Self-Regulatory Organizations; The Options Clearing Corporation; Order Approving Proposed Rule Change To Modify the Fees for Exercise Notices Submitted After the Deadlines and To Change the Deadline for Submitting a Late Exercise Notice on Non-Expiration Dates, 13198-13200 [2020-04576]
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13198
Federal Register / Vol. 85, No. 45 / Friday, March 6, 2020 / Notices
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE,
Washington, DC 20549–1090.
All submissions should refer to File
Number SR–CboeEDGX–2020–010. This
file number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
internet website (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for website viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE,
Washington, DC 20549, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change.
Persons submitting comments are
cautioned that we do not redact or edit
personal identifying information from
comment submissions. You should
submit only information that you wish
to make available publicly. All
submissions should refer to File
Number SR–CboeEDGX–2020–010, and
should be submitted on or before March
27, 2020.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.19
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020–04575 Filed 3–5–20; 8:45 am]
lotter on DSKBCFDHB2PROD with NOTICES
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–88310; File No. SR–OCC–
2020–001]
Self-Regulatory Organizations; The
Options Clearing Corporation; Order
Approving Proposed Rule Change To
Modify the Fees for Exercise Notices
Submitted After the Deadlines and To
Change the Deadline for Submitting a
Late Exercise Notice on NonExpiration Dates
March 2, 2020.
I. Introduction
On January 14, 2020, the Options
Clearing Corporation (‘‘OCC’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change SR–OCC–2020–
001 (‘‘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
modify the fee imposed for submitting
a late exercise notice and change the
deadline by which such a notice must
be submitted on non-expiration dates.3
The Proposed Rule Change was
published for public comment in the
Federal Register on January 30, 2020.4
The Commission has received no
comments regarding the Proposed Rule
Change. This order approves the
Proposed Rule Change.
II. Background
OCC’s rules require Clearing Members
to submit option exercise notices within
the timeframes prescribed by OCC.
OCC’s rules provide for an exception
process to accommodate exercise
notices submitted outside of such
timeframes solely for the purpose of
correcting a bona fide error on the part
of a Clearing Member or customer.5
OCC’s process for accommodating late
exercise notices includes, among other
things, a late filing fee and a final
deadline by which any such notice must
be received by OCC. OCC proposes to
amend its Rules 801 and 805 to modify
the fees for exercise notices submitted
after the deadlines by which all option
exercise notices must be submitted and
to change the deadline for submitting a
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Notice of Filing infra note 4, at 85 FR 5491.
4 Securities Exchange Act Release No. 88030 (Jan.
24, 2020), 85 FR 5491 (Jan. 30, 2020) (SR–OCC–
2020–001) (‘‘Notice of Filing’’).
5 See OCC Rules 801 and 805, available at https://
www.theocc.com/components/docs/legal/rules_
and_bylaws/occ_rules.pdf.
2 17
19 17
CFR 200.30–3(a)(12).
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late exercise notice on non-expiration
dates.6
OCC’s Rule 801 governs the exercise
of an options on days other than the
option’s expiration date. OCC’s Rule 805
governs the exercise of an option on the
option’s expiration date. Under OCC’s
Rule 801(d), the filing of a late exercise
notice by a Clearing Member may be
deemed a violation of OCC’s procedures
and may subject the Clearing Member to
disciplinary action. Additionally, under
OCC’s Rule 801(d) and Rule 805(g), a
Clearing Member submitting a late
exercise notice is liable to OCC for a
$75,000 fee per line item listed on a late
exercise notice.7
OCC observed that the Clearing
Members submitting late exercise
notices in 2017 and 2019 captured
dividends on the securities underlying
the late exercised options, thereby
securing the financial gains associated
with such captured dividends.8 Further,
OCC observed that the amount of
dividends captured ranged from $93,600
to $436,800.9 OCC has previously stated
that the late exercise fee is intended as
an incentive for Clearing Members to be
especially diligent in processing
exercise notices and to improve back
office procedures while at the same time
preserving their ability to correct bona
fide operational errors.10
On November 9, 2017, OCC discussed
late exercise notices submitted in 2017
at its OCC Roundtable, an OCCsponsored advisory group comprised of
representatives from OCC’s participant
exchanges, a cross-section of OCC
Clearing Members, and OCC staff.11 The
OCC Roundtable participants noted the
dollar amount at issue in connection
with late exercises received in 2017,
which reflected the amount of
dividends received by the person
submitting the late exercise as a result
of receiving the underlying shares. As a
result of these discussions, Roundtable
participants agreed that an increase in
the late exercise fee from the current
$75,000 fee per line item to $250,000 fee
per line item would be appropriate and
in a range to incentivize Clearing
6 OCC did not propose to change deadlines
related to the late exercise of options on an option’s
expiration date.
7 A line item is an exercise instruction which
includes the account, series, and quantity to be
exercised.
8 See Notice of Filing, 85 FR at 5492.
9 See Notice of Filing, 85 FR at 5492, n. 10. OCC
also stated that the amount of late exercises notices
received since 2017 was significantly more than the
preceding seven years. See Notice of Filing, 85 FR
at 5492.
10 See Securities Exchange Act Release No. 57584
(Mar. 31, 2008), 73 FR 18844 (Apr. 7, 2008) (SR–
OCC–2007–016); Notice of Filing, 85 FR at 5492.
11 See Notice of Filing, 85 FR at 5492.
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Federal Register / Vol. 85, No. 45 / Friday, March 6, 2020 / Notices
Members to be especially diligent in
processing exercise notices while at the
same time still allowing firms to correct
bona fide errors.12
OCC’s Rule 801(d) defines the
deadline for submitting late exercise
notices for exercises other than at
expiration. Under its current rules, OCC
will not accept a late exercise notice
received after 6:30 a.m. CT, and Clearing
Members assigned late exercises must
be notified by 8:00 a.m. CT.13 OCC’s
rules, therefore, may provide OCC with
as little as 90 minutes to accommodate
an exception to OCC’s standard option
exercise processes. OCC’s exception
process requires the (1) review of
Clearing Member positions, (2)
escalation of the request to submit a late
exercise notice to senior management,
(3) random assignment of late exercised
positions to Clearing Members, and (4)
communication to assigned Clearing
Members.14 OCC represented that the
90-minute period from 6:30 a.m. to 8:00
a.m. CT was a narrow window for OCC
staff to complete these steps, which are
necessary to properly process late
exercises and assignments, without
delays.15 As a result, in addition to
increasing the late exercise fee as
discussed above, OCC proposes to
change the deadline for submission of
late exercises to 6:00 a.m. CT to provide
an additional 30 minutes of processing
time. The OCC Roundtable discussed
the proposal described above and agreed
that it would be appropriate and in a
range to incentivize Clearing Members
to be especially diligent in processing
exercise notices while at the same time
still allowing firms to correct bona fide
errors.16
lotter on DSKBCFDHB2PROD with NOTICES
III. Discussion and Commission
Findings
Section 19(b)(2)(C) of the Exchange
Act directs the Commission to approve
a proposed rule change of a selfregulatory organization if it finds that
such proposed rule change is consistent
with the requirements of the Exchange
Act and the rules and regulations
thereunder applicable to such
organization.17 After carefully
considering the Proposed Rule Change,
the Commission finds 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
12 See
Notice of Filing, 85 FR at 5492.
OCC Rule 801(d)(2), available at https://
www.theocc.com/components/docs/legal/rules_
and_bylaws/occ_rules.pdf.
14 See Notice of Filing, 85 FR at 5492.
15 See Notice of Filing, 85 FR at 5492.
16 See Notice of Filing, 85 FR at 5492.
17 15 U.S.C. 78s(b)(2)(C).
13 See
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18:31 Mar 05, 2020
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finds that the proposal is consistent
with Sections 17A(b)(3)(D) and
17A(b)(3)(F) of the Exchange Act.18
A. Consistency With Section
17A(b)(3)(D) of the Exchange Act
Section 17A(b)(3)(D) of the Exchange
Act requires that the rules of a clearing
agency provide for the equitable
allocation of reasonable dues, fees, and
other charges among its participants.19
Based on its review of the record, the
Commission believes that the proposed
increase in the late exercise notice fee
is reasonable for the reasons described
below.
As described above, under Rules
801(d) and 805(g), the filing of a late
exercise notice may be deemed by OCC
to be a violation of OCC’s procedures
and could subject the Clearing Member
who submits such a filing to
disciplinary action, as well as a $75,000
late exercise fee. At the same time,
OCC’s Rules provide for a late exercise
process designed to allow OCC to
accommodate exceptions to its rules
governing the option exercise process
for bona fide errors. As noted above,
OCC observed that, despite subjecting
Clearing Members to the late exercise
fee and potentially subjecting them to
disciplinary action for violating OCC’s
procedures, Clearing Members were
nevertheless filing late exercise notices,
thereby securing the financial gains
associated with the captured dividends
on the securities underlying the late
exercised options.
OCC proposes to increase the late
exercise fee from $75,000 to $250,000
per line item. As noted above, OCC’s
determination to increase the late
exercise fee by this amount was based
on discussions at the 2017 OCC
Roundtable among representatives from
OCC’s participant exchanges, a crosssection of OCC Clearing Members, and
OCC staff regarding a potential increase
in the amount of the late exercise fee
that would be appropriate and in a
range to incentivize Clearing Members
to be especially diligent in processing
exercise notices while at the same time
still allowing firms to correct bona fide
errors.20 As part of those discussions,
Roundtable participants reviewed the
dollar amounts at issue in connection
with late exercises received in 2017,
which reflected the amount of
dividends received by the person
submitting the late exercise as a result
of receiving the underlying shares.
Based on these discussions, the
18 15
U.S.C. 78q–1(b)(3)(D) and 15 U.S.C. 78q–
1(b)(3)(F).
19 15 U.S.C. 78q–1(b)(3)(D).
20 See Notice of Filing, 85 FR at 5492.
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13199
Roundtable participants agreed that an
increase in the late exercise fee from the
current $75,000 fee per line item to
$250,000 fee per line item would be
appropriate and in a range to
accomplish the goals noted above.
The Commission understands that, as
part of OCC’s exception process, one of
the purposes of the late exercise fee is
to incent Clearing Members to be
especially diligent in complying with
OCC’s Rules regarding processing
exercise notices, while at the same time
preserving the ability of Clearing
Members to correct bona fide
operational errors in those relatively
rare instances when such a need
arises.21 To that end, as noted above,
OCC coordinated with relevant
stakeholders to discuss the relevant
information and determine the level of
fees related to late exercise notices that
would strike an appropriate balance
between these goals. The Commission
views OCC’s efforts in this regard as
reasonable. Likewise, given that
dividends captured through the late
exercise process in 2017 and 2019
ranged from $93,600 to $436,800, the
Commission believes that OCC’s
proposal to adopt the consensus
recommendation from the 2017 OCC
Roundtable to raise the late exercise fee
to $250,000 is equally reasonable.
Taken together, and given the purpose
of the late exercise fee and the financial
incentives represented by such
dividends, the Commission believes that
the proposed increase to $250,000 per
line item for late exercise notices is
reasonable and, therefore, is consistent
with the requirements of Section
17A(b)(3)(D) of the Exchange Act.22
B. 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 promote the prompt and
accurate clearance and settlement of
securities transactions.23 Based on its
review of the record, the Commission
believes that the proposed change to the
deadline for submitting late exercise
notices is consistent with the promotion
of prompt and accurate clearance and
settlement of securities transactions for
the reasons described below.
As described above, the late exercise
notice process is designed to
accommodate exceptions for bona fide
errors to the routine options exercise
21 See Securities Exchange Act Release No. 57584
(Mar. 31, 2008), 73 FR 18844 (Apr. 7, 2008) (SR–
OCC–2007–016); Notice of Filing, 85 FR at 5492.
22 15 U.S.C. 78q–1(b)(3)(D).
23 15 U.S.C. 78q–1(b)(3)(F).
E:\FR\FM\06MRN1.SGM
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Federal Register / Vol. 85, No. 45 / Friday, March 6, 2020 / Notices
process. OCC’s current rules may
provide as little as 90 minutes to
process late exercise notices. Processing
such notices requires a number of
procedural steps, including the
notification of Clearing Members
affected by the random assignment of
late exercises. The Commission believes
that successful and timely completion of
exercise and assignment processes is
important to the prompt and accurate
settlement of securities transactions.
The Commission further believes that
providing an additional 30 minutes to
facilitate the processing of late exercises
and assignments without delay would
promote the prompt and accurate
clearance and settlement of securities
transactions and is, therefore, consistent
with the requirements of Section
17A(b)(3)(F) of the Exchange Act.24
IV. Conclusion
On the basis of the foregoing, the
Commission finds that the Proposed
Rule Change is consistent with the
requirements of the Exchange Act, and
in particular, the requirements of
Section 17A of the Exchange Act 25 and
the rules and regulations thereunder.
It is therefore ordered, pursuant to
Section 19(b)(2) of the Exchange Act,26
that the Proposed Rule Change (SR–
OCC–2020–001) be, and hereby is,
approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.27
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020–04576 Filed 3–5–20; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–88308; File No. SR–ICEEU–
2020–003]
Self-Regulatory Organizations; ICE
Clear Europe Limited; Notice of Filing
of Proposed Rule Change, SecurityBased Swap Submission or Advance
Notice Relating to the ICE Clear
Europe Rules and Procedures
March 2, 2020.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 and Rule 19b–4 thereunder,2
lotter on DSKBCFDHB2PROD with NOTICES
24 15
U.S.C. 78q–1(b)(3)(F).
approving this Proposed Rule Change, the
Commission has considered the proposed rules’
impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
26 15 U.S.C. 78s(b)(2).
27 17 CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
25 In
VerDate Sep<11>2014
18:31 Mar 05, 2020
Jkt 250001
notice is hereby given that on February
18, 2020, ICE Clear Europe Limited
(‘‘ICE Clear Europe’’ or the ‘‘Clearing
House’’) filed with the Securities and
Exchange Commission (‘‘Commission’’)
the proposed rule changes described in
Items I, II and III below, which Items
have been prepared by ICE Clear
Europe. The Commission is publishing
this notice to solicit comments on the
proposed rule change from interested
persons.
I. Clearing Agency’s Statement of the
Terms of Substance of the Proposed
Rule Change, Security-Based Swap
Submission, or Advance Notice
ICE Clear Europe Limited proposes to
revise its Clearing Rules (the ‘‘Rules’’),3
the Standard Terms contained in the
annexes to the Rules, the Clearing
Procedures, Finance Procedures,
Delivery Procedures, CDS Procedures,
FX Procedures, Complaint Resolution
Procedures, Business Continuity
Procedures, Membership Procedures,
and General Contract Terms
(collectively, the ‘‘Amended
Documents’’) to make various updates
and enhancements.
II. Clearing Agency’s Statement of the
Purpose of, and Statutory Basis for, the
Proposed Rule Change, Security-Based
Swap Submission or Advance Notice
In its filing with the Commission, ICE
Clear Europe included statements
concerning the purpose of and basis for
the proposed rule change and discussed
any comments it received on the
proposed rule change. The text of these
statements may be examined at the
places specified in Item IV below. ICE
Clear Europe has prepared summaries,
set forth in sections (A), (B), and (C)
below, of the most significant aspects of
such statements.
make certain amendments to the
variation and mark-to-market margin
settlement process (and related
calculations) in order to facilitate
treatment of such margin as a settlement
payment rather than collateral for
purposes of Clearing Member capital
calculations, (4) to revise certain
provisions relating to option settlement
to enhance clarity and reflect
operational procedures, (5) to revise
certain disciplinary and complaints
procedures, (6) to add certain provisions
relating to compliance with applicable
U.S. tax requirements, (7) to make
certain other default management
enhancement and clarifications, (8) to
update and clarify various aspects of the
Delivery Procedures and (9) to make
certain other drafting improvements and
clarifications, in each case as described
in further detail herein.
Specifically, ICE Clear Europe
proposes to make amendments to Parts
1, 2, 3, 4, 5, 7, 8, 9, 10 and 12 of the
Rules, the Customer-Clearing Member
Standard Terms contained in the
annexes to the Rules, and the Clearing
Procedures, Finance Procedures,
Delivery Procedures, CDS Procedures,
Complaint Resolution Procedures,
Business Continuity Procedures,
Membership Procedures and General
Contract Terms. The text of the
proposed Rule and Procedure
amendments is attached [sic] in Exhibits
5A–5J, with additions underlined and
deletions in strikethrough text. The
proposed Rule and Procedure
amendments are described in detail as
follows.
(a) Purpose
ICE Clear Europe is submitting
proposed amendments to the Amended
Documents that are intended to make a
variety of improvements and changes,
including (1) to enhance the customer
documentation framework for NonFCM/BD Clearing Members to facilitate
default management by the Clearing
House, (2) to adopt an ‘‘externalised
payments mechanism’’ to facilitate
making certain payments to and from
Clearing Members outside of the
standard net settlement process, (3) to
(i) Customer Documentation Framework
Changes have been proposed to
strengthen the legal foundations for the
Standard Terms, which form part of the
ICE Clear Europe customer
documentation framework for NonFCM/BD Clearing Members.4 The
existing Standard Terms promote postdefault porting in the case of a NonFCM/BD Clearing Member default
through contractual provisions that bind
Customers and Clearing Members.
These provisions are designed to limit
interference with the porting process
and give additional comfort that margin
is transferred by Customers to Clearing
Members on terms that allow usage and
porting of margin and positions.
Purported close-out actions by the
Customer against a defaulting Clearing
Member prior to porting are also
restricted, so that all terminations and
re-establishments of cleared contracts
occur at the same time and at the same
3 Capitalized terms used but not defined herein
have the meanings specified in the Rules.
4 The Standard Terms do not apply to FCM/BD
Clearing Members and their customers.
(A) Clearing Agency’s Statement of the
Purpose of, and Statutory Basis for, the
Proposed Rule Change, Security-Based
Swap Submission or Advance Notice
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E:\FR\FM\06MRN1.SGM
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Agencies
[Federal Register Volume 85, Number 45 (Friday, March 6, 2020)]
[Notices]
[Pages 13198-13200]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-04576]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-88310; File No. SR-OCC-2020-001]
Self-Regulatory Organizations; The Options Clearing Corporation;
Order Approving Proposed Rule Change To Modify the Fees for Exercise
Notices Submitted After the Deadlines and To Change the Deadline for
Submitting a Late Exercise Notice on Non-Expiration Dates
March 2, 2020.
I. Introduction
On January 14, 2020, the Options Clearing Corporation (``OCC'')
filed with the Securities and Exchange Commission (``Commission'') the
proposed rule change SR-OCC-2020-001 (``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 modify the fee
imposed for submitting a late exercise notice and change the deadline
by which such a notice must be submitted on non-expiration dates.\3\
The Proposed Rule Change was published for public comment in the
Federal Register on January 30, 2020.\4\ The Commission has received no
comments regarding the Proposed Rule Change. 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 85 FR 5491.
\4\ Securities Exchange Act Release No. 88030 (Jan. 24, 2020),
85 FR 5491 (Jan. 30, 2020) (SR-OCC-2020-001) (``Notice of Filing'').
---------------------------------------------------------------------------
II. Background
OCC's rules require Clearing Members to submit option exercise
notices within the timeframes prescribed by OCC. OCC's rules provide
for an exception process to accommodate exercise notices submitted
outside of such timeframes solely for the purpose of correcting a bona
fide error on the part of a Clearing Member or customer.\5\ OCC's
process for accommodating late exercise notices includes, among other
things, a late filing fee and a final deadline by which any such notice
must be received by OCC. OCC proposes to amend its Rules 801 and 805 to
modify the fees for exercise notices submitted after the deadlines by
which all option exercise notices must be submitted and to change the
deadline for submitting a late exercise notice on non-expiration
dates.\6\
---------------------------------------------------------------------------
\5\ See OCC Rules 801 and 805, available at https://www.theocc.com/components/docs/legal/rules_and_bylaws/occ_rules.pdf.
\6\ OCC did not propose to change deadlines related to the late
exercise of options on an option's expiration date.
---------------------------------------------------------------------------
OCC's Rule 801 governs the exercise of an options on days other
than the option's expiration date. OCC's Rule 805 governs the exercise
of an option on the option's expiration date. Under OCC's Rule 801(d),
the filing of a late exercise notice by a Clearing Member may be deemed
a violation of OCC's procedures and may subject the Clearing Member to
disciplinary action. Additionally, under OCC's Rule 801(d) and Rule
805(g), a Clearing Member submitting a late exercise notice is liable
to OCC for a $75,000 fee per line item listed on a late exercise
notice.\7\
---------------------------------------------------------------------------
\7\ A line item is an exercise instruction which includes the
account, series, and quantity to be exercised.
---------------------------------------------------------------------------
OCC observed that the Clearing Members submitting late exercise
notices in 2017 and 2019 captured dividends on the securities
underlying the late exercised options, thereby securing the financial
gains associated with such captured dividends.\8\ Further, OCC observed
that the amount of dividends captured ranged from $93,600 to
$436,800.\9\ OCC has previously stated that the late exercise fee is
intended as an incentive for Clearing Members to be especially diligent
in processing exercise notices and to improve back office procedures
while at the same time preserving their ability to correct bona fide
operational errors.\10\
---------------------------------------------------------------------------
\8\ See Notice of Filing, 85 FR at 5492.
\9\ See Notice of Filing, 85 FR at 5492, n. 10. OCC also stated
that the amount of late exercises notices received since 2017 was
significantly more than the preceding seven years. See Notice of
Filing, 85 FR at 5492.
\10\ See Securities Exchange Act Release No. 57584 (Mar. 31,
2008), 73 FR 18844 (Apr. 7, 2008) (SR-OCC-2007-016); Notice of
Filing, 85 FR at 5492.
---------------------------------------------------------------------------
On November 9, 2017, OCC discussed late exercise notices submitted
in 2017 at its OCC Roundtable, an OCC-sponsored advisory group
comprised of representatives from OCC's participant exchanges, a cross-
section of OCC Clearing Members, and OCC staff.\11\ The OCC Roundtable
participants noted the dollar amount at issue in connection with late
exercises received in 2017, which reflected the amount of dividends
received by the person submitting the late exercise as a result of
receiving the underlying shares. As a result of these discussions,
Roundtable participants agreed that an increase in the late exercise
fee from the current $75,000 fee per line item to $250,000 fee per line
item would be appropriate and in a range to incentivize Clearing
[[Page 13199]]
Members to be especially diligent in processing exercise notices while
at the same time still allowing firms to correct bona fide errors.\12\
---------------------------------------------------------------------------
\11\ See Notice of Filing, 85 FR at 5492.
\12\ See Notice of Filing, 85 FR at 5492.
---------------------------------------------------------------------------
OCC's Rule 801(d) defines the deadline for submitting late exercise
notices for exercises other than at expiration. Under its current
rules, OCC will not accept a late exercise notice received after 6:30
a.m. CT, and Clearing Members assigned late exercises must be notified
by 8:00 a.m. CT.\13\ OCC's rules, therefore, may provide OCC with as
little as 90 minutes to accommodate an exception to OCC's standard
option exercise processes. OCC's exception process requires the (1)
review of Clearing Member positions, (2) escalation of the request to
submit a late exercise notice to senior management, (3) random
assignment of late exercised positions to Clearing Members, and (4)
communication to assigned Clearing Members.\14\ OCC represented that
the 90-minute period from 6:30 a.m. to 8:00 a.m. CT was a narrow window
for OCC staff to complete these steps, which are necessary to properly
process late exercises and assignments, without delays.\15\ As a
result, in addition to increasing the late exercise fee as discussed
above, OCC proposes to change the deadline for submission of late
exercises to 6:00 a.m. CT to provide an additional 30 minutes of
processing time. The OCC Roundtable discussed the proposal described
above and agreed that it would be appropriate and in a range to
incentivize Clearing Members to be especially diligent in processing
exercise notices while at the same time still allowing firms to correct
bona fide errors.\16\
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\13\ See OCC Rule 801(d)(2), available at https://www.theocc.com/components/docs/legal/rules_and_bylaws/occ_rules.pdf.
\14\ See Notice of Filing, 85 FR at 5492.
\15\ See Notice of Filing, 85 FR at 5492.
\16\ See Notice of Filing, 85 FR at 5492.
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III. Discussion and Commission Findings
Section 19(b)(2)(C) of the Exchange Act directs the Commission to
approve a proposed rule change of a self-regulatory organization if it
finds that such proposed rule change is consistent with the
requirements of the Exchange Act and the rules and regulations
thereunder applicable to such organization.\17\ After carefully
considering the Proposed Rule Change, the Commission finds 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
Sections 17A(b)(3)(D) and 17A(b)(3)(F) of the Exchange Act.\18\
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\17\ 15 U.S.C. 78s(b)(2)(C).
\18\ 15 U.S.C. 78q-1(b)(3)(D) and 15 U.S.C. 78q-1(b)(3)(F).
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A. Consistency With Section 17A(b)(3)(D) of the Exchange Act
Section 17A(b)(3)(D) of the Exchange Act requires that the rules of
a clearing agency provide for the equitable allocation of reasonable
dues, fees, and other charges among its participants.\19\ Based on its
review of the record, the Commission believes that the proposed
increase in the late exercise notice fee is reasonable for the reasons
described below.
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\19\ 15 U.S.C. 78q-1(b)(3)(D).
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As described above, under Rules 801(d) and 805(g), the filing of a
late exercise notice may be deemed by OCC to be a violation of OCC's
procedures and could subject the Clearing Member who submits such a
filing to disciplinary action, as well as a $75,000 late exercise fee.
At the same time, OCC's Rules provide for a late exercise process
designed to allow OCC to accommodate exceptions to its rules governing
the option exercise process for bona fide errors. As noted above, OCC
observed that, despite subjecting Clearing Members to the late exercise
fee and potentially subjecting them to disciplinary action for
violating OCC's procedures, Clearing Members were nevertheless filing
late exercise notices, thereby securing the financial gains associated
with the captured dividends on the securities underlying the late
exercised options.
OCC proposes to increase the late exercise fee from $75,000 to
$250,000 per line item. As noted above, OCC's determination to increase
the late exercise fee by this amount was based on discussions at the
2017 OCC Roundtable among representatives from OCC's participant
exchanges, a cross-section of OCC Clearing Members, and OCC staff
regarding a potential increase in the amount of the late exercise fee
that would be appropriate and in a range to incentivize Clearing
Members to be especially diligent in processing exercise notices while
at the same time still allowing firms to correct bona fide errors.\20\
As part of those discussions, Roundtable participants reviewed the
dollar amounts at issue in connection with late exercises received in
2017, which reflected the amount of dividends received by the person
submitting the late exercise as a result of receiving the underlying
shares. Based on these discussions, the Roundtable participants agreed
that an increase in the late exercise fee from the current $75,000 fee
per line item to $250,000 fee per line item would be appropriate and in
a range to accomplish the goals noted above.
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\20\ See Notice of Filing, 85 FR at 5492.
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The Commission understands that, as part of OCC's exception
process, one of the purposes of the late exercise fee is to incent
Clearing Members to be especially diligent in complying with OCC's
Rules regarding processing exercise notices, while at the same time
preserving the ability of Clearing Members to correct bona fide
operational errors in those relatively rare instances when such a need
arises.\21\ To that end, as noted above, OCC coordinated with relevant
stakeholders to discuss the relevant information and determine the
level of fees related to late exercise notices that would strike an
appropriate balance between these goals. The Commission views OCC's
efforts in this regard as reasonable. Likewise, given that dividends
captured through the late exercise process in 2017 and 2019 ranged from
$93,600 to $436,800, the Commission believes that OCC's proposal to
adopt the consensus recommendation from the 2017 OCC Roundtable to
raise the late exercise fee to $250,000 is equally reasonable.
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\21\ See Securities Exchange Act Release No. 57584 (Mar. 31,
2008), 73 FR 18844 (Apr. 7, 2008) (SR-OCC-2007-016); Notice of
Filing, 85 FR at 5492.
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Taken together, and given the purpose of the late exercise fee and
the financial incentives represented by such dividends, the Commission
believes that the proposed increase to $250,000 per line item for late
exercise notices is reasonable and, therefore, is consistent with the
requirements of Section 17A(b)(3)(D) of the Exchange Act.\22\
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\22\ 15 U.S.C. 78q-1(b)(3)(D).
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B. 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 promote the
prompt and accurate clearance and settlement of securities
transactions.\23\ Based on its review of the record, the Commission
believes that the proposed change to the deadline for submitting late
exercise notices is consistent with the promotion of prompt and
accurate clearance and settlement of securities transactions for the
reasons described below.
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\23\ 15 U.S.C. 78q-1(b)(3)(F).
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As described above, the late exercise notice process is designed to
accommodate exceptions for bona fide errors to the routine options
exercise
[[Page 13200]]
process. OCC's current rules may provide as little as 90 minutes to
process late exercise notices. Processing such notices requires a
number of procedural steps, including the notification of Clearing
Members affected by the random assignment of late exercises. The
Commission believes that successful and timely completion of exercise
and assignment processes is important to the prompt and accurate
settlement of securities transactions. The Commission further believes
that providing an additional 30 minutes to facilitate the processing of
late exercises and assignments without delay would promote the prompt
and accurate clearance and settlement of securities transactions and
is, therefore, consistent with the requirements of Section 17A(b)(3)(F)
of the Exchange Act.\24\
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\24\ 15 U.S.C. 78q-1(b)(3)(F).
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IV. Conclusion
On the basis of the foregoing, the Commission finds that the
Proposed Rule Change is consistent with the requirements of the
Exchange Act, and in particular, the requirements of Section 17A of the
Exchange Act \25\ and the rules and regulations thereunder.
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\25\ In approving this Proposed Rule Change, the Commission has
considered the proposed rules' impact on efficiency, competition,
and capital formation. See 15 U.S.C. 78c(f).
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It is therefore ordered, pursuant to Section 19(b)(2) of the
Exchange Act,\26\ that the Proposed Rule Change (SR-OCC-2020-001) be,
and hereby is, approved.
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\26\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\27\
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\27\ 17 CFR 200.30-3(a)(12).
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J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020-04576 Filed 3-5-20; 8:45 am]
BILLING CODE 8011-01-P