(i).
CFR 240.17Ad–22(e)(6)(v).
46 17 CFR 240.17Ad–22(e)(6)(i) and (v).
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III. 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 49 and the rules
and regulations promulgated
thereunder.
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act 50 that
proposed rule change SR–NSCC–2019–
004, be, and hereby is, APPROVED.51
47 Id.
48 Id.
49 15
U.S.C. 78q–1.
U.S.C. 78s(b)(2).
51 In approving the proposed rule change, the
Commission considered the proposals’ impact on
efficiency, competition, and capital formation. 15
U.S.C. 78c(f).
50 15
43 Id.
40 Notice
regularly review the municipal bond
haircut percentages, thereby helping to
ensure that the haircut percentages and
resulting margin levels take into account
any changes over time to the risk
attributes of municipal bonds.
Accordingly, the Commission believes
that the proposal to re-calibrate the
municipal bond haircut percentages no
less frequently than annually is
consistent with Rules 17Ad–22(e)(6)(i)
and (v) because it would contribute to
a risk-based margin system designed to
(1) consider and produce relevant
margin levels commensurate with the
risks and particular attributes of
municipal bonds, and (2) use an
appropriate method for measuring credit
exposure that accounts for municipal
bond risk factors and portfolio effects.47
As described above in Section I.B.,
NSCC proposes to have the ability to use
the highest percentage generated for any
municipal bond group when calculating
the haircut-based volatility component
for municipal bonds issued by a
municipality or issuer presenting
unique risks not otherwise captured by
the calculations in the proposed
methodology. This discretion should
help ensure that NSCC collects
sufficient margin amounts with respect
to those securities. Accordingly, the
Commission believes that the proposed
discretion to apply the highest
percentage to such municipal bonds is
consistent with Rules 17Ad–22(e)(6)(i)
and (v) because it would contribute to
a risk-based margin system designed to
(1) consider and produce relevant
margin levels commensurate with the
risks and particular attributes of
municipal bonds, and (2) use an
appropriate method for measuring credit
exposure that accounts for municipal
bond risk factors and portfolio effects.48
Fmt 4703
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E:\FR\FM\20FEN1.SGM
20FEN1
Federal Register / Vol. 85, No. 34 / Thursday, February 20, 2020 / Notices
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.52
Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2020–03317 Filed 2–19–20; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–88211; File No. SR–
NYSENAT–2020–05]
Self-Regulatory Organizations; NYSE
National, Inc.; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change To Establish Fees for the
NYSE National Integrated Feed
February 14, 2020.
Pursuant to Section 19(b)(1) 1 of the
Securities Exchange Act of 1934
(‘‘Act’’),2 and Rule 19b–4 thereunder,3
notice is hereby given that on February
3, 2020, NYSE National, Inc. (‘‘NYSE
National’’ or ‘‘Exchange’’) filed with the
Securities and Exchange Commission
(‘‘SEC’’ or ‘‘Commission’’) the proposed
rule change as described in Items I, II,
and III below, which Items have been
prepared by the Exchange. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to establish
fees for the NYSE National Integrated
Feed. The proposed rule change is
available on the Exchange’s website at
www.nyse.com, at the principal office of
the Exchange, and at the Commission’s
Public Reference Room.
lotter on DSKBCFDHB2PROD with NOTICES
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
self-regulatory organization included
statements concerning the purpose of,
and basis for, the proposed rule change
and discussed any comments it received
on the proposed rule change. The text
of those statements may be examined at
the places specified in Item IV below.
The Exchange has prepared summaries,
set forth in sections A, B, and C below,
of the most significant parts of such
statements.
52 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 15 U.S.C. 78a.
3 17 CFR 240.19b–4.
1 15
VerDate Sep<11>2014
19:48 Feb 19, 2020
Jkt 250001
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange proposes to adopt the
NYSE National Proprietary Market Data
Fee Schedule (‘‘Fee Schedule’’) and
establish the fees for the NYSE National
Integrated Feed that would be effective
February 3, 2020.4
In summary, the NYSE National
Integrated Feed is a NYSE National-only
market data feed that provides vendors
and subscribers on a real-time basis
with a unified view of events, in
sequence, as they appear on the NYSE
National matching engine. The NYSE
National Integrated Feed includes
depth-of-book order data, last sale data,
security status updates (e.g., trade
corrections and trading halts), and stock
summary messages. Because the NYSE
National Integrated Feed has a unified
view of events, in sequence, it also
includes information about the
Exchange’s best bid or offer at any given
time.
The Exchange currently does not
charge any fees for the NYSE National
Integrated Feed market data product.5
The Exchange initially filed to
introduce fees for the NYSE National
Integrated Feed on December 4, 2019
(the ‘‘Initial Proposal’’).6 Pursuant to the
Initial Proposal, the fees would not be
implemented until February 3, 2020.
The Initial Proposal was published in
the Federal Register and two comment
letters were submitted in response. The
Initial Proposal was temporarily
suspended pursuant to a Suspension
Order (the ‘‘Initial Suspension Order’’).7
The Initial Suspension Order also
instituted proceedings to determine
whether to approve or disapprove the
Initial Proposal.
4 The
proposed rule change establishing the
NYSE National Integrated Feed was immediately
effective on May 31, 2018. See Securities Exchange
Act Release No. 83350 (May 31, 2018), 83 FR 26332
(June 6, 2018) (SR–NYSENAT–2018–09) (‘‘NYSE
National Integrated Feed Product Filing’’). The
NYSE National Integrated Feed Product Filing also
established the NYSE National BBO and NYSE
National Trades market data feeds.
5 The Exchange also currently does not charge
any fees for the NYSE National BBO and NYSE
National Trades market data products and proposes
to adopt rule text on the Fee Schedule to reflect that
there are no fees charged for NYSE National BBO
and NYSE National Trades market data products.
6 See Securities Exchange Act Release No. 87797
(December 18, 2019), 84 FR 71025 (December 26,
2019).
7 See Securities Exchange Act Release No. 88109
(January 31, 2020) (SR–NYSENAT–2019–13)
(‘‘Initial Suspension Order’’).
PO 00000
Frm 00127
Fmt 4703
Sfmt 4703
9847
Background
The Commission has repeatedly
expressed its preference for competition
over regulatory intervention in
determining prices, products, and
services in the securities markets. In
Regulation NMS, the Commission
highlighted the importance of market
forces in determining prices and SRO
revenues, and also recognized that
current regulation of the market system
‘‘has been remarkably successful in
promoting market competition in its
broader forms that are most important to
investors and listed companies.’’ 8
As the Commission itself recognized,
the market for trading services in NMS
stocks has become ‘‘more fragmented
and competitive.’’ 9 Equity trading is
currently dispersed across 13
exchanges,10 31 alternative trading
systems,11 and numerous broker-dealer
internalizers and wholesalers, all
competing for order flow. Based on
publicly-available information, no
single exchange has more than 18%
market share (whether including or
excluding auction volume).12
The recent growth of NYSE National’s
market share demonstrates this
competitive marketplace. Between
February 2017 and mid-May 2018,
NYSE National was non-operational,
and therefore had 0% of market share.
On May 21, 2018, NYSE National relaunched on its current platform as an
affiliated exchange of New York Stock
Exchange, LLC (‘‘NYSE’’), NYSE Arca,
Inc. (‘‘NYSE Arca, Inc.’’), and NYSE
American LLC (‘‘NYSE American’’).
Within four months, NYSE National
began regularly executing 1% of
consolidated trading volume. By August
2019, NYSE National began executing
approximately 1.5% of consolidated
trading volume on a more regular basis.
By October 2019, the Exchange had
8 See Securities Exchange Act Release No. 51808
(June 9, 2005), 70 FR 37495, 37499 (June 29, 2005)
(S7–10–04) (Final Rule) (‘‘Regulation NMS
Adopting Release’’).
9 See Securities Exchange Act Release No. 51808,
84 FR 5202, 5253 (February 20, 2019) (File No. S7–
05–18) (Transaction Fee Pilot for NMS Stocks Final
Rule) (‘‘Transaction Fee Pilot’’).
10 See Cboe Global Markets, U.S. Equities Market
Volume Summary, available at https://
markets.cboe.com/us/equities/market_share/. See
generally https://www.sec.gov/fast-answers/
divisionsmarketregmrexchangesshtml.html.
11 See FINRA ATS Transparency Data, available
at https://otctransparency.finra.org/
otctransparency/AtsIssueData. A list of alternative
trading systems registered with the Commission is
available at https://www.sec.gov/foia/docs/
atslist.htm.
12 See Cboe Global Markets, U.S. Equities Market
Volume Summary, available at https://
markets.cboe.com/us/equities/market_share/.
E:\FR\FM\20FEN1.SGM
20FEN1
Agencies
[Federal Register Volume 85, Number 34 (Thursday, February 20, 2020)]
[Notices]
[Pages 9843-9847]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-03317]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-88191; File No. SR-NSCC-2019-004]
Self-Regulatory Organizations; National Securities Clearing
Corporation; Order Approving a Proposed Rule Change To Enhance National
Securities Clearing Corporation's Haircut-Based Volatility Charge
Applicable to Municipal Bonds
February 13, 2020.
On December 13, 2019, National Securities Clearing Corporation
(``NSCC'') 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-NSCC-2019-004 to revise NSCC's methodology for
calculating margin amounts applicable to municipal bonds.\3\ The
proposed rule change was published for comment in the Federal Register
on January 2, 2020,\4\ and the Commission received no comment letters
regarding the changes proposed in the proposed rule change.\5\ For the
reasons discussed below, the Commission is approving the proposed rule
change.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ NSCC also filed the proposals contained in the proposed rule
change as advance notice SR-NSCC-2019-801 with the Commission
pursuant to Section 806(e)(1) of the Dodd-Frank Wall Street Reform
and Consumer Protection Act entitled the Payment, Clearing, and
Settlement Supervision Act of 2010 (``Clearing Supervision Act''),
12 U.S.C. 5465(e)(1), and Rule 19b-4(n)(1)(i) of the Act, 17 CFR
240.19b-4(n)(1)(i). Notice of Filing of the Advance Notice was
published for comment in the Federal Register on January 14, 2020.
Securities Exchange Act Release No. 87911 (January 8, 2020), 85 FR
2197 (January 14, 2020) (File No. SR-NSCC-2019-801).
\4\ Securities Exchange Act Release No. 87858 (December 26,
2019), 85 FR 149 (January 2, 2020) (``Notice of Filing'').
\5\ As the proposals contained in the proposed rule change were
also filed as an advance notice, all public comments received on the
proposals are considered regardless of whether the comments are
submitted on the proposed rule change or the advance notice.
---------------------------------------------------------------------------
I. Description of the Proposed Rule Change
The proposed rule change would revise NSCC's Rules and Procedures
(``Rules'') \6\ to change the methodology NSCC uses for calculating the
haircut-based margin charge applicable to municipal bonds.
---------------------------------------------------------------------------
\6\ Capitalized terms not defined herein are defined in NSCC's
Rules, available at https://dtcc.com/~/media/Files/Downloads/legal/
rules/nscc_rules.pdf.
---------------------------------------------------------------------------
A. Background
NSCC provides clearing, settlement, risk management, central
counterparty services, and a guarantee of completion for virtually all
broker-to-broker trades involving equity securities, corporate and
municipal debt securities, and certain other securities. NSCC manages
its credit exposure to its members by determining an appropriate
Required Fund Deposit (i.e., margin) for each member.\7\ NSCC collects
each member's Required Fund Deposit to mitigate potential losses to
NSCC associated with the liquidation of the member's portfolio in the
event of the member's default.\8\ The aggregate of all NSCC members'
Required Fund Deposits (together with certain other deposits required
under the Rules) constitutes NSCC's Clearing Fund, which NSCC would
access should a defaulting member's own Required Fund Deposit be
insufficient to satisfy losses to NSCC caused by the liquidation of the
defaulting member's portfolio.\9\
---------------------------------------------------------------------------
\7\ See Rule 4 (Clearing Fund) and Procedure XV (Clearing Fund
Formula and Other Matters) of the Rules (``Procedure XV''), supra
note 6.
\8\ The Rules identify when NSCC may cease to act for a member
and the types of actions NSCC may take. For example, NSCC may
suspend a firm's membership with NSCC or prohibit or limit a
member's access to NSCC's services in the event that member defaults
on a financial or other obligation to NSCC. See Rule 46
(Restrictions on Access to Services), supra note 6.
\9\ See id.
---------------------------------------------------------------------------
Each member's Required Fund Deposit consists of a number of
applicable components, which are calculated to address specific risks
that the member's portfolio presents to NSCC.\10\ Generally, the
largest component of a member's Required Fund Deposit is the volatility
component.\11\ The volatility component is designed to calculate the
potential losses on a portfolio over a given period of time assumed
necessary to liquidate the portfolio, within a 99% confidence level.
---------------------------------------------------------------------------
\10\ Procedure XV, supra note 6.
\11\ See id.
---------------------------------------------------------------------------
The methodology for calculating the volatility component of the
Required Fund Deposit depends on the type of security.\12\
Specifically, for certain securities, including municipal bonds, NSCC
calculates a haircut-based volatility component by multiplying the
absolute value of a member's positions in such securities by a certain
percentage designated by NSCC.\13\
---------------------------------------------------------------------------
\12\ For most securities (e.g., equity securities), NSCC
calculates the volatility component as the greater of (1) the larger
of two separate calculations that utilize a parametric Value at Risk
(``VaR'') model, (2) a gap risk measure calculation based on the
largest non-index position in a portfolio that exceeds a
concentration threshold, which addresses concentration risk that can
be present in a member's portfolio, and (3) a portfolio margin floor
calculation based on the market values of the long and short
positions in the portfolio, which addresses risks that might not be
adequately addressed with the other volatility component
calculations. See id.; see also Securities Exchange Act Release No.
82780 (February 26, 2018), 83 FR 9035 (March 2, 2018) (File No. SR-
NSCC-2017-808); Securities Exchange Act Release No. 82781 (February
26, 2018), 83 FR 9042 (March 2, 2018) (File No. SR-NSCC-2017-020).
\13\ Procedure XV, supra note 6.
---------------------------------------------------------------------------
NSCC's current methodology for designating the percentages used in
calculating the haircut-based volatility component for municipal bonds
involves distinguishing between municipal bonds based on tenor (i.e.,
remaining time to maturity), municipal sector (e.g., general
obligation, transportation, healthcare, etc.), and credit rating.\14\
Pursuant to that methodology, NSCC assigns each tenor-based group a
percentage.\15\ For municipal bonds rated higher than BBB+, the tenor-
based percentage is the percentage NSCC uses to calculate the haircut-
based volatility component.\16\ However, for municipal bonds rated BBB+
or lower, NSCC multiplies the tenor-based percentage by a sector-based
risk factor, resulting in a larger percentage for the haircut.\17\ The
additional sector-based risk factors
[[Page 9844]]
account for the variable risks between municipal sectors associated
with the various industries in which the bonds are issued and the
sources of bond repayment.\18\
---------------------------------------------------------------------------
\14\ Id.
\15\ Id.
\16\ Id. For example, a $10MM short position in a municipal bond
rated above BBB+ with 3 years to maturity is subject to the 2-5
years tenor-based group haircut of 5%, which applies to the absolute
market value of the positions, resulting in a haircut-based
volatility component of $500,000. Notice of Filing, supra note 4 at
150.
\17\ Procedure XV, supra note 6. For example, a $10MM short
position in a healthcare sector municipal bond rated BBB+ or lower
with 3 years to maturity is subject to the 2-5 years tenor-based
group haircut (5%) multiplied by the sector-based factor of 1.2,
resulting in a 6% haircut-based volatility component of $600,000.
Notice of Filing, supra note 4 at 151.
\18\ Notice of Filing, supra note 4 at 151.
---------------------------------------------------------------------------
In all cases, the percentage used to calculate the municipal bond
haircut-based volatility component is not less than 2%, regardless of a
municipal bond's credit rating.\19\
---------------------------------------------------------------------------
\19\ Procedure XV, supra note 6.
---------------------------------------------------------------------------
B. Changes to NSCC's Methodology for Calculating Municipal Bond Haircut
Percentages
NSCC states that it regularly assesses its margining methodologies
to evaluate whether margin levels are commensurate with the particular
risk attributes of the various products, portfolios, and markets that
NSCC serves.\20\ NSCC further states that based on recent impact
studies, the margin levels generated from municipal bonds using the
current methodology exceed the levels necessary to mitigate the risk
associated with those securities.\21\ In the proposed rule change, NSCC
seeks to change the methodology for calculating the municipal bond
haircut-based volatility component so that the amount of margin NSCC
collects is more commensurate with the risk attributes of those
securities.
---------------------------------------------------------------------------
\20\ Notice of Filing, supra note 4 at 151.
\21\ Notice of Filing, supra note 4 at 151-52. As part of the
proposed rule change, NSCC filed Exhibit 3--NSCC Impact Studies,
comparing the current and proposed methodologies. Pursuant to 17 CFR
240.24b-2, NSCC requested confidential treatment of Exhibit 3.
---------------------------------------------------------------------------
As proposed, NSCC would retain the current provision that in all
cases the percentage used to calculate the municipal bond haircut-based
volatility component is not less than 2%, regardless of a municipal
bond's credit rating. NSCC would also continue to distinguish between
municipal bonds based on tenor, credit rating, and municipal sector.
However, NSCC would calculate the haircut percentages for various
groups of municipal bonds based on the historical returns of one or
more benchmark indices over a look-back period not shorter than 10
years, using a minimum 99% calibration percentile.
The proposal would change the manner in which NSCC addresses the
risk presented by lower-rated municipal bonds. Instead of the current
methodology's approach which applies a sector-based straight risk
factor to the tenor-based haircut resulting in a larger haircut
percentage, the proposed approach would allow the calculation to be
more precisely tailored to the risks presented by particular municipal
bonds. Specifically, the new approach would base the haircut percentage
on the historical returns of one or more benchmark indices, such as
tenor-based indices, municipal bond sector-based indices, and high-
yield indices, over a look-back period of at least ten years, and would
no longer use a sector-based straight risk factor for lower-rated
municipal bonds. This approach should allow NSCC to more accurately
calculate margin amounts appropriate for the risks presented by such
municipal bonds by allowing NSCC to take into account a broader range
of risk characteristics associated with municipal bonds. NSCC notes
that, based on recent impact studies comparing the current and proposed
methodologies, the proposed methodology would manage NSCC's applicable
risks well above the 99% confidence level, although it would generate
lower overall margin amounts.\22\
---------------------------------------------------------------------------
\22\ Id.
---------------------------------------------------------------------------
NSCC states that for municipal bonds rated higher than BBB+, NSCC
would use the percentage derived from a tenor-based index as the
haircut for the purpose of calculating the volatility component.\23\
For municipal bonds rated BBB+ or lower (or not rated), NSCC states
that it would use a percentage that is the highest of: (1) The
applicable tenor-based index, (2) municipal bond sector-based indices,
and (3) a high-yield index.\24\ For all municipal bonds, when deriving
the haircut percentage from the applicable indices, NSCC would use a
look-back period of a 10-year rolling window plus a 1-year ``worst case
scenario'' stress period.\25\ NSCC would identify the largest 3-day
price return movement (reflected as a percentage) within the 99th
percentile of all 3-day price return movements during the look-back
period. Additionally, NSCC proposes to re-calibrate the municipal bond
haircut percentages no less frequently than annually.
---------------------------------------------------------------------------
\23\ Notice of Filing, supra note 4 at 151.
\24\ Id.
\25\ NSCC believes that a 10-year window plus 1-year stress
period would capture relevant data and cover sufficient market data
without diluting the ``tail'' with an abundance of data. NSCC
believes this look-back period is typically long enough to capture
at least two recent market cycles, whereas a longer look-back period
might ``flatten'' out the results because recent volatile periods
might be offset by non-volatile periods, making the more recent
volatility appear less significant. Notice of Filing, supra note 4
at 152.
---------------------------------------------------------------------------
As proposed, NSCC would have the ability to modify certain aspects
of the application of the proposed methodology consistent with NSCC's
relevant governance procedures and based on NSCC's determination that
such modifications are necessary to manage the applicable risks above
the 99% confidence level. Specifically, based on NSCC's regular review
of its margin methodologies, NSCC would be able to modify: The
frequency of re-calibrating the municipal bond haircut percentages;
which benchmark indices to use; the applicable period for the price
return used in the calculations; and the look-back period. NSCC states
that any such modifications would be subject to the governance
procedures applicable to all of NSCC's margin methodologies, as set
forth in NSCC's Clearing Agency Model Risk Management Framework, which
the Commission has approved.\26\
---------------------------------------------------------------------------
\26\ Notice of Filing, supra note 4 at 151-52; See also
Securities Exchange Act Release No. 81485 (August 25, 2017), 82 FR
41433 (August 31, 2017) (File No. SR-NSCC-2017-008); Securities
Exchange Act Release No. 84458 (October 19, 2018), 83 FR 53925
(October 25, 2018) (File No. SR-NSCC-2018-009).
---------------------------------------------------------------------------
Finally, NSCC proposes a method to address extraordinary
circumstances in which a certain municipality or issuer may present
unique risks not otherwise captured by the proposed methodology's use
of a percentage derived from the maximum of the applicable tenor-based
index, municipal bond sector-based indices, and high-yield indices.\27\
In such scenarios, NSCC proposes to have the ability to use the highest
percentage generated for any municipal bond group when calculating the
haircut-based volatility component for municipal bonds issued by the
municipality or issuer presenting such unique risks.
---------------------------------------------------------------------------
\27\ For example, the market price risk for issues of a
municipality facing technical default following a natural disaster
may not be fully captured by the proposed methodology due to the
liquidity profile of municipal securities.
---------------------------------------------------------------------------
II. Discussion and Commission Findings
Section 19(b)(2)(C) of the Act \28\ 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 NSCC. In particular, the
Commission finds that the proposed rule change is consistent with
Section
[[Page 9845]]
17A(b)(3)(F) \29\ of the Act and Rules 17Ad-22(e)(4) and (e)(6)
thereunder.\30\
---------------------------------------------------------------------------
\28\ 15 U.S.C. 78s(b)(2)(C).
\29\ 15 U.S.C. 78q-1(b)(3)(F).
\30\ 17 CFR 240.17Ad-22(e)(4) and (e)(6).
---------------------------------------------------------------------------
A. Consistency With Section 17A(b)(3)(F)
Section 17A(b)(3)(F) of the Act requires, in part, that the rules
of a clearing agency, such as NSCC, be designed to 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.\31\
---------------------------------------------------------------------------
\31\ 15 U.S.C. 78q-1(b)(3)(F).
---------------------------------------------------------------------------
First, as described above in Section I.A., NSCC's current
methodology calculates municipal bond haircut percentages using tenor-
based percentages and sector-based risk factors. NSCC states that the
current methodology generates margin amounts greater than necessary to
mitigate NSCC's risks associated with municipal bonds.\32\ NSCC
proposes to replace the current methodology with one that would
calculate the haircut percentages based on the historical returns of
one or more benchmark indices over a look-back period of not shorter
than 10 years, using a minimum 99% calibration percentile. These
changes would result in margin amounts that are more commensurate with
the risk attributes of municipal bonds. As noted above, while the
proposed methodology would reduce margin requirements for members
holding positions in municipal bonds, NSCC states that based on recent
impact studies, the proposed methodology would fully manage NSCC's
applicable risks well above the 99% confidence level.\33\ NSCC's
collection of margin amounts with respect to municipal bonds in a
manner that fully manages NSCC's applicable credit exposures should
help ensure that, in the event of a member default, NSCC's operations
would not be disrupted and non-defaulting members would not be exposed
to losses that they cannot anticipate or control. Accordingly, the
Commission finds that NSCC's proposed methodology for calculating
municipal bond haircut percentages would promote the prompt and
accurate clearance and settlement of securities transactions,
consistent with Section 17A(b)(3)(F) of the Act.\34\ Moreover, NSCC's
collection of margin amounts with respect to municipal bonds in a
manner that fully manages NSCC's applicable credit exposures would help
ensure that NSCC maintains adequate funds necessary to manage the risks
associated with performing its clearance and settlement functions,
which could, in turn, help reduce the amount of credit losses that
would potentially be charged to the Clearing Fund contributions of non-
defaulting members in the event of a default. Accordingly, the
Commission finds that NSCC's proposed methodology for calculating
municipal bond haircut percentages should safeguard the securities and
funds that are in NSCC's custody or control or for which NSCC is
responsible, consistent with Section 17A(b)(3)(F).\35\
---------------------------------------------------------------------------
\32\ Notice of Filing, supra note 4 at 151-52.
\33\ Notice of Filing, supra note 4 at 151-52, 154.
\34\ 15 U.S.C. 78q-1(b)(3)(F).
\35\ Id.
---------------------------------------------------------------------------
Second, as described above in Section I.B., NSCC proposes to re-
calibrate the municipal bond haircut percentages no less frequently
than annually. Regular re-calibration of the municipal bond haircut
percentages is necessary to ensure that the relevant calculations and
resulting margin levels take into account any changes over time to the
risk attributes of municipal bonds. The proposal to re-calibrate the
municipal bond haircut percentages no less frequently than annually
would require NSCC to regularly review the municipal bond haircut
percentages, thus helping to ensure that NSCC collects margin amounts
commensurate with the particular risk attributes of municipal bonds. By
enabling NSCC to continue to collect margin amounts sufficient to
manage the risks associated with municipal bonds, NSCC's proposal to
re-calibrate the municipal bond haircut percentages no less frequently
than annually should help limit NSCC's applicable credit exposures such
that, in the event of a default of a member with positions in municipal
bonds, NSCC's operations would not be disrupted and non-defaulting
members would not be exposed to losses that they cannot anticipate or
control. Accordingly, the Commission believes that NSCC's proposal to
re-calibrate the municipal bond haircut percentages no less frequently
than annually would promote the prompt and accurate clearance and
settlement of securities transactions, consistent with Section
17A(b)(3)(F).\36\
---------------------------------------------------------------------------
\36\ Id.
---------------------------------------------------------------------------
Third, as described above in Section I.B., a certain municipality
or issuer may present unique risks to NSCC not otherwise captured by
the proposed methodology's use of a percentage derived from the maximum
of the applicable tenor-based index, municipal bond sector-based
indices, and high-yield indices. In such scenarios, NSCC proposes to
have the ability to use the highest percentage generated for any
municipal bond group when calculating the haircut-based volatility
component for municipal bonds issued by the municipality or issuer
presenting such unique risks. By enabling NSCC to increase margin
requirements in such scenarios, the proposed rule change should help
limit NSCC's exposure such that, in the event of a default of a member
with positions in uniquely risky municipal bonds, NSCC's operations
would not be disrupted and non-defaulting members would not be exposed
to losses that they cannot anticipate or control. Accordingly, the
Commission believes that NSCC's proposed discretion to increase margin
requirements in scenarios where municipal bonds present unique risks
should promote the prompt and accurate clearance and settlement of
securities transactions, consistent with Section 17A(b)(3)(F).\37\
Moreover, by enabling NSCC to increase margin requirements in scenarios
where municipal bonds present unique risks, the proposed rule change
would help ensure that NSCC maintains adequate funds necessary to
manage the risks associated with performing its clearance and
settlement functions, which could, in turn, help reduce the amount of
credit losses that would potentially be charged to the Clearing Fund
contributions of non-defaulting members in the event of a default.
Accordingly, the Commission finds that NSCC's proposed discretion to
increase margin requirements in scenarios where municipal bonds present
unique risks should safeguard the securities and funds that are in
NSCC's custody or control or for which NSCC is responsible, consistent
with Section 17A(b)(3)(F) of the Act.\38\
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\37\ Id.
\38\ Id.
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B. Consistency With Rule 17Ad-22(e)(4)(i)
Rule 17Ad-22(e)(4)(i) requires that NSCC establish, implement,
maintain and enforce written policies and procedures reasonably
designed to effectively identify, measure, monitor, and manage its
credit exposures to participants and those arising from its payment,
clearing, and settlement processes, including by maintaining sufficient
financial resources to cover its credit exposure to each participant
fully with a high degree of confidence.\39\
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\39\ 17 CFR 240.17Ad-22(e)(4)(i).
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As described above in Section I.B., NSCC proposes to replace the
current
[[Page 9846]]
methodology for calculating municipal bond haircut percentages with a
methodology that would utilize the historical returns of one or more
benchmark indices over a look-back period of not shorter than 10 years,
using a minimum 99% calibration percentile. These changes would result
in more precisely determined margin amounts, while still managing
NSCC's applicable risks well above the 99% confidence level.\40\
Accordingly, the Commission believes that the proposed methodology is
consistent with Rule 17Ad-22(e)(4)(i) because it should enable NSCC to
effectively identify, measure, monitor, and manage its credit exposures
to members with positions in municipal bonds, including by maintaining
sufficient financial resources to cover NSCC's credit exposure to such
members fully with a high degree of confidence.\41\
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\40\ Notice of Filing, supra note 4 at 151-52.
\41\ 17 CFR 240.17Ad-22(e)(4)(i).
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As described above in Section I.B., NSCC proposes to re-calibrate
the municipal bond haircut percentages no less frequently than
annually. The proposal would require NSCC to regularly review the
municipal bond haircut percentages, thereby helping to ensure that the
haircut percentages and resulting margin levels take into account any
changes over time to the risk attributes of municipal bonds.
Accordingly, the Commission believes that the proposal to re-calibrate
the municipal bond haircut percentages no less frequently than annually
is consistent with Rule 17Ad-22(e)(4)(i) because it should allow NSCC
to effectively identify, measure, monitor, and manage its credit
exposures to members with positions in municipal bonds, including by
maintaining sufficient financial resources to cover NSCC's credit
exposure to such members fully with a high degree of confidence.\42\
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\42\ Id.
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As described above in Section I.B., NSCC proposes to have the
ability to use the highest percentage generated for any municipal bond
group when calculating the haircut-based volatility component for
municipal bonds issued by a municipality or issuer presenting unique
risks not otherwise captured by the calculations in the proposed
methodology. Such discretion should help ensure that NSCC collects
sufficient margin amounts with respect to those securities.
Accordingly, the Commission believes that the proposed ability to apply
the highest percentage to such municipal bonds is consistent with Rule
17Ad-22(e)(4)(i) because it should better enable NSCC to effectively
identify, measure, monitor, and manage its credit exposures to members
with positions in such municipal bonds, including by maintaining
sufficient financial resources to cover NSCC's credit exposure to such
members fully with a high degree of confidence.\43\
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\43\ Id.
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C. Consistency With Rules 17Ad-22(e)(6)(i) and (v)
Rule 17Ad-22(e)(6)(i) requires that NSCC establish, implement,
maintain and enforce written policies and procedures reasonably
designed to cover its credit exposures to its participants by
establishing a risk-based margin system that, at a minimum, considers,
and produces margin levels commensurate with, the risks and particular
attributes of each relevant product, portfolio, and market.\44\ Rule
17Ad-22(e)(6)(v) requires that NSCC establish, implement, maintain and
enforce written policies and procedures reasonably designed to cover
its credit exposures to its participants by establishing a risk-based
margin system that, at a minimum, uses an appropriate method for
measuring credit exposure that accounts for relevant product risk
factors and portfolio effects across products.\45\
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\44\ 17 CFR 240.17Ad-22(e)(6)(i).
\45\ 17 CFR 240.17Ad-22(e)(6)(v).
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As described above in Section I.B., NSCC proposes to replace the
current methodology for calculating municipal bond haircut percentages
with a methodology that would utilize the historical returns of one or
more benchmark indices over a look-back period of not shorter than 10
years, using a minimum 99% calibration percentile. NSCC designed the
proposed methodology to generate margin amounts that are more
commensurate with the risk attributes of municipal bonds than the
current methodology. Accordingly, the Commission believes that the
proposed methodology is consistent with Rules 17Ad-22(e)(6)(i) and (v)
because it is designed to establish a risk-based margin system that (1)
considers and produces relevant margin levels commensurate with the
risks and particular attributes of municipal bonds, and (2) uses an
appropriate method for measuring credit exposure that accounts for
municipal bond risk factors and portfolio effects.\46\
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\46\ 17 CFR 240.17Ad-22(e)(6)(i) and (v).
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As described above in Section I.B., NSCC proposes to re-calibrate
the municipal bond haircut percentages no less frequently than
annually. The proposal would require NSCC to regularly review the
municipal bond haircut percentages, thereby helping to ensure that the
haircut percentages and resulting margin levels take into account any
changes over time to the risk attributes of municipal bonds.
Accordingly, the Commission believes that the proposal to re-calibrate
the municipal bond haircut percentages no less frequently than annually
is consistent with Rules 17Ad-22(e)(6)(i) and (v) because it would
contribute to a risk-based margin system designed to (1) consider and
produce relevant margin levels commensurate with the risks and
particular attributes of municipal bonds, and (2) use an appropriate
method for measuring credit exposure that accounts for municipal bond
risk factors and portfolio effects.\47\
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\47\ Id.
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As described above in Section I.B., NSCC proposes to have the
ability to use the highest percentage generated for any municipal bond
group when calculating the haircut-based volatility component for
municipal bonds issued by a municipality or issuer presenting unique
risks not otherwise captured by the calculations in the proposed
methodology. This discretion should help ensure that NSCC collects
sufficient margin amounts with respect to those securities.
Accordingly, the Commission believes that the proposed discretion to
apply the highest percentage to such municipal bonds is consistent with
Rules 17Ad-22(e)(6)(i) and (v) because it would contribute to a risk-
based margin system designed to (1) consider and produce relevant
margin levels commensurate with the risks and particular attributes of
municipal bonds, and (2) use an appropriate method for measuring credit
exposure that accounts for municipal bond risk factors and portfolio
effects.\48\
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\48\ Id.
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III. 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 \49\ and
the rules and regulations promulgated thereunder.
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\49\ 15 U.S.C. 78q-1.
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It is therefore ordered, pursuant to Section 19(b)(2) of the Act
\50\ that proposed rule change SR-NSCC-2019-004, be, and hereby is,
APPROVED.\51\
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\50\ 15 U.S.C. 78s(b)(2).
\51\ In approving the proposed rule change, the Commission
considered the proposals' impact on efficiency, competition, and
capital formation. 15 U.S.C. 78c(f).
[[Page 9847]]
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For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\52\
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\52\ 17 CFR 200.30-3(a)(12).
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Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2020-03317 Filed 2-19-20; 8:45 am]
BILLING CODE 8011-01-P