Self-Regulatory Organizations; National Securities Clearing Corporation; Order Approving a Proposed Rule Change To Enhance the Calculation of the Family-Issued Securities Charge, 18615-18617 [2020-06849]
Download as PDF
Federal Register / Vol. 85, No. 64 / Thursday, April 2, 2020 / Notices
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 these
filings 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–IEX–2019–15 and should
be submitted on or before April 23,
2020. Rebuttal comments should be
submitted by May 7, 2020.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.34
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020–06856 Filed 4–1–20; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–88494; File No. SR–NSCC–
2020–002]
Self-Regulatory Organizations;
National Securities Clearing
Corporation; Order Approving a
Proposed Rule Change To Enhance
the Calculation of the Family-Issued
Securities Charge
jbell on DSKJLSW7X2PROD with NOTICES
March 27, 2020.
On January 28, 2020, 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–2020–
002 to enhance the calculation of the
34 17
CFR 200.30–3(a)(57).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
1 15
VerDate Sep<11>2014
18:34 Apr 01, 2020
Jkt 250001
Family-Issued Securities Charge.3 The
proposed rule change was published for
comment in the Federal Register on
February 18, 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.
I. Description of the Proposed Rule
Change
The proposed rule change would
revise NSCC’s Rules and Procedures
(‘‘Rules’’) 6 to amend the calculation of
NSCC’s existing margin charge applied
to long positions in Family-Issued
Securities to address certain risk
presented by these positions.
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 for each Member, which
serves as each Member’s margin.7 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 Member default and that
Member’s Required Fund Deposit, upon
liquidation, is insufficient to satisfy
NSCC’s losses.
Each Member’s Required Fund
Deposit consists of a number of
3 NSCC also filed the proposals contained in the
proposed rule change as advance notice SR–NSCC–
2020–801 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,
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 February 27, 2020.
Securities Exchange Act Release No. 88267
(February 24, 2020), 85 FR 11437 (February 27,
2020) (File No. SR–NSCC–2020–801).
4 Securities Exchange Act Release No. 88163
(February 11, 2020), 85 FR 8964 (February 18, 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.
6 Capitalized terms not defined herein are defined
in NSCC’s Rules and Procedures (‘‘Rules’’),
available at https://www.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, supra note 6.
PO 00000
Frm 00067
Fmt 4703
Sfmt 4703
18615
applicable components, each of which
is calculated to address specific risks
faced by NSCC.8 NSCC states that it
regularly assesses the market, liquidity,
and other risks that its margining
methodologies are designed to mitigate
to evaluate whether margin levels are
commensurate with the particular risk
attributes of each relevant product,
portfolio, and market.9 Such risks
include risks introduced by its
counterparties or Members. In
particular, NSCC seeks to identify and
mitigate its exposures to specific wrongway risk (‘‘SWWR’’), which is the risk
that an exposure to a counterparty is
highly likely to increase when the
creditworthiness of that counterparty
deteriorates. Such risk would arise
when NSCC acts as central counterparty
to a Member with unsettled long
positions in securities that were issued
by that Member or an affiliate of that
Member (‘‘Family-Issued Securities’’). If
that Member defaults, NSCC would seek
to cover its losses by closing out the
unsettled Family-Issued Securities long
positions. However, because the
Member default would also likely lead
to a drop in the creditworthiness of the
Member and, therefore, the value of the
Family-Issued Securities, NSCC would
likely not be able to completely cover its
losses in closing out those positions.
In order to address this particular
form of SWWR, NSCC imposes a charge
on all Members with unsettled long
positions in their own Family-Issued
Securities, called the FIS Charge, which
is calculated by multiplying the value of
the net unsettled long positions in
Family-Issued Securities by a certain
percentage (‘‘Haircut Rate’’). Currently,
the Haircut Rate applied in the FIS
Charge calculation is based on a
Member’s rating category on NSCC’s
Credit Risk Rating Matrix (‘‘CRRM’’),
which ranges from 1 to 7. NSCC utilizes
the CRRM to evaluate its credit risk
exposure to each Member; a higher
CRRM rating represents a higher credit
risk (i.e., a greater risk of defaulting on
settlement obligations) and may cause a
Member to be subject to enhanced
surveillance or additional margin
requirements.10
Currently, the applicable Haircut Rate
for the FIS Charge depends on a
Member’s rating on the CRRM.
8 Id.
9 See
Notice of Filing supra note 4, at 85 FR 8965.
Rule 1 and Section 4 of Rule 2B of the
Rules, supra note 6. See also Securities Exchange
Act Release Nos. 80734 (May 19, 2017), 82 FR
24177 (May 25, 2017) (SR–DTC–2017–002, SR–
FICC–2017–006, SR–NSCC–2017–002); and 80731
(May 19, 2017), 82 FR 24174 (May 25, 2017) (SR–
DTC–2017–801, SR–FICC–2017–804, SR–NSCC–
2017–801).
10 See
E:\FR\FM\02APN1.SGM
02APN1
18616
Federal Register / Vol. 85, No. 64 / Thursday, April 2, 2020 / Notices
Specifically, for Members that are rated
6 or 7 on the CRRM, the applicable
Haircut Rate for net unsettled long
positions in Family-Issued Securities
shall be (1) at least 80 percent for fixed
income securities, and (2) 100 percent
for equity securities. For Members that
are rated 1 through 5 on the CRRM, the
applicable Haircut Rate shall be (1) at
least 40 percent for fixed income
securities, and (2) at least 50 percent for
equity securities.11
B. Proposed Changes to FIS Charge
In the proposed rule change, NSCC is
proposing to revise the calculation of
the FIS Charge to use the same Haircut
Rate for all Members regardless of their
CRRM rating category. Under the
proposal, net unsettled long positions in
(1) fixed income securities that are
Family-Issued Securities are charged a
Haircut Rate of no less than 80 percent,
and (2) equity securities that are FamilyIssued Securities are charged a Haircut
Rate of 100 percent.
NSCC states that it may still be
exposed to SWWR despite applying
different Haircut Rates based on a
Member’s rating on the CRRM, and it
can better mitigate its exposure to this
risk by calculating the FIS Charge
without considering Members’ CRRM
rating categories.12 According to NSCC,
while the current methodology
appropriately assumes that Members
with a higher rating category on the
CRRM present a heightened credit risk
to NSCC or have demonstrated higher
risk related to their ability to meet
settlement, this methodology does not
account for the risk that a Member may
default due to unanticipated causes
(referred to as a ‘‘jump-to-default’’
scenario) not captured by the CRRM.13
This is because the CRRM relies on
historical data as a predictor of future
risks,14 whereas jump-to-default
scenarios are triggered by unanticipated
causes that could not be predicted based
on historical trends or data (e.g.,
instances of fraud or other bad actions
by a Member’s management). Therefore,
NSCC represents that the proposed
change is designed to cover SWWR
arising from potential jump-to-default
scenarios by applying the higher
applicable Haircut Rate in calculating
the FIS Charge for all Members.15
jbell on DSKJLSW7X2PROD with NOTICES
11 See
Procedure XV (Clearing Fund Formula and
Other Matters) of the Rules, supra note 6.
12 See Notice of Filing supra note 4, at 85 FR
8965.
13 See id.
14 See Notice of Filing supra note 4, at 85 FR
8965–66.
15 See Notice of Filing supra note 4, at 85 FR
8966.
VerDate Sep<11>2014
18:34 Apr 01, 2020
Jkt 250001
The practical outcome of this
proposed change is that for all FamilyIssued Securities, NSCC would apply a
haircut equivalent to the current Haircut
Rate for Members that are rated 6 or 7
on the CRRM regardless of whether a
Member is rated at a 6 or 7. To
implement this proposal, NSCC would
amend Sections I.(A)(1)(a)(iv) and
I.(A)(2)(a)(iv) of Procedure XV of the
Rules.
II. Discussion and Commission
Findings
Section 19(b)(2)(C) of the Act 16
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
17A(b)(3)(F) 17 of the Act and Rules
17Ad–22(e)(4)(i) and (e)(6)(i) and (v)
thereunder.18
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 to assure the
safeguarding of securities and funds
which are in the custody or control of
the clearing agency or for which it is
responsible.19
The Commission believes that the
proposal is consistent with the
promotion of prompt and accurate
clearance and settlement of securities
transactions. As described above, NSCC
faces SWWR when it acts as central
counterparty to a Member with long
positions in Family-Issued Securities.
Although NSCC’s current margin
methodology addresses SWWR through
imposition of the FIS Charge, it does not
address SWWR associated with a jumpto-default scenario. The proposal would
address SWWR associated with a jumpto-default scenario by using the higher
applicable Haircut Rate for all Members
concerning their net unsettled long
16 15
U.S.C. 78s(b)(2)(C).
U.S.C. 78q–1(b)(3)(F).
18 17 CFR 240.17Ad–22(e)(4)(i) and (e)(6)(i) and
(v).
19 15 U.S.C. 78q–1(b)(3)(F).
17 15
PO 00000
Frm 00068
Fmt 4703
Sfmt 4703
positions in Family-Issued Securities,
regardless of the Members’ CRRM rating
category. As such, the proposal would
address a risk not captured currently
under NSCC’s margin methodology and
provide for more comprehensive risk
management of NSCC’s risks. Further,
applying the higher applicable Haircut
Rate in calculating the FIS Charge for all
Members would result in the collection
of additional margin, which should, in
turn, better enable NSCC to manage the
potential losses arising out of a Member
default and continue operations of its
critical clearance and settlement
services in default scenarios.
Accordingly, the Commission finds that
NSCC’s proposal should help NSCC to
continue providing prompt and accurate
clearance and settlement of securities
transactions in the event of a Member
default.
The Commission also believes that the
proposal is consistent with assuring the
safeguarding of securities and funds
which are in the custody or control of
NSCC for which it is responsible. As
described above, the proposal would
allow NSCC to collect additional margin
to collateralize exposures to SWWR
associated with jump-to-default scenario
that NSCC may face when liquidating
Family-Issued Securities positions that
are depreciating in value in response to
a Member’s default. By expanding the
higher haircut rates to all Members, the
proposal would assist NSCC in
collecting margin and maintaining the
Clearing Fund that more precisely
reflects NSCC’s overall risk exposure to
its Members. By better limiting NSCC’s
exposure to Members, the proposal is
designed to help ensure that NSCC has
collected sufficient margin from
Members with long positions in FamilyIssued Securities, so that non-defaulting
Members would not be exposed to
mutualized losses as a result of a default
of a Member with long positions in
Family-Issued Securities. By helping to
limit non-defaulting Members’ exposure
to mutualized losses, the proposal is
designed to help assure the safeguarding
of securities and funds which are in
NSCC’s custody or control. For the
reasons stated above, the Commission
believes that the Proposed Rule Change
is consistent with the requirements of
Section 17A(b)(3)(F) of the Act.20
B. Consistency With Rule 17Ad–
22(e)(4)(i)
Rule 17Ad–22(e)(4)(i) under the Act
requires that each covered clearing
agency establish, implement, maintain
and enforce written policies and
procedures reasonably designed to
20 15
E:\FR\FM\02APN1.SGM
U.S.C. 78q–1(b)(3)(F).
02APN1
Federal Register / Vol. 85, No. 64 / Thursday, April 2, 2020 / Notices
jbell on DSKJLSW7X2PROD with NOTICES
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.21
As described above, NSCC is exposed
to SWWR where it acts as central
counterparty for its Members’
transactions in Family-Issued Securities.
Applying the same higher Haircut Rate
to all Members with net long unsettled
positions in Family-Issued Securities,
regardless of their rating on the CRRM,
would help further mitigate NSCC’s
SWWR exposures, especially in a jumpto-default scenario. Thus, applying the
same Haircut Rate in the FIS charge
calculation is designed to help NSCC
collect sufficient financial resources to
help cover its credit exposures, with a
high degree of confidence, to those
Members seeking to clear and settle
transactions in Family-Issued Securities.
Therefore, the Commission believes the
proposed change is consistent with Rule
17Ad–22(e)(4)(i).22
C. Consistency With Rules 17Ad–
22(e)(6)(i) and (v)
Rule 17Ad–22(e)(6)(i) under the Act
requires that each covered clearing
agency that provides central
counterparty services 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.23 Rule 17Ad–22(e)(6)(v) under
the Act requires that each covered
clearing agency that provides central
counterparty services 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.24
As described above, NSCC faces
SWWR in jump-to-default scenarios
where it acts as central counterparty to
Member transactions in Family-Issued
Securities. This risk is present
21 17
CFR 240.17Ad–22(e)(4)(i).
22 Id.
23 17
24 17
CFR 240.17Ad–22(e)(6)(i).
CFR 240.17Ad–22(e)(6)(v).
VerDate Sep<11>2014
18:34 Apr 01, 2020
Jkt 250001
regardless of a Member’s rating on the
CRRM. However, the current
methodology assumes that Members
with a higher rating on the CRRM
present a heightened credit risk to NSCC
and applies a higher Haircut Rate to
such Members. This distinction does
not take into account the SWWR that
would manifest in a jump-to-default
scenario. As such, NSCC proposes to
apply the same higher Haircut Rate to
all Members. This proposal would
improve NSCC’s ability to mitigate its
exposure to SWWR in a jump-to-default
scenario, thereby helping NSCC to
maintain a risk-based margin system
that considers, and produces margin
levels commensurate with, the risks and
particular attributes of net unsettled
long positions in Family-Issued
Securities. Therefore, the Commission
believes that the proposal would be
consistent with Rule 17Ad–22(e)(6)(i).25
Additionally, because the enhanced
FIS Charge would be a component of the
margin that NSCC collects from its
Members to help cover NSCC credit
exposure to the Members, and because
the charge would be based on different
product risk factors with respect to
equity and fixed-income securities, it
would be part of an appropriate method
for measuring credit exposure that
accounts for relevant product risk
factors and portfolio effects across
products, as described above. Therefore,
the Commission believes the proposed
change is consistent with Rule 17Ad–
22(e)(6)(v).26
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 27 and the rules
and regulations promulgated
thereunder.
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act 28 that
proposed rule change SR–NSCC–2020–
002, be, and hereby is, approved.29
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.30
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020–06849 Filed 4–1–20; 8:45 am]
BILLING CODE 8011–01–P
25 17
CFR 240.17Ad–22(e)(6)(i).
CFR 240.17Ad–22(e)(6)(v).
27 15 U.S.C. 78q–1.
28 15 U.S.C. 78s(b)(2).
29 In approving the proposed rule change, the
Commission considered the proposals’ impact on
efficiency, competition, and capital formation. 15
U.S.C. 78c(f).
30 17 CFR 200.30–3(a)(12).
26 17
PO 00000
Frm 00069
Fmt 4703
Sfmt 4703
18617
SECURITIES AND EXCHANGE
COMMISSION
[Securities Exchange Act of 1934; Release
No. 88493/March 27, 2020]
In the Matter of the BOX Exchange LLC
Regarding Proposed Rule Changes To
Amend the Fee Schedule on the BOX
Market LLC Options Facility To
Establish BOX Connectivity Fees for
Participants and Non-Participants Who
Connect to the BOX Network (File Nos.
SR–BOX–2018–24, SR–BOX–2018–37,
and SR–BOX–2019–04); Order
Affirming Action by Delegated
Authority and Disapproving Proposed
Rule Changes Related to Connectivity
and Port Fee
This matter comes before the
Securities and Exchange Commission
(‘‘Commission’’) on a petition to review
the Division of Trading and Markets’s
disapproval, by delegated authority, of
proposed rule changes filed by the BOX
Exchange LLC (‘‘BOX’’ or ‘‘Exchange’’).
BOX proposed to amend the fee
schedule on the BOX options facility to
establish certain connectivity fees and
reclassify its high-speed vendor feed
connection as a port fee (File Nos. SR–
BOX–2018–24, SR–BOX–2018–37, and
SR–BOX–2019–04). The three filings
propose identical rule changes.
The Division of Trading and Markets,
acting for the Commission pursuant to
delegated authority, disapproved the
proposed rule changes. Pursuant to
Section 4A of the Securities Exchange
Act of 1934, and Commission Rules of
Practice 430 and 431, we have
conducted a de novo review of the
record. For the reasons discussed below,
we conclude that BOX has not met its
burden to demonstrate that the
proposed rule changes are consistent
with the Exchange Act. Nor do BOX’s
other arguments convince us that its
proposed rule changes should be
approved. Accordingly, we disapprove
the proposed rule changes.
I. Background
A. The Proposed Rule Changes
1. BOX 1
On July 19, 2018, BOX filed with the
Commission, pursuant to Section
19(b)(1) of the Securities Exchange Act
of 1934 and Rule 19b–4 thereunder,1 a
proposed rule change to amend the BOX
fee schedule to establish certain
connectivity fees and to reclassify its
high speed vendor feed connection fee
as a port fee (SR–BOX–2018–24) (‘‘BOX
1’’). BOX 1 was immediately effective
upon filing with the Commission
1 15
E:\FR\FM\02APN1.SGM
U.S.C. 78s(b)(1); 17 CFR 240.19b–4.
02APN1
Agencies
[Federal Register Volume 85, Number 64 (Thursday, April 2, 2020)]
[Notices]
[Pages 18615-18617]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-06849]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-88494; File No. SR-NSCC-2020-002]
Self-Regulatory Organizations; National Securities Clearing
Corporation; Order Approving a Proposed Rule Change To Enhance the
Calculation of the Family-Issued Securities Charge
March 27, 2020.
On January 28, 2020, 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-2020-002 to enhance the calculation of the
Family-Issued Securities Charge.\3\ The proposed rule change was
published for comment in the Federal Register on February 18, 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-2020-801 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, 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 February 27, 2020. Securities Exchange Act
Release No. 88267 (February 24, 2020), 85 FR 11437 (February 27,
2020) (File No. SR-NSCC-2020-801).
\4\ Securities Exchange Act Release No. 88163 (February 11,
2020), 85 FR 8964 (February 18, 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 amend the calculation of NSCC's existing margin
charge applied to long positions in Family-Issued Securities to address
certain risk presented by these positions.
---------------------------------------------------------------------------
\6\ Capitalized terms not defined herein are defined in NSCC's
Rules and Procedures (``Rules''), available at https://www.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 for each Member, which serves as each Member's
margin.\7\ 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
Member default and that Member's Required Fund Deposit, upon
liquidation, is insufficient to satisfy NSCC's losses.
---------------------------------------------------------------------------
\7\ See Rule 4 (Clearing Fund) and Procedure XV (Clearing Fund
Formula and Other Matters) of the Rules, supra note 6.
---------------------------------------------------------------------------
Each Member's Required Fund Deposit consists of a number of
applicable components, each of which is calculated to address specific
risks faced by NSCC.\8\ NSCC states that it regularly assesses the
market, liquidity, and other risks that its margining methodologies are
designed to mitigate to evaluate whether margin levels are commensurate
with the particular risk attributes of each relevant product,
portfolio, and market.\9\ Such risks include risks introduced by its
counterparties or Members. In particular, NSCC seeks to identify and
mitigate its exposures to specific wrong-way risk (``SWWR''), which is
the risk that an exposure to a counterparty is highly likely to
increase when the creditworthiness of that counterparty deteriorates.
Such risk would arise when NSCC acts as central counterparty to a
Member with unsettled long positions in securities that were issued by
that Member or an affiliate of that Member (``Family-Issued
Securities''). If that Member defaults, NSCC would seek to cover its
losses by closing out the unsettled Family-Issued Securities long
positions. However, because the Member default would also likely lead
to a drop in the creditworthiness of the Member and, therefore, the
value of the Family-Issued Securities, NSCC would likely not be able to
completely cover its losses in closing out those positions.
---------------------------------------------------------------------------
\8\ Id.
\9\ See Notice of Filing supra note 4, at 85 FR 8965.
---------------------------------------------------------------------------
In order to address this particular form of SWWR, NSCC imposes a
charge on all Members with unsettled long positions in their own
Family-Issued Securities, called the FIS Charge, which is calculated by
multiplying the value of the net unsettled long positions in Family-
Issued Securities by a certain percentage (``Haircut Rate'').
Currently, the Haircut Rate applied in the FIS Charge calculation is
based on a Member's rating category on NSCC's Credit Risk Rating Matrix
(``CRRM''), which ranges from 1 to 7. NSCC utilizes the CRRM to
evaluate its credit risk exposure to each Member; a higher CRRM rating
represents a higher credit risk (i.e., a greater risk of defaulting on
settlement obligations) and may cause a Member to be subject to
enhanced surveillance or additional margin requirements.\10\
---------------------------------------------------------------------------
\10\ See Rule 1 and Section 4 of Rule 2B of the Rules, supra
note 6. See also Securities Exchange Act Release Nos. 80734 (May 19,
2017), 82 FR 24177 (May 25, 2017) (SR-DTC-2017-002, SR-FICC-2017-
006, SR-NSCC-2017-002); and 80731 (May 19, 2017), 82 FR 24174 (May
25, 2017) (SR-DTC-2017-801, SR-FICC-2017-804, SR-NSCC-2017-801).
---------------------------------------------------------------------------
Currently, the applicable Haircut Rate for the FIS Charge depends
on a Member's rating on the CRRM.
[[Page 18616]]
Specifically, for Members that are rated 6 or 7 on the CRRM, the
applicable Haircut Rate for net unsettled long positions in Family-
Issued Securities shall be (1) at least 80 percent for fixed income
securities, and (2) 100 percent for equity securities. For Members that
are rated 1 through 5 on the CRRM, the applicable Haircut Rate shall be
(1) at least 40 percent for fixed income securities, and (2) at least
50 percent for equity securities.\11\
---------------------------------------------------------------------------
\11\ See Procedure XV (Clearing Fund Formula and Other Matters)
of the Rules, supra note 6.
---------------------------------------------------------------------------
B. Proposed Changes to FIS Charge
In the proposed rule change, NSCC is proposing to revise the
calculation of the FIS Charge to use the same Haircut Rate for all
Members regardless of their CRRM rating category. Under the proposal,
net unsettled long positions in (1) fixed income securities that are
Family-Issued Securities are charged a Haircut Rate of no less than 80
percent, and (2) equity securities that are Family-Issued Securities
are charged a Haircut Rate of 100 percent.
NSCC states that it may still be exposed to SWWR despite applying
different Haircut Rates based on a Member's rating on the CRRM, and it
can better mitigate its exposure to this risk by calculating the FIS
Charge without considering Members' CRRM rating categories.\12\
According to NSCC, while the current methodology appropriately assumes
that Members with a higher rating category on the CRRM present a
heightened credit risk to NSCC or have demonstrated higher risk related
to their ability to meet settlement, this methodology does not account
for the risk that a Member may default due to unanticipated causes
(referred to as a ``jump-to-default'' scenario) not captured by the
CRRM.\13\ This is because the CRRM relies on historical data as a
predictor of future risks,\14\ whereas jump-to-default scenarios are
triggered by unanticipated causes that could not be predicted based on
historical trends or data (e.g., instances of fraud or other bad
actions by a Member's management). Therefore, NSCC represents that the
proposed change is designed to cover SWWR arising from potential jump-
to-default scenarios by applying the higher applicable Haircut Rate in
calculating the FIS Charge for all Members.\15\
---------------------------------------------------------------------------
\12\ See Notice of Filing supra note 4, at 85 FR 8965.
\13\ See id.
\14\ See Notice of Filing supra note 4, at 85 FR 8965-66.
\15\ See Notice of Filing supra note 4, at 85 FR 8966.
---------------------------------------------------------------------------
The practical outcome of this proposed change is that for all
Family-Issued Securities, NSCC would apply a haircut equivalent to the
current Haircut Rate for Members that are rated 6 or 7 on the CRRM
regardless of whether a Member is rated at a 6 or 7. To implement this
proposal, NSCC would amend Sections I.(A)(1)(a)(iv) and I.(A)(2)(a)(iv)
of Procedure XV of the Rules.
II. Discussion and Commission Findings
Section 19(b)(2)(C) of the Act \16\ 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 17A(b)(3)(F) \17\ of the Act and Rules 17Ad-22(e)(4)(i) and
(e)(6)(i) and (v) thereunder.\18\
---------------------------------------------------------------------------
\16\ 15 U.S.C. 78s(b)(2)(C).
\17\ 15 U.S.C. 78q-1(b)(3)(F).
\18\ 17 CFR 240.17Ad-22(e)(4)(i) and (e)(6)(i) and (v).
---------------------------------------------------------------------------
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
to assure the safeguarding of securities and funds which are in the
custody or control of the clearing agency or for which it is
responsible.\19\
---------------------------------------------------------------------------
\19\ 15 U.S.C. 78q-1(b)(3)(F).
---------------------------------------------------------------------------
The Commission believes that the proposal is consistent with the
promotion of prompt and accurate clearance and settlement of securities
transactions. As described above, NSCC faces SWWR when it acts as
central counterparty to a Member with long positions in Family-Issued
Securities. Although NSCC's current margin methodology addresses SWWR
through imposition of the FIS Charge, it does not address SWWR
associated with a jump-to-default scenario. The proposal would address
SWWR associated with a jump-to-default scenario by using the higher
applicable Haircut Rate for all Members concerning their net unsettled
long positions in Family-Issued Securities, regardless of the Members'
CRRM rating category. As such, the proposal would address a risk not
captured currently under NSCC's margin methodology and provide for more
comprehensive risk management of NSCC's risks. Further, applying the
higher applicable Haircut Rate in calculating the FIS Charge for all
Members would result in the collection of additional margin, which
should, in turn, better enable NSCC to manage the potential losses
arising out of a Member default and continue operations of its critical
clearance and settlement services in default scenarios. Accordingly,
the Commission finds that NSCC's proposal should help NSCC to continue
providing prompt and accurate clearance and settlement of securities
transactions in the event of a Member default.
The Commission also believes that the proposal is consistent with
assuring the safeguarding of securities and funds which are in the
custody or control of NSCC for which it is responsible. As described
above, the proposal would allow NSCC to collect additional margin to
collateralize exposures to SWWR associated with jump-to-default
scenario that NSCC may face when liquidating Family-Issued Securities
positions that are depreciating in value in response to a Member's
default. By expanding the higher haircut rates to all Members, the
proposal would assist NSCC in collecting margin and maintaining the
Clearing Fund that more precisely reflects NSCC's overall risk exposure
to its Members. By better limiting NSCC's exposure to Members, the
proposal is designed to help ensure that NSCC has collected sufficient
margin from Members with long positions in Family-Issued Securities, so
that non-defaulting Members would not be exposed to mutualized losses
as a result of a default of a Member with long positions in Family-
Issued Securities. By helping to limit non-defaulting Members' exposure
to mutualized losses, the proposal is designed to help assure the
safeguarding of securities and funds which are in NSCC's custody or
control. For the reasons stated above, the Commission believes that the
Proposed Rule Change is consistent with the requirements of Section
17A(b)(3)(F) of the Act.\20\
---------------------------------------------------------------------------
\20\ 15 U.S.C. 78q-1(b)(3)(F).
---------------------------------------------------------------------------
B. Consistency With Rule 17Ad-22(e)(4)(i)
Rule 17Ad-22(e)(4)(i) under the Act requires that each covered
clearing agency establish, implement, maintain and enforce written
policies and procedures reasonably designed to
[[Page 18617]]
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.\21\
---------------------------------------------------------------------------
\21\ 17 CFR 240.17Ad-22(e)(4)(i).
---------------------------------------------------------------------------
As described above, NSCC is exposed to SWWR where it acts as
central counterparty for its Members' transactions in Family-Issued
Securities. Applying the same higher Haircut Rate to all Members with
net long unsettled positions in Family-Issued Securities, regardless of
their rating on the CRRM, would help further mitigate NSCC's SWWR
exposures, especially in a jump-to-default scenario. Thus, applying the
same Haircut Rate in the FIS charge calculation is designed to help
NSCC collect sufficient financial resources to help cover its credit
exposures, with a high degree of confidence, to those Members seeking
to clear and settle transactions in Family-Issued Securities.
Therefore, the Commission believes the proposed change is consistent
with Rule 17Ad-22(e)(4)(i).\22\
---------------------------------------------------------------------------
\22\ Id.
---------------------------------------------------------------------------
C. Consistency With Rules 17Ad-22(e)(6)(i) and (v)
Rule 17Ad-22(e)(6)(i) under the Act requires that each covered
clearing agency that provides central counterparty services 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.\23\ Rule 17Ad-22(e)(6)(v) under the Act requires that each
covered clearing agency that provides central counterparty services
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.\24\
---------------------------------------------------------------------------
\23\ 17 CFR 240.17Ad-22(e)(6)(i).
\24\ 17 CFR 240.17Ad-22(e)(6)(v).
---------------------------------------------------------------------------
As described above, NSCC faces SWWR in jump-to-default scenarios
where it acts as central counterparty to Member transactions in Family-
Issued Securities. This risk is present regardless of a Member's rating
on the CRRM. However, the current methodology assumes that Members with
a higher rating on the CRRM present a heightened credit risk to NSCC
and applies a higher Haircut Rate to such Members. This distinction
does not take into account the SWWR that would manifest in a jump-to-
default scenario. As such, NSCC proposes to apply the same higher
Haircut Rate to all Members. This proposal would improve NSCC's ability
to mitigate its exposure to SWWR in a jump-to-default scenario, thereby
helping NSCC to maintain a risk-based margin system that considers, and
produces margin levels commensurate with, the risks and particular
attributes of net unsettled long positions in Family-Issued Securities.
Therefore, the Commission believes that the proposal would be
consistent with Rule 17Ad-22(e)(6)(i).\25\
---------------------------------------------------------------------------
\25\ 17 CFR 240.17Ad-22(e)(6)(i).
---------------------------------------------------------------------------
Additionally, because the enhanced FIS Charge would be a component
of the margin that NSCC collects from its Members to help cover NSCC
credit exposure to the Members, and because the charge would be based
on different product risk factors with respect to equity and fixed-
income securities, it would be part of an appropriate method for
measuring credit exposure that accounts for relevant product risk
factors and portfolio effects across products, as described above.
Therefore, the Commission believes the proposed change is consistent
with Rule 17Ad-22(e)(6)(v).\26\
---------------------------------------------------------------------------
\26\ 17 CFR 240.17Ad-22(e)(6)(v).
---------------------------------------------------------------------------
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 \27\ and
the rules and regulations promulgated thereunder.
---------------------------------------------------------------------------
\27\ 15 U.S.C. 78q-1.
---------------------------------------------------------------------------
It is therefore ordered, pursuant to Section 19(b)(2) of the Act
\28\ that proposed rule change SR-NSCC-2020-002, be, and hereby is,
approved.\29\
---------------------------------------------------------------------------
\28\ 15 U.S.C. 78s(b)(2).
\29\ In approving the proposed rule change, the Commission
considered the proposals' impact on efficiency, competition, and
capital formation. 15 U.S.C. 78c(f).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\30\
---------------------------------------------------------------------------
\30\ 17 CFR 200.30-3(a)(12).
---------------------------------------------------------------------------
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020-06849 Filed 4-1-20; 8:45 am]
BILLING CODE 8011-01-P