Order Granting Exemptions From Sections 8 and 15(a)(1) of the Securities Exchange Act of 1934 and Rules 3b-13(b)(2), 8c-1, 10b-10, 15a-1(c), 15a-1(d) and 15c2-1 Thereunder in Connection With the Revision of the Definition of “Security” To Encompass Security-Based Swaps and Determining the Expiration Date for a Temporary Exemption From Section 29(b) of the Securities Exchange Act of 1934 in Connection With Registration of Security-Based Swap Dealers and Major Security-Based Swap Participants, 70667-70678 [2020-24598]
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Federal Register / Vol. 85, No. 215 / Thursday, November 5, 2020 / Notices
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–90308; File Nos. S7–27–
11 and S7–24–11]
Order Granting Exemptions From
Sections 8 and 15(a)(1) of the
Securities Exchange Act of 1934 and
Rules 3b–13(b)(2), 8c–1, 10b–10, 15a–
1(c), 15a–1(d) and 15c2–1 Thereunder
in Connection With the Revision of the
Definition of ‘‘Security’’ To Encompass
Security-Based Swaps and
Determining the Expiration Date for a
Temporary Exemption From Section
29(b) of the Securities Exchange Act of
1934 in Connection With Registration
of Security-Based Swap Dealers and
Major Security-Based Swap
Participants
November 2, 2020.
I. Exemptions in Connection With the
Revision of the Definition of ‘‘Security’’
To Encompass Security-Based Swaps
A. Background
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Title VII of the Dodd-Frank Wall
Street Reform and Consumer Protection
Act 1 amended the definition of
‘‘security’’ under the Exchange Act to
expressly encompass security-based
swaps. The expansion of the definition
of the term ‘‘security’’ to include
security-based swaps had the effect of
changing the scope of the Exchange Act
regulatory provisions that apply to
security-based swaps and, in doing so,
raised certain complex questions that
required further consideration. In July
2011, the Commission issued an order,
granting temporary exemptions from
compliance with certain provisions of
the Exchange Act, and the rules and
regulations thereunder.2 The overall
1 Dodd-Frank Wall Street Reform and Consumer
Protection Act, Public Law 111–203, 124 Stat. 1376
(2010) (‘‘Dodd-Frank Act’’).
2 See Order Granting Temporary Exemptions
under the Securities Exchange Act of 1934 in
Connection with the Pending Revisions of the
Definition of ‘‘Security’’ to Encompass SecurityBased Swaps, Exchange Act Release No. 64795 (Jul.
1, 2011), 76 FR 39927 (Jul. 7, 2011) (‘‘2011
Exchange Act Exemptive Order’’). The 2011
Exchange Act Exemptive Order included two
relevant exemptions. First, the Commission granted
to any person who meets the definition of ‘‘eligible
contract participant’’ set forth in Section 1a(12) of
the Commodity Exchange Act as in effect on July
20, 2010 (i.e., the day prior to the date the DoddFrank Act was signed into law) and who is not a
registered broker or dealer or a self-regulatory
organization a temporary exemption from certain
provisions of the Exchange Act, and the rules and
regulations thereunder, solely in connection with
the person’s activities involving security-based
swaps. This temporary exemption was made
available to a broker or dealer registered under
Exchange Act Section 15(b)(11) and to a selfregulatory organization in limited circumstances.
Second, the Commission granted to a broker or
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approach of that order was directed
toward maintaining the status quo
during the implementation process for
the Dodd-Frank Act.3
The Commission in 2011 set the
temporary exemptions to expire on the
compliance date for final rules defining
the terms ‘‘security-based swap’’ and
‘‘eligible contract participant,’’ 4 and
since that time periodically has
extended this deadline.5 Notably, in
dealer registered under Section 15(b) of the
Exchange Act (other than a broker or dealer
registered under Section 15(b)(11) of the Exchange
Act), a temporary exemption from certain
provisions of the Exchange Act, and the rules and
regulations thereunder, solely with respect to
security-based swaps. See 2011 Exchange Act
Exemptive Order, 76 FR at 39938–39. The 2011
Exchange Act Exemptive Order did not provide
exemptive relief for any provisions or rules
prohibiting fraud, manipulation, or insider trading
(other than prophylactic reporting or recordkeeping
requirements such as the confirmation requirements
of Exchange Act Rule 10b–10). In addition, the 2011
Exchange Act Exemptive Order did not affect the
Commission’s investigative, enforcement, and
procedural authority related to those provisions and
rules. See 2011 Exchange Act Exemptive Order, 76
FR at 39931 n.34. The 2011 Exchange Act
Exemptive Order also did not address Sections 12,
13, 14, 15(d), 16, and 17A of the Exchange Act and
the rules and regulations thereunder.
3 See 2011 Exchange Act Exemptive Order, 76 FR
at 39929. Under the 2011 Exchange Act Exemptive
Order, instruments that were security-based swap
agreements before July 16, 2011 (360 days after the
enactment of the Dodd-Frank Act) (‘‘Effective
Date’’) and constituted security-based swaps after
the Effective Date were still subject to the
application of those Exchange Act provisions. See
2011 Exchange Act Exemptive Order, 76 FR at
39930 nn.24–25.
4 See 2011 Exchange Act Exemptive Order, 76 FR
at 39938.
5 See Further Definition of ‘‘Swap,’’ ‘‘SecurityBased Swap,’’ and ‘‘Security-Based Swap
Agreement’’; Mixed Swaps; Security-Based Swap
Agreement Recordkeeping, Exchange Act Release
No. 67453 (Jul. 18, 2012), 77 FR 48208 (Aug. 13,
2012) (‘‘Product Definitions Adopting Release’’)
(extending the expiration date of the temporary
exemptions to February 11, 2013); Order Extending
Temporary Exemptions under the Securities
Exchange Act of 1934 in Connection with the
Revision of the Definition of ‘‘Security’’ to
Encompass Security-Based Swaps, and Request for
Comment, Exchange Act Release No. 68864 (Feb. 7,
2013), 78 FR 10218 (Feb. 13, 2013) (‘‘2013
Extension Order’’) (extending the expiration date of
the temporary exemptions to February 11, 2014);
Order Extending Temporary Exemptions under the
Securities Exchange Act of 1934 in Connection with
the Revision of the Definition of ‘‘Security’’ to
Encompass Security-Based Swaps, and Request for
Comment, Exchange Act Release No. 71485 (Feb. 5,
2014), 79 FR 7731 (Feb. 10, 2014) (‘‘2014 Extension
Order’’) (extending the expiration dates (i) for
certain ‘‘linked’’ temporary exemptions related to
then-pending security-based swap rulemakings to
the compliance dates for the related rulemakings
and (ii) for certain other ‘‘unlinked’’ temporary
exemptions not related to then-pending
rulemakings to February 5, 2017); Order Extending
Certain Temporary Exemptions Under the
Securities Exchange Act of 1934 in Connection
With the Revision of the Definition of ‘‘Security’’
To Encompass Security-Based Swaps and Request
for Comment, Exchange Act Release No. 79833 (Jan.
18, 2017), 82 FR 8467 (Jan. 25, 2017) (‘‘2017
Extension Order’’) (extending the expiration date
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70667
2014, the Commission extended the
expiration date for the temporary
exemptions, distinguishing between: (1)
The temporary exemptions related to
pending security-based swap
rulemakings (‘‘Linked Temporary
Exemptions’’), the expiration dates for
which were extended to the compliance
dates for the specific rulemakings to
which they were ‘‘linked’’; and (2) the
temporary exemptions that generally
were not directly related to a specific
security-based swap rulemaking
(‘‘Unlinked Temporary Exemptions’’).6
for the unlinked temporary exemptions to February
5, 2018); Order Extending Until February 5, 2019
Certain Temporary Exemptions under the Securities
Exchange Act of 1934 in Connection with the
Pending Revision of the Definition of ‘‘Security’’ to
Encompass Security-Based Swaps and Request for
Comment, Exchange Act Release No. 82626 (Feb. 2,
2018), 83 FR 5665 (Feb. 18, 2018) (‘‘2018 Extension
Order’’) (extending the expiration date for the
unlinked temporary exemptions to February 5,
2019); Order Granting a Limited Exemption from
the Exchange Act Definition of ‘‘Penny Stock’’ for
Security-Based Swap Transactions between Eligible
Contract Participants; Granting a Limited
Exemption from the Exchange Act Definition of
‘‘Municipal Securities’’ for Security-Based Swaps;
and Extending Certain Temporary Exemptions
under the Exchange Act in Connection with the
Revision of the Definition of ‘‘Security’’ to
Encompass Security-Based Swaps, Exchange Act
Release No. 84991 (Jan. 25, 2019), 84 FR 863 (Jan.
31, 2019) (‘‘2019 Extension Order’’) (extending the
expiration date for the unlinked temporary
exemptions to February 5, 2020); Order Extending
Temporary Exemptions from Exchange Act Section
8 and Exchange Act Rules 8c–1, 10b–16, 15a–1,
15c2–1 and 15c2–5 in Connection with the Revision
of the Definition of ‘‘Security’’ to Encompass
Security-Based Swaps, Exchange Act Release No.
87943 (Jan. 10, 2020), 85 FR 2763 (Jan. 16, 2020)
(‘‘January 2020 Extension Order’’) (extending the
expiration date for the unlinked temporary
exemptions to November 5, 2020).
6 See 2014 Extension Order, 79 FR at 7732–35.
The 2014 Extension Order identified the Linked
Temporary Exemptions as those Expiring
Temporary Exemptions related to: (1) Capital and
margin requirements applicable to a broker or
dealer (Exchange Act Sections 7 and 15(c)(3),
Regulation T, and Exchange Act Rules 15c3–1,
15c3–3, and 15c3–4); (2) recordkeeping
requirements applicable to a broker or dealer
(Exchange Act Sections 17(a) and 17(b) and
Exchange Act Rules 17a–3, 17a–4, 17a–5, 17a–11,
and 17a–13); (3) registration requirements under
Exchange Act Section 15(a)(1), and the other
requirements of the Exchange Act and the rules and
regulations thereunder that apply to a ‘‘broker’’ or
‘‘dealer’’ that is not registered with the Commission;
(4) Exchange Act Rule 10b–10; and (5) Regulation
ATS. The remaining Expiring Temporary
Exemptions are the Unlinked Temporary
Exemptions. The Commission extended the Linked
Temporary Exemptions until the compliance date
for pending rulemakings concerning, as applicable:
Capital, margin, and segregation requirements for
security-based swap dealers and major securitybased swap participants; recordkeeping and
reporting requirements for security-based swap
dealers and major security-based swap participants;
security-based swap trade acknowledgement and
verification requirements; and registration
requirements for security-based swap execution
facilities. The Linked Temporary Exemptions
linked to registration requirements for securitybased swap execution facilities are not addressed in
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The approach to the Linked Temporary
Exemptions was designed to facilitate
timely, phased-in application of the
relevant provisions of the Exchange Act
to security-based swaps based on the
Commission’s finalization of the
relevant rules mandated by the DoddFrank Act.7 The approach to the
Unlinked Temporary Exemptions
provided the Commission with
flexibility, while its relevant rulemaking
was still in progress, to determine
whether continuing relief should be
provided for any of the Exchange Act
provisions subject to the Unlinked
Temporary Exemptions.8 In January
2020, the Commission issued an order
extending until November 5, 2020, the
temporary exemptions related to three
commenter requests discussed below.9
The remainder of the Unlinked
Temporary Exemptions expired on
February 5, 2020.10
The Commission has requested
comment on the initial issuance and
subsequent extensions of these
temporary exemptions several times
during consideration of the various
exemptive orders.11 In response, some
this Order and will be separately considered in
connection with the rulemaking concerning those
requirements. The Commission already has
addressed other Linked Temporary Exemptions in
the related security-based swap rulemakings. See,
e.g., Capital, Margin, and Segregation Requirements
for Security-Based Swap Dealers and Major
Security-Based Swap Participants and Capital and
Segregation Requirements for Broker-Dealers,
Exchange Act Release No. 86175 (Jun. 21, 2019), 84
FR 43872, 43955–56 (Aug. 22, 2019) (‘‘Capital,
Margin and Segregation Adopting Release’’);
Recordkeeping and Reporting Requirements for
Security-Based Swap Dealers, Major Security-Based
Swap Participants, and Broker-Dealers, Exchange
Act Release No. 87005 (Sept. 19 2019), 84 FR 68550,
68601–02 (Dec. 16, 2019) (‘‘Recordkeeping and
Reporting Adopting Release’’); Trade
Acknowledgment and Verification of SecurityBased Swap Transactions, Exchange Act Release
No. 78011 (Jun. 8, 2016), 81 FR 39807, 39824–25
n.189 (Jun. 17, 2016) (‘‘Trade Acknowledgment and
Verification Adopting Release’’).
7 See 2014 Extension Order, 79 FR at 7731.
8 See 2014 Extension Order, 79 FR at 7731.
9 See January 2020 Extension Order, 85 FR at
2766.
10 See January 2020 Extension Order, 85 FR at
2766.
11 See 2011 Exchange Act Exemptive Order, 76
FR at 39938; 2013 Extension Order, 78 FR at 10219–
20 (discussion of comments on 2011 Exchange Act
Exemptive Order and additional request for
comment); 2014 Extension Order, 79 FR at 7734
(additional request for comment); 2017 Extension
Order, 82 FR at 8469 (additional request for
comment); 2018 Extension Order, 83 FR at 5667–
68 (discussion of comments on 2017 Extension
Order and additional request for comment). In
response to its 2018 request for comment, the
Commission received four letters from two different
commenters. See letter from Kyle Brandon,
Managing Director, Securities Industry and
Financial Markets Association (‘‘SIFMA’’), dated
Nov. 8, 2018 (‘‘SIFMA November 2018 Letter’’)
(requesting that the Commission further extend the
Unlinked Temporary Exemptions, and also
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20:36 Nov 04, 2020
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commenters requested that the
Commission make permanent some of
the Linked Temporary Exemptions and
Unlinked Temporary Exemptions.12 The
Commission has addressed some
aspects of these requests in two
previous orders.13 Some of the requests
for permanent exemptions have been
withdrawn 14 or superseded.15
On January 8, 2020, the Commission
received a letter from SIFMA
supplementing its requests regarding the
Unlinked Temporary Exemptions.16 The
commenter requested that the
Commission make permanent three
aspects 17 of the Unlinked Temporary
requesting certain permanent exemptive and other
relief); letter from Kyle Brandon, Managing
Director, SIFMA, dated Dec. 20, 2018 (‘‘SIFMA
December 2018 Letter’’) (supplementing the SIFMA
November 2018 Letter with additional detail
regarding the Unlinked Temporary Exemptions and
recommending a twelve-month transition period
before expiration of any Unlinked Temporary
Exemptions); letter from Walt L. Lukken, President
and Chief Executive Officer, Futures Industry
Association, dated Nov. 14, 2018 (‘‘FIA November
2018 Letter I’’) (expressing support for the
permanent exemptions requested in the SIFMA
November 2018 Letter); letter from Walt L. Lukken,
President and Chief Executive Officer, Futures
Industry Association, dated Nov. 29, 2018 (‘‘FIA
November 2018 Letter II’’) (same). All comments
received are available at https://www.sec.gov/
comments/s7-27-11/s72711.shtml.
12 See SIFMA November 2018 Letter at 1–4;
SIFMA December 2018 Letter at 1–7; see also FIA
November 2018 Letter I at 10; FIA November 2018
Letter II at 10–11.
13 In 2019, the Commission provided limited
exemptions from the definition of ‘‘penny stock’’ in
Exchange Act Section 3(a)(51) and Exchange Act
Rule 3a51–1 for transactions in security-based
swaps between eligible contract participants and
from the definition of ‘‘municipal securities’’ in
Exchange Act Section 3(a)(29) for security-based
swaps. See 2019 Extension Order, 84 FR at 867. In
response to the commenter’s request for guidance
regarding the definition of ‘‘government securities,’’
the Commission noted that the Unlinked
Temporary Exemptions did not include an
exemption from the definition of ‘‘government
securities’’ in Section 3(a)(42) of the Exchange Act
and noted that the Exchange Act does not permit
the Commission to provide such relief. See 2019
Extension Order, 84 FR at 866 & n.40. In response
to the commenter’s request for exemptions for
security-based swap execution facilities, the
Commission noted that it would consider the
request in connection with the Commission’s
finalization of rules for security-based swap
execution facilities. See 2019 Extension Order, 84
FR at 864 n.10. In January 2020, the Commission
allowed all of the Unlinked Temporary Exemptions
except for those related to three of the commenter’s
requests to expire on February 5, 2020. See January
2020 Extension Order, 85 FR at 2766.
14 See letter from Kyle Brandon, Managing
Director, SIFMA, dated Jan. 8, 2020 (‘‘SIFMA
January 2020 Letter’’), at 5; letter from Kyle L.
Brandon, Managing Director, Head of Derivatives
Policy, SIFMA, dated September 10, 2020 (‘‘SIFMA
September 2020 Letter’’), at 8. All comments
received are available at https://www.sec.gov/
comments/s7-27-11/s72711.shtml.
15 See SIFMA September 2020 Letter at 5–6.
16 See SIFMA January 2020 Letter.
17 The commenter confirmed that it was no longer
requesting additional extensions for any Unlinked
Temporary Exemptions other than for the three
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Exemptions: (1) A limited exemption
from the hypothecation requirements of
Exchange Act Section 8 and in
Exchange Act Rules 8c–1 and 15c2–1 for
certain securities carried for the account
of a customer with respect to a securitybased swap transaction,18 (2)
exemptions from broker and dealer
disclosure requirements relating to
extensions of credit in Exchange Act
Rules 10b–16 and 15c2–5 as applied to
security-based swaps,19 and (3)
exemptions for security-based swaps
from certain limitations on an OTC
derivatives dealer’s activities in
Exchange Act Rule 15a–1.20 On
September 10, 2020, the Commission
received a letter supplementing the
commenter’s requests regarding those
three aspects of the Unlinked
Temporary Exemptions, as well as three
additional aspects of the Linked
Temporary Exemptions.21 In that letter,
the commenter requested that the
Commission make permanent three
aspects of the Linked Temporary
Exemptions: (1) an exemption from the
broker and dealer registration
requirement in Exchange Act Section
15(a)(1) 22 for a foreign broker or dealer,
otherwise operating in compliance with
Exchange Act Rule 15a–6, solely in
connection with security-based swap
dealing with or for an eligible contract
participant,23 (2) an exemption from the
broker registration requirement in
Section 15(a)(1) for a registered securityissues cited in the letter. See SIFMA January 2020
Letter at 5.
18 See SIFMA January 2020 Letter at 3–4; SIFMA
December 2018 Letter at 5; SIFMA November 2018
Letter at 3; Exchange Act Section 8, 15 U.S.C. 78h;
Exchange Act Rule 8c–1, 17 CFR 240.8c–1;
Exchange Act Rule 15c2–1, 17 CFR 240.15c2–1.
Section 8 of the Exchange Act and Exchange Act
Rules 8c–1 and 15c2–1 limit a broker or dealer’s
ability to hypothecate securities carried for the
account of a customer.
19 See SIFMA January 2020 Letter at 4; SIFMA
December 2018 Letter at 5–6; SIFMA November
2018 Letter at 3; Exchange Act Rule 10b–16, 17 CFR
240.10b–16; Exchange Act Rule 15c2–5, 17 CFR
240.15c2–5. Exchange Act Rules 10b–16 and 15c2–
5 govern the disclosures that a broker or dealer
must provide to customers to whom they extend
credit.
20 See SIFMA January 2020 Letter at 4–5; SIFMA
December 2018 Letter at 6–7; SIFMA November
2018 Letter at 4; Exchange Act Rule 15a–1, 17 CFR
240.15a–1. Exchange Act Rule 15a–1 limits an OTC
derivatives dealer’s ability to engage in dealer
activities in listed instruments and in fungible
instruments that are standardized as to their
material economic terms.
21 See SIFMA September 2020 Letter.
22 15 U.S.C. 78o(a)(1).
23 See SIFMA September 2020 Letter at 3–4;
Exchange Act Section 15(a)(1), 15 U.S.C. 78o(a)(1);
Exchange Act Rule 15a–6, 17 CFR 240.15a–6. This
request updated the commenter’s 2018 request for
exemption from registration as a broker or dealer for
Rule 15a–6-reliant foreign brokers and dealers that
induce or attempt to purchase or sell a securitybased swap with or for an eligible contract
participant. See SIFMA November 2018 Letter at 2.
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Federal Register / Vol. 85, No. 215 / Thursday, November 5, 2020 / Notices
based swap dealer that arranges,
negotiates or executes a security-based
swap with or for an eligible contract
participant on behalf of a majorityowned affiliate that is a registered
security-based swap dealer,24 and (3) an
exemption from certain confirmation
requirements under Exchange Act Rule
10b–10 for a broker or dealer that
arranges, negotiates or executes a
security-based swap with or for an
eligible contract participant on behalf of
a majority-owned affiliate that is a
registered security-based swap dealer.25
The Commission has finalized a
majority of the rulemakings under Title
VII of the Dodd-Frank Act, including
rules regarding the registration and
regulation of SBS Entities. The
Commission also has set the compliance
date for rules regarding registration and
regulation of SBS Entities,26 which will
be October 6, 2021. Market participants
will be required to assess whether their
activities meet the definitions of
‘‘security-based swap dealer’’ or ‘‘major
security-based swap participant’’
beginning two months before this
compliance date, or August 6, 2021.27
This Order addresses the commenter’s
current requests regarding the Linked
Temporary Exemptions and the
Unlinked Temporary Exemptions in
light of those finalized rules and dates.
The remainder of the Unlinked
Temporary Exemptions extended in
January 2020, and not extended in this
Order, will expire on November 5,
2020.28
B. Requests for Exemptions
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The Commission has considered the
commenter’s six current requests and is
providing exemptions in response to
five of those requests. Each of the
requests is discussed in turn below.
24 See SIFMA September 2020 Letter at 4;
Exchange Act Section 15(a)(1), 15 U.S.C. 78o(a)(1).
25 See SIFMA September 2020 Letter at 4–5;
Exchange Act Rule 10b–10, 17 CFR 240.10b–10.
This request updated the commenter’s 2018 request
for exemption from broker and dealer confirmation
requirements. See SIFMA November Letter at 2.
26 See Rule Amendments and Guidance
Addressing Cross-Border Application of Certain
Security-Based Swap Requirements, Exchange Act
Release No. 87780 (Dec. 18, 2019), 85 FR 6270, 6345
(Feb. 4, 2020) (‘‘Cross-Border Adopting Release’’).
27 See Registration Process for Security-Based
Swap Dealers and Major Security-Based Swap
Participants, Exchange Act Release No. 75611 (Aug.
5, 2015), 80 FR 48963, 48988 (Aug. 14, 2015) (‘‘SBS
Entity Registration Adopting Release’’).
28 See January 2020 Extension Order, 85 FR at
2766.
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20:36 Nov 04, 2020
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1. Request for an Exemption From
Broker and Dealer Registration for a
Rule 15a–6-Reliant Foreign Broker or
Dealer, Solely in Connection With
Security-Based Swap Dealing With or
for an Eligible Contract Participant
Exchange Act Section 15(a)(1)
requires a person to register as a broker
or dealer if the person is a ‘‘broker’’ as
defined in Exchange Act Section
3(a)(4) 29 or a ‘‘dealer’’ as defined in
Exchange Act Section 3(a)(5) 30 and
engages in certain activities in a
‘‘security’’ as defined in Exchange Act
Section 3(a)(10),31 a term that includes
security-based swaps. Section 15(a)(1)
currently is subject to Linked
Temporary Exemptions that exempt
from the registration requirement
brokerage activities and dealing
activities involving security-based
swaps with eligible contract
participants.32 These Linked Temporary
Exemptions will expire on October 6,
2021.33
Dealing in security-based swaps with
or for an eligible contract participant is
excluded from the definition of the term
‘‘dealer,’’ 34 and that will remain true
after the Linked Temporary Exemptions
expire. Similarly, market participants
that conduct other activities meeting the
definitions of ‘‘broker’’ and/or ‘‘dealer’’
may nevertheless avoid registration as a
broker or dealer by availing themselves
of the exemption from registration in
Exchange Act Rule 15a–6. Yet, the
commenter expressed concern that if a
person combines these types of
securities activities—that is, dealing in
a security-based swap with or for an
eligible contract participant (which is
excluded from the definition of the term
‘‘dealer’’) and Rule 15a–6-compliant
securities activities (which cause the
person to meet the definition of
‘‘broker’’ and/or ‘‘dealer’’ but that do not
require registration as such)—Section
15(a)(1) may require the person to
register as a broker and/or dealer. The
commenter’s concern is that this result
may follow from Section 15(a)(1)’s
requirement for any person that meets
the definition of ‘‘broker’’ or
‘‘dealer’’ 35—a category that includes
29 15
U.S.C. 78c(a)(4).
U.S.C. 78c(a)(5).
31 15 U.S.C. 78c(a)(10).
32 See 2011 Exchange Act Exemptive Order, 76
FR at 39938–39; 2014 Extension Order, 79 FR at
7734–35.
33 See 2014 Extension Order, 79 FR at 7734–35;
Recordkeeping and Reporting Adopting Release, 84
FR at 68600; Cross-Border Adopting Release, 85 FR
at 6345.
34 See Exchange Act Section 3(a)(5)(A).
35 This registration requirement does not apply to
a broker or dealer whose business is exclusively
intrastate and who does not make use of any facility
30 15
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Sfmt 4703
70669
foreign brokers and dealers relying on
Rule 15a–6—to register with the
Commission if it makes use of the mails
or any means or instrumentality of
interstate commerce to effect any
transactions in, or to induce or attempt
to induce the purchase or sale of, any
security,36 including security-based
swaps. The commenter requested that
foreign brokers and dealers relying on
Exchange Act Rule 15a–6 be exempted
from Section 15(a)(1)’s broker and
dealer registration requirement in
connection with any security-based
swap dealing with or for an eligible
contract participant that is excluded
from the definition of ‘‘dealer.’’ 37 The
commenter also provided an example
unrelated to Rule 15a–6, expressing
concern that if a non-U.S. person
combines dealing in a security-based
swap in the United States with or for an
eligible contract participant, on the one
hand, with brokerage activity outside
the United States, on the other hand,
Section 15(a)(1) would require the
person to register as a broker and/or
dealer.38
The Commission agrees that brokerdealer registration should not be
required in the circumstances described
by the commenter. To provide certainty
about this result, the Commission is
providing an exemption from Section
15(a)(1) for security-based swap dealing
with or for eligible contract participants,
available to foreign brokers and dealers
whose activities in securities other than
security-based swaps with or for an
eligible contract participant comply
with Rule 15a–6. The Commission
believes this exemption would further
the purpose of the exclusion of that type
of security-based swap dealing from the
definition of ‘‘dealer.’’ Similarly, the
Commission believes that a limited
exemption from Section 15(a)(1) for
security-based swap dealing with or for
eligible contract participants, available
to foreign brokers and dealers whose
activities in securities other than
security-based swaps with or for an
eligible contract participant lack a U.S.
jurisdictional nexus, also would further
the purpose of the exclusion of that type
of security-based swap dealing from the
definition of ‘‘dealer.’’ This exemption
addresses the commenter’s concern that,
without this limited exemptive relief
from the registration requirement of
of a national securities exchange. See Exchange Act
Section 15(a)(1).
36 This registration requirement does not apply to
activities in an exempted security or commercial
paper, bankers’ acceptances or commercial bills.
See Exchange Act Section 15(a)(1).
37 See SIFMA September 2020 Letter at 3–4;
SIFMA November 2018 Letter at 2.
38 See SIFMA September 2020 Letter at 3–4.
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Section 15(a)(1), the exclusion of
security-based swaps with or for eligible
contract participants from the definition
of ‘‘dealer’’ might effectively become
unavailable to foreign brokers and
dealers whose other securities activities
either comply with Rule 15a–6 or lack
any U.S. jurisdictional nexus. Requiring
registration in this circumstance could
undermine the market structure for
security-based swaps by making it more
costly and complex to engage in that
type of security-based swap dealing
with eligible contract participants in the
United States, to the detriment of
investors. Accordingly, pursuant to its
authority under Exchange Act Section
15(a)(2), the Commission finds that it is
consistent with the public interest and
the protection of investors to exempt a
‘‘foreign broker or dealer,’’ as such term
is defined in Rule 15a–6(b)(3) under the
Exchange Act, whose activities in
securities other than security-based
swaps with or for an eligible contract
participant are conducted either in
compliance with Rule 15a–6 under the
Exchange Act or without the
jurisdiction of the United States, from
the registration requirement of Exchange
Act Section 15(a)(1) solely in
connection with the foreign broker or
dealer’s security-based swap dealing
with or for an eligible contract
participant. Consistent with the
commenter’s request, this exemption
would not extend to foreign brokers’
and dealers’ security-based swap
brokerage activity.
2. Request for Exemption From Broker
Registration for a Registered SecurityBased Swap Dealer That Arranges,
Negotiates or Executes a Security-Based
Swap With or for an Eligible Contract
Participant on Behalf of a MajorityOwned Affiliate That Is a Registered
Security-Based Swap Dealer
As described above, Exchange Act
Section 15(a)(1) requires a person to
register as a broker if the person is a
‘‘broker’’ as defined in Exchange Act
Section 3(a)(4) and engages in certain
activities in a ‘‘security’’ as defined in
Exchange Act Section 3(a)(10), a term
that includes security-based swaps.
Though dealing in security-based swaps
with or for an eligible contract
participant is excluded from the
definition of the term ‘‘dealer,’’ 39 the
statutory definition of the term ‘‘broker’’
contains no such exclusion.40 Section
15(a)(1) currently is subject to Linked
Temporary Exemptions that exempt
from the registration requirement
brokerage activities involving security39 See
40 See
Exchange Act Section 3(a)(5)(A).
Exchange Act Section 3(a)(4).
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based swaps with eligible contract
participants.41 These Linked Temporary
Exemptions will expire on October 6,
2021.42
As part of its consideration of crossborder issues in the registration of
security-based swap dealers, the
Commission recently determined that a
limited exemption from the broker
registration requirement was
appropriate for a registered securitybased swap dealer and its associated
persons who conduct certain securitybased swap ‘‘arranging, negotiating or
executing’’ activity (‘‘ANE activity’’)
with or for a non-U.S. person eligible
contract participant on behalf of a nonU.S. majority-owned affiliate that is
relying on an exception to the de
minimis thresholds for registration as a
security-based swap dealer.43 The
commenter requested that this limited
exemption from the broker registration
requirement be extended to situations in
which the majority-owned affiliate is
not relying on the de minimis exception
but, rather, is a registered security-based
swap dealer.44 When adopting this
limited exemption in the context of the
de minimis exception, the Commission
noted that a security-based swap dealer
not dually registered as a broker or
dealer and approved to use models to
compute deductions for market or credit
risk is subject to a minimum net capital
requirement of $20 million and a
minimum tentative net capital
requirement of $100 million, versus
minimum requirements of $1 billion
and $5 billion, respectively, for a broker
or dealer approved to use models.45 The
Commission adopted that exemption to
avoid a situation in which ‘‘applying the
heightened broker-dealer capital
requirements to all security-based swap
dealers approved to use models who
serve as the registered entity for
purposes of the [de minimis] exception
could limit the usefulness of the
exception.’’ 46 The commenter argued
that extending the limited exemption
would be appropriate because the same
concerns also apply when the majorityowned affiliate is a registered, rather
41 See 2011 Exchange Act Exemptive Order, 76
FR at 39938–39; 2014 Extension Order, 79 FR at
7734.
42 See 2014 Extension Order, 79 FR at 7734–35;
SBS Entity Registration Adopting Release, 80 FR at
48988; Cross-Border Adopting Release, 85 FR at
6345.
43 See Exchange Act Rule 3a71–3(d)(4); CrossBorder Adopting Release, 85 FR at 6279–80.
44 See SIFMA September 2020 Letter at 4.
45 See Cross-Border Adopting Release, 85 FR at
6279.
46 See Cross-Border Adopting Release, 85 FR at
6279.
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than unregistered, security-based swap
dealer.47
The Commission continues to believe
that ANE activity generally would
constitute activity of a ‘‘broker’’ as that
term is defined in Exchange Act Section
3(a)(4).48 The Commission
acknowledges the concerns regarding
the heightened capital requirements for
brokers approved to use models as
applied to the security-based swap ANE
activity described in the commenter’s
request. At the same time, the statutory
definition of ‘‘broker’’ does not contain
an exclusion for this activity.49
Moreover, the Commission also is
concerned that an exemption for ANE
activity from the broker registration
requirement could prompt changes in
market structure that make it more
difficult for the Commission to oversee
that activity. In the Commission’s view,
however, a temporary exemption should
not encourage such market structure
changes, but could provide the
Commission an opportunity to consider
these concerns in light of market
conditions prevailing after registration
of security-based swap dealers begins.50
Accordingly, pursuant to its authority
under Exchange Act Section 15(a)(2),
the Commission finds that it is
consistent with the public interest and
the protection of investors to provide a
conditional temporary exemption from
the broker registration requirement of
Section 15(a)(1) until November 1, 2022
(i.e., one year after the earliest due date
for applications for registration as a
security-based swap dealer) for a
registered security-based swap dealer
and its associated persons solely in
connection with such registered
security-based swap dealer or associated
person arranging, negotiating or
executing a security-based swap
transaction with or for a non-U.S.
person eligible contract participant on
behalf of a non-U.S. person qualified
majority-owned affiliate. Consistent
with the exemption from broker
registration in the context of the de
minimis exception, this exemption is
limited to ANE activity with or for a
non-U.S. person eligible contract
participant. The Commission continues
to believe that requiring broker
registration with respect to ANE activity
with or for a counterparty that is not an
eligible contract participant is
consistent with the heightened
47 See
SIFMA September 2020 Letter at 4.
Cross-Border Adopting Release, 85 FR at
6279 & n.104.
49 See Exchange Act Section 3(a)(4).
50 The Commission welcomes engagement with
market participants to discuss developments that
may occur in this market after security-based swap
dealers begin to register.
48 See
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protections that Congress applied to
security-based swap transactions with
or for non-eligible contract
participants.51 For purposes of this
exemption, the term ‘‘qualified majorityowned affiliate’’ means a majorityowned affiliate (as such term is defined
in Exchange Act Rule 3a71–3(a)(10)) of
the registered security-based swap
dealer that is itself also a registered
security-based swap dealer.
To be eligible for the exemption, the
registered security-based swap dealer
must comply with two relevant
conditions to the parallel exemption
from broker registration in the context of
the de minimis exception. First, the
registered security-based swap dealer
must create and maintain books and
records relating to such ANE activity
that are required by Exchange Act Rules
18a–5 and 18a–6. This condition differs
slightly from the parallel condition in
the context of the de minimis
exception 52 in that the required books
and records relate only to the ANE
activity by the registered security-based
swap dealer relying on the exemption,
rather than to the entire security-based
swap transaction subject to the de
minimis exception. The Commission
believes this difference is appropriate
because the de minimis exception
applies to transactions on behalf of an
unregistered affiliate, whereas the
exemption granted in this Order applies
only to ANE activity on behalf of a
registered security-based swap dealer
affiliate. Because the affiliate also must
maintain books and records relating to
the transaction, the Commission
believes that the exemption should
require the registered security-based
swap dealer relying on this exemption
to create and maintain only those books
and records that relate to its own ANE
activity. Second, if Exchange Act Rule
10b–10 would apply to such ANE
activity, the registered security-based
swap dealer also must provide to the
customer the disclosures required by
Rule 10b–10(a)(2) (excluding Rule 10b–
10(a)(2)(i) and (ii)) and Rule 10b–
10(a)(8) in accordance with the time and
form requirements set forth in Exchange
Act Rule 15Fi–2(b) and (c) or,
alternatively, promptly after discovery
of any defect in such registered securitybased swap dealer’s good faith effort to
comply with such requirements.53
51 See Cross-Border Adopting Release, 85 FR at
6279 & n.109 (citing Exchange Act Section 6(l), 15
U.S.C. 78f(l), and Exchange Act Section 3(a)(5), 15
U.S.C. 78c(a)(5)).
52 See Exchange Act Rule 3a71–4(d)(1)(iii)(B)(1).
53 The other conditions to the availability of the
exemption from broker registration in the context of
the de minimis exception are not applicable to ANE
activity on behalf of a registered security-based
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3. Request for Exemption From Certain
Confirmation Requirements for a Broker
or Dealer That Arranges, Negotiates or
Executes a Security-Based Swap With or
for an Eligible Contract Participant on
Behalf of a Majority-Owned Affiliate
That Is a Registered Security-Based
Swap Dealer
Exchange Act Rule 10b–10 54 requires
a broker or dealer to deliver to a
customer certain disclosures about
transactions in securities, including
security-based swaps. Exchange Act
Rule 15Fi–2 55 requires an SBS Entity to
deliver to a counterparty a trade
acknowledgment containing certain
terms of the security-based swap or to
verify the trade acknowledgment
received from the counterparty. Certain
information required to be included in
a Rule 10b–10 confirmation is not
required in the Rule 15Fi-2 trade
acknowledgment, such as a description
of the broker or dealer’s role as agent for
the customer, agent for some other
person, agent for both the customer and
another person or principal for its own
account in the transaction, as well as
information about the source and/or
amount of certain other remuneration
received or to be received by the broker
or dealer in connection with the
transaction.56 Rule 10b–10 currently is
subject to a Linked Temporary
Exemption that exempts brokers and
dealers from these disclosure
requirements with respect to securitybased swaps.57 This Linked Temporary
Exemption will expire on October 6,
2021.58
A registered broker that conducts
ANE activity pursuant to the de minimis
exception in Exchange Act Rule 3a71–
3(d) is exempt from providing the
disclosures described in Rule 10b–10,
except for those regarding the broker’s
role as agent or principal in the
transaction and the broker or dealer’s
swap dealer and thus are not included as conditions
to the exemption granted in this Order. For
example, registered security-based swap dealers
already have to comply with the provisions listed
in Exchange Act Rule 3a71–3(d)(1)(ii), provide the
Commission with the access to books and records
described in Rule 3a71–3(d)(1)(iii)(A) and maintain
the books and records and consent to service of
process described in Rule 3a71–3(d)(1)(iii)(B)(3)–
(4). The conditions described in Rule 3a71–
3(d)(1)(iii)(B)(2) and (d)(1)(iv)–(vii) are specific to
the operation of the de minimis exception and are
not relevant to the exemption granted in this Order.
54 17 CFR 240.10b–10.
55 17 CFR 240.15Fi–2.
56 See Exchange Act Rule 10b–10(a).
57 See 2011 Exchange Act Exemptive Order, 76
FR at 39939; 2014 Extension Order, 79 FR at 7734.
58 See 2014 Extension Order, 79 FR at 7734; Trade
Acknowledgment and Verification Adopting
Release, 81 FR at 39828; Recordkeeping and
Reporting Adopting Release, 84 FR at 68600; CrossBorder Adopting Release, 85 FR at 6345.
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70671
status as a member of SIPC.59 In
addition, a registered security-based
swap dealer that conducts ANE activity
pursuant to the de minimis exception is
exempt from registration as a broker so
long as it provides these same Rule 10b–
10 disclosures.60 Because Rule 10b–10
and Rule 15Fi–2 have different form and
timing requirements,61 the de minimis
exception allows these Rule 10b–10
disclosures to be provided in
accordance with the form and timing
requirements in Rule 15Fi–2(b) and
(c).62
The commenter requests that a
parallel exemption from Rule 10b–10
apply to situations in which a registered
broker or dealer conducts ANE activity
not pursuant to the de minimis
exception but, rather, on behalf of a
majority-owned affiliate that is a
registered security-based swap dealer.63
Though Rule 10b–10 requires
disclosures not duplicated in the trade
acknowledgment required under Rule
15Fi–2, the commenter claims that some
of these disclosures are ‘‘irrelevant’’ in
the situations covered by its request
because a broker or dealer would be
‘‘solely compensated by its [securitybased swap dealer] affiliate.’’ 64 Rule
10b–10, however, contains no
exemption for transactions in which
compensation is paid by an affiliate.
Moreover, compensation disclosure is
not available through other means, as
the trade acknowledgment required by
Rule 15Fi–2 would disclose only the
terms of the security-based swap
transaction, which do not necessarily
include compensation regarding the
brokerage activity to which Rule 10b–10
applies. Security-based swap trade
acknowledgments thus do not duplicate
or replace Rule 10b–10 disclosures for
brokerage activity.65 In response to the
commenter’s previous request for
exemption from Rule 10b–10 for
59 See
Exchange Act Rule 3a71–(d)(5).
Exchange Act Rule 3a71–3(d)(4)(ii).
61 Rule 10b–10(a) requires a broker or dealer to
give or send a confirmation in the form of a
‘‘written notification,’’ whereas Rule 15Fi–2(c)
requires a trade acknowledgment to be provided by
‘‘electronic means that provide reasonable
assurance of delivery and a record of transmittal.’’
A broker or dealer must give or send a transaction
confirmation under Rule 10b–10(a) ‘‘at or before the
completion of such transaction,’’ whereas a trade
acknowledgment pursuant to Rule 15Fi–2(b) must
be provided ‘‘promptly, but in any event by the end
of the first business day following the day of
execution.’’
62 See Exchange Act Rule 3a71–3(d)(4)(ii), (5)(ii).
63 See SIFMA September 2020 Letter at 5.
64 See SIFMA September 2020 Letter at 5.
65 See Trade Acknowledgment and Verification
Adopting Release, 81 FR at 39824–25 (‘‘[Rule 15Fi–
2] thus does not apply to brokerage or agency
transactions, which are different in structure and
involve different activity by a broker than principal
transactions by [a security-based swap dealer].’’).
60 See
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security-based swap brokerage
activity,66 the Commission stated that,
‘‘since Rule 15Fi–2 does not require a
trade acknowledgment for an SBS
Entity’s brokerage or agency
transactions, and therefore would not
result in any duplication of efforts by
the SBS Entity effecting the brokerage or
agency transaction, the Commission
does not believe that there is a need to
provide an exemption from providing a
confirmation under Rule 10b–10 for an
SBS Entity’s brokerage or agency
transactions.’’ 67 Indeed, the
Commission believes that customers
would benefit from disclosure about
brokerage costs even when gross costs
may be reflected in the transaction price
reported in the trade acknowledgment.
For these reasons, the Commission is
not providing an exemption from Rule
10b–10’s disclosure requirements in
connection with a broker or dealer’s
security-based swap ANE activity.
In the context described by the
commenter—that is, a broker or dealer’s
ANE activity on behalf of a majorityowned affiliate that is a registered
security-based swap dealer—the broker
or dealer may wish to deliver the Rule
10b–10 disclosures regarding the ANE
activity in the same document or
communication as the trade
acknowledgment or verification that its
affiliate delivers pursuant to Rule 15Fi–
2. The Commission recognizes,
however, the potential for the different
time and form requirements in Rule
10b–10 and Rule 15Fi–2(b) and (c) to
frustrate attempts to deliver a single
document or communication and could,
as a result, increase the costs and other
burdens to investors of responding to
multiple communications regarding the
ANE activity. As a result, the
Commission is granting the
commenter’s request for an exemption
from Rule 10b–10’s requirement to
deliver disclosures to a customer at or
before completion of the transaction, so
as to allow disclosures related to ANE
activity to be provided at the time and
in the form of a trade acknowledgment
as required by Rule 15Fi–2(b) and (c),
except that disclosures requested by the
customer as allowed by Rule 10b–10,
which are not addressed in Rule 15Fi–
2, must be delivered in accordance with
the deadlines specified in Rule 10b–
10(c).68
66 See letter from Securities Industry and
Financial Markets Association, dated Dec. 5, 2011,
available at https://www.sec.gov/comments/s7-2711/s72711.shtml.
67 See Trade Acknowledgment and Verification
Adopting Release, 81 FR at 39825.
68 Rule 10b–10(c) requires a broker or dealer to
‘‘give or send to a customer information requested
pursuant to [Rule 10b–10] within five business days
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Consistent with the Rule 10b–10related exemptions and requirements in
the de minimis exception, the
commenter requested that any relief
from Rule 10b–10’s timing requirements
also include the ability to avoid
violation of Rule 10b–10 so long as the
broker or dealer provides the
disclosures promptly after discovery of
a defect in its good faith efforts to
comply.69 This ability to provide
disclosures either at the time specified
in the de minimis exception or promptly
after discovery of a defect in good faith
efforts to do so was necessary, in the
context of the de minimis exception, to
avoid a situation in which a ‘‘foot fault’’
in Rule 10b–10 compliance would make
the exemption from broker registration
unavailable.70 Because no exemption
from broker registration is at risk if the
broker or dealer does not comply with
the conditions of the Rule 10b–10
exemption in this Order, this ‘‘foot
fault’’ relief is not necessary. Rather, the
consequence of not complying with
either Rule 10b–10’s timing
requirements, or Rule 15Fi–2(b) and
(c)’s form and timing requirements (and
Rule 10b–10(c)’s timing requirements as
applicable) if the broker or dealer is
relying on this exemption, is that a
broker or dealer would find itself out of
compliance with Rule 10b–10.
Accordingly, pursuant to its authority
under Exchange Act Section 36, the
Commission finds that it is necessary or
appropriate in the public interest, and
consistent with the protection of
investors, to exempt a broker or dealer
from the requirement to give or send to
a customer the disclosures required by
Rule 10b–10(a) at or before completion
of the transaction solely in connection
with such broker or dealer or its
associated persons arranging,
negotiating or executing a securitybased swap transaction on behalf of a
qualified majority-owned affiliate,
provided that such broker or dealer
gives or sends to the customer written
notification containing the disclosures
required by Rule 10b–10(a) in
connection with such arranging,
negotiating or executing in accordance
with the time and form requirements for
a trade acknowledgment set forth in
Rule 15Fi–2(b) and (c) under the
Exchange Act and, as applicable, Rule
10b–10(c) under the Exchange Act. For
purposes of this exemption, the term
of receipt of the request,’’ except that ‘‘in the case
of information pertaining to a transaction effected
more than 30 days prior to receipt of the request,
the information shall be given or sent to the
customer within 15 business days.’’
69 See SIFMA September 2020 Letter at 5.
70 See Cross-Border Adopting Release, 85 FR at
6280 n.113.
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‘‘qualified majority-owned affiliate’’
means a majority-owned affiliate (as
such term is defined in Rule 3a71–
3(a)(10) under the Exchange Act) of
such broker or dealer that is a registered
security-based swap dealer.
4. Request for Relief From the
Hypothecation Requirements With
Respect to Security-Based Swap
Accounts
Exchange Act Section 8 provides, in
pertinent part, that it shall be unlawful
for any broker or dealer, in
contravention of such rules and
regulations as the Commission shall
prescribe for the protection of investors,
to hypothecate or arrange for the
hypothecation of any securities carried
for the account of any customer under
circumstances: (1) That will permit the
commingling of the customer’s
securities without the customer’s
written consent with the securities of
any other customer; (2) that will permit
such securities to be commingled with
the securities of any person other than
a bona fide customer; or (3) that will
permit such securities to be
hypothecated, or subjected to any lien
or claim of the pledgee, for a sum in
excess of the aggregate indebtedness of
such customers in respect of such
securities.71 Pursuant to this authority,
the Commission adopted Exchange Act
Rules 8c–1 and 15c2–1. Exchange Act
Rule 8c–1 places limitations on the
ability of a broker or dealer to
hypothecate ‘‘any securities carried for
the account of any customer.’’ 72
Exchange Act Rule 15c2–1 defines the
phrase ‘‘fraudulent, deceptive, or
manipulative act or practice’’ as used in
Exchange Act Section 15(c)(2) to
include the hypothecation of ‘‘any
securities carried for the account of any
customer’’ that would be inconsistent
with the limitations imposed by Rule
8c–1.73 The commenter made two
requests related to these provisions.
First, the commenter asked the
Commission to clarify how the phrase
‘‘securities carried for the account of
any customer’’ as used in Exchange Act
Rules 8c–1 and 15c2–1 applies to
security-based swaps.74 The commenter
stated that, for the purposes of the
possession or control requirements of
Exchange Act Rule 15c3–3 as applied to
security-based swaps, the Commission,
among other amendments, added a
definition of ‘‘excess securities
71 15
U.S.C. 78h.
17 CFR 240.8c–1.
73 See 17 CFR 240.15c2–1.
74 See SIFMA January 2020 Letter at 3–4.
72 See
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collateral’’ to the Rule 15c3–3.75 Rule
15c3–3 was further amended to require
a broker or dealer to promptly obtain
and thereafter maintain physical
possession or control of all excess
securities collateral carried for the
security-based swap accounts of
security-based swap customers.76 The
commenter requested confirmation that,
for the purposes of Exchange Act Rules
8c–1 and 15c2–1, the term ‘‘securities
carried for the account of any customer’’
be interpreted in connection with
security-based swaps to have the same
meaning as ‘‘excess securities
collateral’’ has for the purposes of
Exchange Act Rule 15c3–3. For the
reasons discussed below, the
Commission is not issuing the
interpretation suggested by the
commenter and instead is issuing a
conditional exemption from Rules 8c–1
and 15c2–1 for securities and money
market instruments carried in a
security-based swap account of a
security-based swap customer.
The term ‘‘excess securities
collateral’’ as used in Exchange Act
Rules 15c3–3 and 18a–4 77 with respect
to security-based swaps is modelled on
the terms ‘‘fully paid securities’’ and
‘‘excess margin securities’’ as used in
Exchange Act Rule 15c3–3 with respect
to securities that are not security-based
swaps.78 Exchange Act Rule 15c3–3
requires a broker or dealer to promptly
obtain and thereafter maintain physical
possession or control of all fully paid
and excess margin securities carried for
the account of customers.79 Securities
that have been hypothecated are not in
the physical possession or control of the
broker or dealer.80 However, securities
that meet the definition of ‘‘margin
securities’’ in Exchange Act Rule 15c3–
3 may be hypothecated, subject to the
requirements of that rule. Similarly,
with respect to security-based swaps,
Exchange Act Rules 15c3–3 and 18a–4
75 Id.; see also Capital, Margin and Segregation
Adopting Release, 84 FR at 43935–38; 17 CFR
240.15c3–3(p)(1)(ii). Exchange Act Rule 18a–4
imposes segregation requirements on security-based
swap dealers that are not brokers or dealers (other
than OTC derivatives dealers). 17 CFR 240.18a–4.
Exchange Act Rule 18a–4 has a parallel definition
of ‘‘excess securities collateral.’’ See 17 CFR
240.18a–4(a)(2).
76 See 17 CFR 240.15c3–3(p)(2). Exchange Act
Rule 18a–4 has a parallel requirement that the
security-based swap dealer promptly obtain and
thereafter maintain physical possession or control
of all excess securities collateral carried for the
security-based swap accounts of security-based
swap customers. See 17 CFR 240.18a–4(b).
77 17 CFR 240.18a–4.
78 See Capital, Margin, and Segregation Adopting
Release, 84 FR at 43935; 17 CFR 240.15c3–3(a)(3),
(a)(5) and (p)(1)(ii).
79 See 17 CFR 240.15c3–3(b).
80 See 17 CFR 240.15c3–3(c) and (d); see also 17
CFR 240.15c3–3(p)(2); 17 CFR 240.18a–4(b).
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require that a broker, dealer or securitybased swap dealer promptly obtain and
thereafter maintain physical possession
or control of securities and money
market instruments carried for the
account of a security-based swap
customer that meet the rules’ definitions
of ‘‘excess securities collateral.’’ 81
Securities or money market instruments
carried in the accounts of security-based
swap customers that do not meet the
definition of ‘‘excess securities
collateral’’ may be hypothecated subject
to the requirements of Exchange Act
Rules 15c3–3 and 18a–4. Consequently,
while the respective limitations and
anti-fraud provisions of Rules 8c–1 and
15c2–1 apply to ‘‘any securities carried
for the account of any customer,’’ the
possession or control requirements of
Rules 15c3–3 and 18a–4 apply to fully
paid and excess margin securities and
excess securities collateral, respectively.
Because Exchange Act Rules 8c–1 and
15c2–1 apply to any securities carried
for the account of any customer,
interpreting the term ‘‘any securities
carried for the account of any customer’’
in those rules to mean ‘‘excess securities
collateral’’ as defined in Rules 15c3–3
and 18a–4 for the purposes of a securitybased swap would not be appropriate.
Doing so could imply that the
hypothecation rules do not apply to
certain securities carried for the
accounts of customers when the rules,
in fact, apply to ‘‘any securities carried
for the account of any customer.’’
However, a limited exemption from
Rules 8c–1 and 15c2–1 with respect to
securities and money market
instruments carried in the securitybased swap accounts of security-based
swap customers would be appropriate
for the following reasons.
When adopting the segregation
requirements for security-based swaps,
the Commission did not contemplate
imposing the respective limitations and
anti-fraud provisions of Exchange Act
Rules 8c–1 and 15c2–1 to securities and
money market instruments carried in
security-based swap accounts of
security-based swap customers.
Moreover, the Dodd-Frank Act did not
mandate that the Commission
implement requirements with respect to
security-based swaps that are analogous
to Rules 8c–1 and 15c2–1. Further,
Rules 8c–1 and 15c2–1 were adopted in
1940 and were not designed to address
security-based swaps.82 Exchange Act
81 See 17 CFR 240.15c3–3(p)(2); 17 CFR 240.18a–
4(b).
82 Hypothecation of Customers’ Securities, 5 FR
4530 (Nov. 19, 1940) (adopting Exchange Act Rule
8c–1); Hypothecation of Customers’ Securities, 5 FR
4531 (Nov. 19, 1940) (adopting Exchange Act Rule
15c2–1).
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Rule 15c3–3 was adopted in 1972 to
provide comprehensive protection to
customer funds and securities held by
brokers and dealers.83 The Commission
addressed the protection of securities
and money market instruments carried
in security-based swap accounts of
security-based swap customers through
the recent amendments to Exchange Act
Rule 15c3–3 and the adoption of new
Exchange Act Rule 18a–4.84 The
amendments and new rule addressing
security-based swaps were modelled on
the requirements and limitations in
Exchange Rule 15c3–3 applicable to
securities that are not security-based
swaps. They were not modelled on
Exchange Act Rules 8c–1 and 15c2–1.
Finally, Rules 8c–1 and 15c2–1 provide
OTC derivatives dealers exemptions
from their requirements. Therefore, it is
not necessary to impose the limitations
and anti-fraud provisions of Exchange
Act Rules 8c–1 and 15c2–1 to securities
and money market instruments carried
in security-based swap accounts of
security-based swap customers.85 This
approach will achieve the objective
sought by the commenter in proposing
the interpretation discussed above: That
Rules 8c–1 and 15c2–1 not apply to
securities and money market
instruments carried in a security-based
swap account of a security-based swap
customer.
However, Rules 8c–1 and 15c2–1
continue to apply to any securities
carried for all other customers. For
example, as discussed above, the
requirement to promptly obtain and
thereafter maintain physical possession
or control of securities (other than
security-based swaps) carried for the
account of customers in Exchange Act
Rule 15c3–3 does not apply to ‘‘margin
83 See Broker-Dealers; Maintenance of Certain
Basic Reserves, Exchange Act Release No. 9856
(Nov. 17, 1972), 37 FR 25224 (Nov. 29, 1972) (‘‘Rule
15c3–3 as adopted herein is well fashioned to
furnish the protection for the integrity of customer
funds and securities as envisioned by Congress
when it amended section 15(c) (3) of the [Exchange]
Act by adopting section 7(d) of the Securities
Investor Protection Act of 1970 . . .’’); see also Pub.
L. 91–598 (Dec. 30, 1970). The hypothecation rules
(Rules 8c–1 and 15c2–1) require that a broker-dealer
segregate customer securities from its own
proprietary securities and prescribe limits on a
broker-dealer’s ability to hypothecate customer
securities.
84 See Capital, Margin, and Segregation Adopting
Release, 84 FR at 43930–43, 17 CFR 240.15c3–3(p);
17 CFR 240.18a–4.
85 A security-based swap dealer that is not also
registered as a broker or dealer is not subject to
Exchange Act Rules 8c–1 and 15c2–1. Moreover, a
security-based swap dealer that is also registered as
an OTC derivatives dealer can provide notifications
to its counterparties to remove them from the
definitions of ‘‘customer’’ in Exchange Act Rules
8c–1 and 15c2–1 and, thereby, avoid the
requirement to comply with those rules. See 17 CFR
8c–1(b); 17 CFR 240.15c2–1(b).
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securities’’ as defined in the rule.86 The
commenter did not request that ‘‘margin
securities,’’ as defined in Rule 15c3–3,
should be exempt from Exchange Act
Rules 8c–1 and 15c2–1 or that the
Commission interpret the term in a
manner that removes them from the
requirements of those rules.
For these reasons, the Commission
finds that it is necessary or appropriate
in the public interest, and is consistent
with the protection of investors to
exempt securities and money market
instruments carried in a security-based
swap account of a security-based swap
customer from the requirements of
Exchange Act Rules 8c–1 and 15c2–1;
provided the account does not hold
‘‘margin securities’’ as defined in
Exchange Act Rule 15c3–3.87 Further,
this exemption does not modify the
requirement that a broker, dealer or
security-based swap dealer promptly
obtain and thereafter maintain physical
possession or control of securities or
money market instruments carried for
the accounts of security-based swap
customers that meet the definition of
‘‘excess securities collateral’’ as required
by Exchange Act Rules 15c3–3 and 18a–
4, as applicable.
Second, the commenter asked the
Commission to extend most, but not all,
of the Unlinked Temporary Exemptions
from the hypothecation requirements for
security-based swaps. The current
Unlinked Temporary Exemptions from
the hypothecation requirements apply
without regard to whether these
requirements applied to the broker or
dealer’s security-based swap positions
or activities as of July 15, 2011 (i.e., the
day before relevant provisions of the
86 See
17 CFR 240.15c3–3(a)(3), (a)(4), (a)(5) and
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(b).
87 As indicated, the relief does not extend to
accounts that hold ‘‘margin securities’’ as that term
is defined in Exchange Act Rule 15c3–3. Therefore,
the exemption would not apply if the account holds
securities positions, other than security-based
swaps, that trigger the margin requirements of
Regulation T of the Board of Governors of the
Federal Reserve System and/or the margin
requirements of the self-regulatory organizations
applicable to securities that are not security-based
swaps (e.g., long securities positions (other than
security-based swaps) that have been financed by
the broker or dealer, short securities positions
(other than security-based swaps), or listed
options). However, as discussed above, the
exemption applies to securities and money market
instruments held in a security-based swap account
of a security-based swap customer; provided they
are not ‘‘margin securities’’ as defined in Rule
15c3–3. For the purposes of this exemption, a
broker or dealer need not treat fully paid securities
and money market instruments in a security-based
swap account of a security-based swap customer
that serve as collateral for security-based swap
positions and/or to meet the margin requirements
of Exchange Act Rule 18a–3 as ‘‘margin securities’’
as that term is defined in Rule 15c3–3.
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Dodd-Frank Act became effective),88
and are set to expire on November 5,
2020.89 By contrast, the Linked
Temporary Exemptions from related
customer protection requirements in
Exchange Act Rule 15c3–3 are limited to
security-based swap positions and
activities not subject to that rule as of
July 15, 2011, and are set to expire on
October 6, 2021, which is the
compliance date for the Commission’s
security-based swap-related
amendments to Rule 15c3–3.90 The
commenter asked the Commission to
extend the Unlinked Temporary
Exemptions from the hypothecation
requirements so that they would expire
on the compliance date for these
security-based swap-related
amendments to Rule 15c3–3.91 The
commenter asked the Commission to
extend these exemptions consistent
with the scope of the Linked Temporary
Exemptions from Rule 15c3–3—that is,
only to the extent that the
hypothecation requirements did not
apply to the broker or dealer’s securitybased swap positions or activities as of
July 15, 2011.92 The commenter stated
that the policies, procedures, processes,
systems and controls that brokers and
dealers use to comply with Rules 8c–1
and 15c2–1 are integrated with the
policies, procedures, processes, systems
and controls that they use to comply
with Rule 15c3–3. Therefore, the
commenter requested that the Unlinked
Temporary Exemptions from Rules 8c–
1 and 15c2–1 be extended to align with
the expiration date for the Linked
Temporary Exemptions from Rule 15c3–
3.93
For the reasons provided by the
commenter, the Commission believes
that it would be appropriate to extend
the Unlinked Temporary Exemptions
from Rules 8c–1 and 15c2–1 so that they
expire at the same time as the Linked
Temporary Exemptions from Rule 15c3–
3. This extension would provide brokers
and dealers time to implement a single
set of policies, procedures, and controls
to comply with Rules 8c–1, 15c2–1 and
15c3–3 as they apply to security-based
swap positions. Accordingly, pursuant
to its authority under Exchange Act
Section 36, the Commission finds that it
is necessary or appropriate in the public
interest, and consistent with the
protection of investors, to extend the
88 See 2011 Exchange Act Exemptive Order, 76
FR at 39939.
89 See January 2020 Extension Order, 85 FR at
2766.
90 See 2014 Extension Order, 79 FR at 7734.
91 See SIFMA January 2020 Letter at 3–4; SIFMA
December 2018 Letter at 5.
92 See SIFMA January 2020 Letter at 3–4.
93 See id.
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Unlinked Temporary Exemptions from
Exchange Act Section 8 and Exchange
Act Rules 8c–1 and 15c2–1 until
October 6, 2021.
5. Request for Exemptions From Broker
and Dealer Disclosure Requirements
Relating to Extensions of Credit
Exchange Act Rule 15c2–5(a)(1)
imposes disclosure requirements, and
Rule 15c2–5(a)(2) imposes suitability
requirements, on brokers and dealers
that that directly or indirectly offer to
extend credit to or arrange any loan for,
or extend to or participate in any loan
for, any person in connection with the
offer or sale of any security to, or the
attempt to induce the purchase of any
security by, such person, subject to
certain exceptions. Exchange Act Rule
10b–16 imposes additional
requirements on brokers and dealers
that directly or indirectly extend credit
to any customer in connection with any
securities transaction. Subject to certain
exceptions, these brokers and dealers
must establish procedures to assure that
each customer receives certain lending
disclosures.94 Citing the Commission’s
2002 guidance on the application of
certain securities laws to security
futures products,95 the commenter
expressed the view that security-based
swaps ‘‘should not in and of themselves
constitute extensions of credit’’ subject
to these suitability and disclosure
requirements.96 The commenter asked
the Commission to confirm this view or,
in the alternative, exempt security-based
swap activity from these extension of
credit requirements.97
The Commission believes that, based
on the facts and circumstances of a
particular transaction, an extension of
credit subject to the suitability and
disclosure requirements of Rules 15c2–
5 and 10b–16 may or may not be made
in connection with a security-based
swap transaction. This belief is
consistent with both the Commission’s
2002 guidance 98 on the application of
94 See
Exchange Act Rule 10b–16(a).
Guidance on the Application of
Certain Provisions of the Securities Act of 1933, the
Securities Exchange Act of 1934, and Rules
Thereunder to Trading in Security Futures
Products, Exchange Act Release No. 46101 (Jun. 21,
2002), 67 FR 43234 (Jun. 27, 2002) (‘‘Security
Futures Release’’).
96 See SIFMA January 2020 Letter at 4.
97 See SIFMA September 2020 Letter at 6–7;
SIFMA January 2020 Letter at 4; SIFMA December
2018 Letter at 5–6; SIFMA November 2018 Letter
at 3.
98 This guidance noted that ‘‘Rule 10b–16 applies
to all extensions of credit, directly or indirectly, to
any customer in connection with any securities
transaction, including a security future. Investors in
security futures, including those extended credit in
connection with margining, should benefit from the
transparency of credit terms fostered by this Rule.’’
95 Commission
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extension of credit requirements to
security futures products and the
Commission and the Commodity
Futures Trading Commission’s 2012
joint release 99 on the definition of
‘‘security-based swap.’’ The relationship
between an extension of credit and a
security-based swap thus does not
shield the extension of credit from
application of Rules 15c2–5 and 10b–16.
When an extension of credit is made in
connection with a security-based swap
transaction, however, brokers and
dealers may as appropriate to the facts
and circumstances devise a single
suitability assessment to satisfy
applicable provisions of Rule 15c2–
5(a)(2) and Exchange Act Rule 15Fh–
3(f),100 as well as a single set of
disclosures to satisfy applicable
provisions of Rules 10b–16 and 15c2–
5(a)(1) and Exchange Act Rule 15Fh–
3(b).101
Because an extension of credit may or
may not be made in connection with a
security-based swap transaction, the
Commission believes that a permanent
exemption from Rules 10b–16 and
15c2–5 for security-based swap activity
is not warranted. The Commission thus
is not further extending the Unlinked
Temporary Exemptions from Exchange
Act Rules 10b–16 and 15c2–5.
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6. Request for Exemptions From Certain
Limitations on an OTC Derivatives
Dealer’s Activities
Exchange Act Rule 15a–1 limits the
securities activities of an OTC
derivatives dealer. The commenter
made three requests related to these
See Security Futures Release, 67 FR at 43246. An
extension of credit could be part of a transaction
involving a security future.
99 The Commissions noted that, depending on the
facts and circumstances, a loan participation may
be a security but not a ‘‘security-based swap,’’ the
definition of which excludes certain agreements,
contracts and transactions that provide for the
purchase or sale of 1 or more securities on a fixed
or contingent basis and that are subject to the
Securities Act of 1933 and the Exchange Act. See
Product Definitions Adopting Release, 77 FR at
48251; Exchange Act Section 3(a)(68)(A)(i) (a
security-based swap must be a ‘‘swap’’ as defined
in certain provisions of Section 1a of the
Commodity Exchange Act); Commodity Exchange
Act Section 1a(47)(B)(v)–(vi) (exclusion of these
agreements, contracts and transactions from the
definition of ‘‘swap’’). Alternatively, a loan
participation could be a security-based swap if the
grantor of the loan participation extends financing
to the participant. See Product Definitions Adopting
Release, 77 FR at 48251. This ‘‘leverage could be
indicative of an instrument that is merely an
exchange of payments and not a transfer of the
ownership of the underlying loan or commitment,
such as may be the case with a . . . security-based
swap.’’ Product Definitions Adopting Release, 77
FR at 48251. An extension of financing could be
part of a transaction classified as a security-based
swap.
100 17 CFR 240.15Fh–3(f).
101 17 CFR 240.15Fh–3(b).
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limitations. First, Rule 15a–1(a)–(b)
permits OTC derivatives dealers to
engage in dealer activities when the
security is an eligible OTC derivatives
instrument. Eligible OTC derivatives
instruments are defined to exclude any
contract, agreement or transaction that
is ‘‘one of a class of fungible
instruments that are standardized as to
their material economic terms.’’ 102 The
commenter noted that centrally cleared
security-based swaps might not qualify
as eligible OTC derivatives instruments
and thus Rule 15a–1 might not permit
OTC derivatives dealers to deal in
them.103 Based on this specific concern,
the commenter requested a permanent
exemption for all security-based swaps
with or for eligible contract participants
from all provisions of Rule 15a–1.104
Because centrally cleared securitybased swaps typically contain
standardized terms, they might be
fungible instruments standardized as to
their material economic terms and thus
might not qualify as eligible OTC
derivatives instruments. Though not
raised in the commenter’s request, the
same also is true of security-based
swaps that are eligible for central
clearing even if they are not in fact
centrally cleared. As a result, dealing in
these types of security-based swaps
could eliminate a market participant’s
OTC derivatives dealer status and
require full registration as a dealer, even
if that security-based swap dealing is
with an eligible contract participant and
thus excluded from the statutory
definition of ‘‘dealer.’’ 105 Because
102 See Exchange Act Rule 3b–13(b)(2), 17 CFR
240.3b–13(b)(2).
103 See SIFMA September 2020 Letter at 7; SIFMA
January 2020 Letter at 4–5. In earlier requests, the
commenter also noted that ‘‘some [security-based
swaps] might, in the future, be listed or traded on
an exchange.’’ See SIFMA December 2018 Letter at
6–7; SIFMA November 2018 Letter at 4. Because
eligible OTC derivatives also exclude any contract,
agreement or transaction that is listed or traded on
a national securities exchange or registered national
securities association or facility or market thereof,
in earlier letters the commenter also requested an
exemption from Rule 15a–1 to allow OTC
derivatives dealers to deal in those instruments. See
Exchange Act Rule 3b13(b)(2); SIFMA December
2018 Letter at 6–7; SIFMA November 2018 Letter
at 4. The Commission is not providing an
exemption or guidance regarding the application of
Rule 15a–1 to those security-based swaps because
at this time no security-based swap is listed or
traded on a national securities exchange or
registered national securities association or facility
or market thereof. If a security-based swap becomes
so listed or traded in the future, the Commission
would consider a request for exemption from or
guidance regarding Rule 15a–1 for those
instruments based on the facts and circumstances
at that time.
104 See SIFMA January 2020 Letter at 4–5.
105 See Exchange Act Rule 15a–1(a)(1)(i)
(securities activities of an OTC derivatives dealer
must be limited, in relevant part, to engaging in
dealer activities in eligible OTC derivatives
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70675
Exchange Act Section 3(a)(5) excludes
security-based swap dealing with or for
an eligible contract participant from the
definition of ‘‘dealer,’’ the Commission
believes that this same dealing activity
should not cause an OTC derivatives
dealer to lose its eligibility for Rule 15a–
1’s exemption from full dealer
registration. Such a result could be
avoided if eligible OTC derivative
instruments included security-based
swaps with or for an eligible contract
participant whose terms are
standardized to be eligible for central
clearing. Because including these
security-based swaps within the scope
of eligible OTC derivative instruments
would address the commenter’s concern
about OTC derivatives dealers’ ability to
deal in centrally cleared security-based
swaps (and also allows OTC derivatives
dealers to deal in security-based swaps
whose terms are standardized to be
eligible for central clearing but that are
not in fact centrally cleared), the
Commission does not believe that an
exemption for these security-based
swaps from all provisions of Rule 15a–
1 is necessary. Accordingly, pursuant to
its authority under Exchange Act
Section 15(a)(2) and Exchange Act Rule
15a–1(b)(2), the Commission finds that
it is consistent with the public interest
and the protection of investors to
determine that security-based swaps
with or for an eligible contract
participant whose terms are
standardized to be eligible for central
clearing are within the scope of an
‘‘eligible OTC derivative instrument’’ as
defined in Rule 3b–13(b)(2).
Second, Rule 15a–1(c) generally
requires that all securities transactions
of an OTC derivatives dealer, including
OTC derivatives transactions, be
effected through a full-purpose broker or
dealer or full-purpose broker or dealer
affiliate.106 Further, Rule 15a–1(d)
requires OTC derivatives dealers to
conduct certain customer-facing
contacts through registered
representatives of a full-purpose broker
or full-purpose broker or dealer affiliate.
These requirements do not apply to
transactions with a registered broker or
dealer, a bank acting in a dealer
capacity, a foreign broker or dealer, or
any affiliate of the OTC derivatives
dealer.107 The commenter requested that
instruments that are securities). Rule 15a–1’s
requirement that OTC derivatives dealers limit their
securities dealing to eligible OTC derivatives
instruments does not contain an exception for
security-based swaps with an eligible contract
participant that are not eligible OTC derivatives
instruments.
106 See Exchange Act Rule 15a–1(c).
107 See Exchange Act Rule 15a–1(c)–(d).
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the Commission exempt OTC
derivatives dealers from the requirement
in Rule 15a–1(d) because standalone
and bank-affiliated SBS Entities are not
required to employ registered
representatives for customer-facing SBS
transactions.108 The commenter also
requested a permanent exemption for all
security-based swaps with or for eligible
contract participants from all provisions
of Rule 15a–1.109
SBS Entities are subject to the Title
VII regulatory framework, while
standalone OTC derivatives dealers are
not. The Commission thus does not
believe that it is necessary or
appropriate to exempt standalone OTC
derivatives dealers from Rule 15a–1
simply because its requirements do not
apply to other market participants that
are subject to a separate, comprehensive
regulatory framework. By contrast,
however, a dually-registered OTC
derivatives dealer and SBS Entity would
be subject to the Title VII regulatory
framework in relation to its securitybased swap transactions. Such a duallyregistered entity could find that Rule
15a–1 requires it either to effect
security-based swap transactions
through a registered broker or dealer (in
the case of Rule 15a–1(c)) or utilize
registered representatives for certain
customer-facing security-based swap
transactions (in the case of Rule 15a–
1(d)), on the one hand, or to register as
a full-purpose dealer, on the other hand,
even if the security-based swap is with
or for an eligible contract participant
and thus excluded from the definition of
‘‘dealer.’’ To avoid this result, the
Commission believes that a duallyregistered OTC derivatives dealer and
SBS Entity’s security-based swap
transactions with or for an eligible
contract participant, and its
communications and contacts with an
eligible contract participant concerning
a security-based swap transaction,
should be exempt from Rules 15a–1(c)
and (d), respectively.
Accordingly, pursuant to its authority
under Exchange Act Section 15(a)(2),
the Commission finds that it is
consistent with the public interest and
the protection of investors to exempt a
registered OTC derivatives dealer that is
also a registered SBS Entity from Rule
15a–1(c) solely in connection with
security-based swap transactions with
or for an eligible contract participant,
and from Rule 15a–1(d) solely in
connection with communications and
contacts with an eligible contract
participant concerning a security-based
swap transaction.
108 See
109 See
SIFMA January 2020 Letter at 5.
SIFMA January 2020 Letter at 4–5.
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Third, the commenter asked the
Commission to extend the Unlinked
Temporary Exemptions from Rule 15a–
1 until the compliance date for the
Commission’s SBS Entity registration
requirements,110 which is October 6,
2021.111 The current Unlinked
Temporary Exemptions from Rule 15a1 are set to expire on November 5,
2020.112
As discussed above, the Commission
is exempting a registered OTC
derivatives dealer that is also a
registered SBS Entity from Rules 15a–
1(c) and (d) for certain security-based
swap-related communications and
contacts. OTC derivatives dealers will
not, however, begin counting
transactions towards the SBS Entity
registration thresholds until August 6,
2021. The Commission believes that
requiring OTC derivatives dealers to
implement policies, procedures and
controls to comply with Rules 15a–1(c)
and (d) for the short period until they
begin to register as SBS Entities
potentially could impose undue cost
and resource burdens and cause
unnecessary market disruption. Rather,
extending the Unlinked Temporary
Exemptions from Rule 15a–1(c) and (d)
until October 6, 2021, would allow
market participants to implement
policies, procedures and controls that
take into account this new limited
exemptive relief from Rule 15a–1(c) and
(d) at the time when that relief can be
utilized. Accordingly, pursuant to its
authority under Exchange Act Section
36, the Commission finds that it is
necessary or appropriate in the public
interest, and consistent with the
protection of investors, to extend the
Unlinked Temporary Exemptions from
Rules 15a–1(c) and (d) until October 6,
2021. This limited temporary exemption
addresses the commenter’s concern
about OTC derivatives dealers’ ability to
conduct customer-facing contacts
without a registered representative until
they can begin to register as SBS
Entities.
7. Exchange Act Section 29(b)
Exchange Act Section 29(b) 113
generally provides that contracts made
in violation of any provision of the
Exchange Act or the rules or regulations
thereunder shall be void ‘‘(1) as regards
the rights of any person who, in
violation of any such provision . . .
shall have made or engaged in the
performance of any such contract, and
110 See
111 See
SIFMA December 2020 Letter at 6.
Cross-Border Adopting Release, 85 FR at
6345.
112 See January 2020 Extension Order, 85 FR at
2766.
113 15 U.S.C. 78cc(b).
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(2) as regards the rights of any person
who, not being a party to such contracts,
shall have acquired any right thereunder
with actual knowledge of the facts by
reason of which the making or
performance of such contracts in
violation of any such provision.’’ In
2011, the Commission provided
temporary exemptive relief from Section
29(b) in connection with the temporary
exemptions that include the Linked
Temporary Exemptions and Unlinked
Temporary Exemptions discussed in
this Order. By its terms, that exemption
from Section 29(b) will expire on
November 5, 2020 (for the Unlinked
Temporary Exemptions discussed but
not extended in this Order) or October
6, 2021 (for the remaining Linked
Temporary Exemptions and Unlinked
Temporary Exemptions discussed in
this Order).114 The Commission made
clear that it did not believe that Section
29(b) would apply to provisions subject
to those temporary exemptions, and that
it provided the exemption from Section
29(b) only to make that view clear to
market participants and ‘‘to eliminate
any possible legal uncertainty or market
disruption.’’ 115 Likewise, the
Commission believes that Section 29(b)
would not apply to circumstances in
which a market participant complies
with the permanent exemptive relief
provided in this Order, and therefore,
for the reasons discussed above, is not
providing further exemptive relief from
Section 29(b).
II. Exemption in Connection With
Registration of Security-Based Swap
Dealers and Major Security-Based
Swap Participants
Also in 2011, the Commission issued
an order providing separate temporary
exemptive relief from Section 29(b) in
connection with the portion of the
Dodd-Frank Act’s security-based swaprelated amendments to the Exchange
Act for which the Commission has taken
the view that compliance will be
triggered by registration of a person or
by adoption of final rules by the
Commission, or for which the
Commission provided an exception or
exemptive relief.116 By its terms, most of
114 See 2011 Exchange Act Exemptive Order, 76
FR at 39940 (Section 29(b) exemptive relief in
connection with temporary exemptive relief from
other Exchange Act provisions expires at ‘‘such
time as the underlying exemptive relief expires’’).
115 See 2011 Exchange Act Exemptive Order, 76
FR at 39926.
116 See Temporary Exemptions and Other
Temporary Relief, Together with Information on
Compliance Dates for New Provisions of the
Securities Exchange Act of 1934 Applicable to
Security-Based Swaps, Exchange Act Release No.
64678 (Jun. 15, 2011), 76 FR 36287, 36307 (‘‘2011
Compliance Date Order’’).
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this exemptive relief expires on such
date as the Commission specifies.117
The Commission made clear then that
it did not believe that Section 29(b)
would apply to the Dodd-Frank Act’s
security-based swap-related
amendments to the Exchange Act for
which the Commission has taken the
view that compliance will be triggered
by registration of a person or by
adoption of final rules by the
Commission, or for which the
Commission provided an exception or
exemptive relief, and that it provided
the exemption from Section 29(b) only
‘‘to avoid possible legal uncertainty or
market disruption.’’ 118 The Commission
granted this temporary exemptive relief,
however, ‘‘to avoid possible legal
uncertainty or market disruption.’’ 119
The Commission believes now, more
than nine years after the relevant
amendments to the Dodd-Frank Act
took effect, that the opportunity for
possible legal uncertainty or market
disruption related to the effective date
of these amendments has passed. To
provide market participants with
certainty about when this separate
temporary exemptive relief from Section
29(b) will expire, the Commission now
believes that all of this exemptive relief
from Section 29(b) should expire on the
same date. Because some of this relief is
117 See 2011 Compliance Date Order, 76 FR at
36307. The Section 29(b) exemption related to
exemptions from Exchange Act Sections 3E(f) and
15F(b)(6) provided in the 2011 Compliance Date
Order expire on the compliance date for rules
governing the registration of SBS Entities, which
will be October 6, 2021. See Order Pursuant to
Sections 15F(b)(6) and 36 of the Securities
Exchange Act of 1934 Extending Certain Temporary
Exemptions and a Temporary and Limited
Exception Related to Security-Based Swaps,
Exchange Act Release No. 75919 (Sep. 15, 2015), 80
FR 56519 (Sep. 18, 2015). The exemption from
Exchange Act Section 6(l) provided in the 2011
Compliance Date Order expired 60 days after the
August 13, 2012, publication of the Product
Definitions Adopting Release in the Federal
Register. See Order Extending Temporary
Conditional Exemption in Connection with the
Effectiveness of the Definition of Eligible Contract
Participant, Exchange Act Release No. 67480 (Jul.
20, 2012), 77 FR 43878, 43879 (Jul. 26, 2012). In a
later release, the Commission implied that the 2011
Compliance Date Order had specified that the
Section 29(b) exemption related to this exemption
from Section 6(l) would expire at the same time as
the exemption from Section 6(l). See Further
Definition of ‘‘Swap Dealer,’’ ‘‘Security-Based Swap
Dealer,’’ ‘‘Major Swap Participant,’’ ‘‘Major
Security-Based Swap Participant’’ and ‘‘Eligible
Contract Participant,’’ Exchange Act Release No.
66868 (Apr. 27, 2012), 77 FR 30596, 30700 n.1248
(May 23, 2012). Rather, the 2011 Compliance Date
Order specified that this Section 29(b) exemption
would expire on such date as the Commission
specifies. See 2011 Compliance Date Order, 76 FR
at 36307. Market participants thus may be uncertain
whether this portion of the 29(b) exemption has
expired.
118 See 2011 Compliance Date Order, 76 FR at
36305.
119 See id.
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already scheduled to expire on the
compliance date for rules regarding
registration and regulation of SBS
Entities,120 which will be October 6,
2021, the Commission thus believes that
it is appropriate for all of this Section
29(b) relief to expire on that date.
Accordingly, the Commission has
determined that this exemption from
Section 29(b) shall expire on October 6,
2021.
III. Conclusion
It is hereby ordered, pursuant to
Section 15(a)(2) of the Exchange Act,
that a ‘‘foreign broker or dealer,’’ as such
term is defined in Rule 15a–6(b)(3)
under the Exchange Act, whose
activities in securities other than
security-based swaps with or for an
eligible contract participant are
conducted either in compliance with
Rule 15a–6 under the Exchange Act or
without the jurisdiction of the United
States, shall be exempt from the
registration requirement of Section
15(a)(1) of the Exchange Act solely in
connection with the foreign broker or
dealer’s security-based swap dealing
with or for an eligible contract
participant.
It is hereby ordered, pursuant to
Section 15(a)(2) of the Exchange Act,
that until November 1, 2022, a
registered security-based swap dealer
and its associated persons shall be
exempt from the broker registration
requirement of Section 15(a)(1) of the
Exchange Act solely in connection with
such registered security-based swap
dealer or associated person arranging,
negotiating or executing a securitybased swap transaction with or for a
non-U.S. person eligible contract
participant on behalf of a non-U.S.
person qualified majority-owned
affiliate; provided that (A) such
registered security-based swap dealer
creates and maintains books and records
relating to such arranging, negotiating or
executing activity that are required by
Rules 18a–5 and 18a–6 under the
Exchange Act and (B) if Rule 10b–10
under the Exchange Act would apply to
such arranging, negotiating or executing
activity, such registered security-based
swap dealer provides to the customer
the disclosures required by Rule 10b–
10(a)(2) (excluding Rule 10b–10(a)(2)(i)
and (ii)) and Rule 10b–10(a)(8) in
accordance with the time and form
requirements set forth in Rule 15Fi-2(b)
and (c) under the Exchange Act or,
alternatively, promptly after discovery
of any defect in such registered securitybased swap dealer’s good faith effort to
120 See Cross-Border Adopting Release, 85 FR at
6345.
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70677
comply with such requirements. For
purposes of this exemption, the term
‘‘qualified majority-owned affiliate’’
means a majority-owned affiliate (as
such term is defined in Rule 3a71–
3(a)(10) under the Exchange Act) of
such registered security-based swap
dealer that is itself also a registered
security-based swap dealer.
It is hereby further ordered, pursuant
to Section 36 of the Exchange Act, that
a broker or dealer shall be exempt from
the requirement to give or send to a
customer the disclosures required by
Rule 10b–10(a) under the Exchange Act
at or before completion of the
transaction solely in connection with
such broker or dealer or its associated
persons arranging, negotiating or
executing a security-based swap
transaction on behalf of a qualified
majority-owned affiliate; provided that
such broker or dealer gives or sends to
the customer written notification
containing the disclosures required by
Rule 10b–10(a) under the Exchange Act
in connection with such arranging,
negotiating or executing in accordance
with the time and form requirements for
a trade acknowledgment set forth in
Rule 15Fi–2(b) and (c) under the
Exchange Act and, as applicable, Rule
10b–10(c) under the Exchange Act. For
purposes of this exemption, the term
‘‘qualified majority-owned affiliate’’
means a majority-owned affiliate (as
such term is defined in Rule 3a71–
3(a)(10) under the Exchange Act) of
such broker or dealer that is a registered
security-based swap dealer.
It is hereby further ordered, pursuant
to Section 36 of the Exchange Act, that
brokers and dealers are exempt from the
requirements of Rules 8c–1 and 15c2–1
under the Exchange Act with respect to
securities and money market
instruments carried in a security-based
swap account of a security-based swap
customer; provided the account does
not hold ‘‘margin securities’’ as defined
in Rule 15c3–3 under the Exchange Act.
It is hereby further ordered, pursuant
to Section 15(a)(2) of the Exchange Act
and Rule 15a–1(b)(2) under the
Exchange Act, that a security-based
swap with or for an eligible contract
participant whose terms are
standardized to make the security-based
swap eligible for central clearing shall
be within the scope of an ‘‘eligible OTC
derivative instrument’’ as defined in
Rule 3b–13 under the Exchange Act.
It is hereby further ordered, pursuant
to Section 15(a)(2) of the Exchange Act,
that a registered OTC derivatives dealer
also registered with the Commission as
a security-based swap dealer or major
security-based swap participant shall be
exempt from Rule 15a–1(c) under the
E:\FR\FM\05NON1.SGM
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Federal Register / Vol. 85, No. 215 / Thursday, November 5, 2020 / Notices
Exchange Act solely in connection with
security-based swap transactions with
or for an eligible contract participant
and Rule 15a–1(d) under the Exchange
Act solely in connection with
communications and contacts with an
eligible contract participant concerning
a security-based swap transaction.
It is hereby further ordered, pursuant
to Section 36 of the Exchange Act, that
the Unlinked Temporary Exemptions
from Section 8 of the Exchange Act and
from Rules 8c–1, 15c2–1, 15a–1(c) and
15a–1(d) under the Exchange Act in
connection with the revision of the
Exchange Act definition of ‘‘security’’ to
encompass security-based swaps, in
each case contained in the 2011
Exchange Act Exemptive Order and
extended in the January 2020 Extension
Order, are extended until October 6,
2021.
It is hereby further ordered, pursuant
to Section 36 of the Exchange Act, that
the exemption from Section 29(b) of the
Exchange Act contained in the 2011
Compliance Date Order shall expire on
October 6, 2021.
By the Commission.
Vanessa A. Countryman,
Secretary.
[FR Doc. 2020–24598 Filed 11–4–20; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
Sunshine Act Meeting; Cancellation
FEDERAL REGISTER CITATION OF PREVIOUS
ANNOUNCEMENT: 85 FR 69375, November
2, 2020.
PREVIOUSLY ANNOUNCED TIME AND DATE OF
THE MEETING: Wednesday, November 2,
2020 at 2 p.m.
The Open
Meeting scheduled for Wednesday,
November 4, 2020 at 2 p.m., has been
cancelled.
CHANGES IN THE MEETING:
CONTACT PERSON FOR MORE INFORMATION:
khammond on DSKJM1Z7X2PROD with NOTICES
For further information; please contact
Vanessa A. Countryman from the Office
of the Secretary at (202) 551–5400.
Dated: November 2, 2020.
Vanessa A. Countryman,
Secretary.
[FR Doc. 2020–24665 Filed 11–3–20; 11:15 am]
20:36 Nov 04, 2020
rule change (File No. SR–CboeBZX–
2020–070).
[Release No. 34–90292; File No. SR–
CboeBZX–2020–070]
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.6
Jill M. Peterson,
Assistant Secretary.
Self-Regulatory Organizations; Cboe
BZX Exchange, Inc.; Notice of
Designation of a Longer Period for
Commission Action on a Proposed
Rule Change To List and Trade Shares
of the –1x Short VIX Futures ETF, a
Series of VS Trust, Under BZX Rule
14.11(f)(4) (Trust Issued Receipts)
October 30, 2020.
On September 4, 2020, Cboe BZX
Exchange, Inc. (‘‘BZX’’) filed with the
Securities and Exchange Commission
(‘‘Commission’’), pursuant to Section
19(b)(1) of the Securities Exchange Act
of 1934 (‘‘Act’’) 1 and Rule 19b–4
thereunder,2 a proposed rule change to
list and trade shares of the –1x Short
VIX Futures ETF, a series of VS Trust,
under BZX Rule 14.11(f)(4) (Trust
Issued Receipts). The proposed rule
change was published for comment in
the Federal Register on September 23,
2020.3 The Commission has received no
comment letters on the proposed rule
change.
Section 19(b)(2) of the Act 4 provides
that within 45 days of the publication of
notice of the filing of a proposed rule
change, or within such longer period up
to 90 days as the Commission may
designate if it finds such longer period
to be appropriate and publishes its
reasons for so finding, or as to which the
self-regulatory organization consents,
the Commission shall either approve the
proposed rule change, disapprove the
proposed rule change, or institute
proceedings to determine whether the
proposed rule change should be
disapproved. The 45th day after
publication of the notice for this
proposed rule change is November 7,
2020. The Commission is extending this
45-day time period.
The Commission finds it appropriate
to designate a longer period within
which to take action on the proposed
rule change so that it has sufficient time
to consider the proposed rule change.
Accordingly, the Commission, pursuant
to Section 19(b)(2) of the Act,5
designates December 22, 2020 as the
date by which the Commission shall
either approve or disapprove, or
institute proceedings to determine
whether to disapprove, the proposed
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 89901
(September 17, 2020), 85 FR 59836.
4 15 U.S.C. 78s(b)(2).
5 Id.
2 17
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[FR Doc. 2020–24501 Filed 11–4–20; 8:45 am]
BILLING CODE 8011–01–P
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COMMISSION
[Release No. 34–90288; File No. SR–
CboeBYX–2020–021]
Self-Regulatory Organizations; Cboe
BYX Exchange, Inc.; Notice of Filing of
Amendment No. 2 and Order Instituting
Proceedings To Determine Whether To
Approve or Disapprove a Proposed
Rule Change, as Modified by
Amendment No. 2, To Introduce
Periodic Auctions for the Trading of
U.S. Equity Securities
October 30, 2020.
On July 17, 2020, Cboe BYX
Exchange, Inc. (‘‘Exchange’’ or ‘‘BYX’’)
filed with the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’ or
‘‘Exchange Act’’) 1 and Rule 19b–4
thereunder,2 a proposed rule change to
introduce periodic auctions in U.S.
equity securities. The proposed rule
change was published for comment in
the Federal Register on August 4, 2020.3
On September 10, 2020, pursuant to
Section 19(b)(2) of the Exchange Act,4
the Commission designated a longer
period within which to approve the
proposed rule change, disapprove the
proposed rule change, or institute
proceedings to determine whether to
disapprove the proposed rule change.5
On October 27, 2020, the Exchange filed
Amendment No. 1 to the proposed rule
change, and on October 28, 2020 the
Exchange filed Amendment No. 2 to the
proposed rule change, which replaced
in its entirety the proposed rule change
as modified by Amendment No. 1.6 The
6 17
CFR 200.30–3(a)(31).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 See Securities Exchange Act Release No. 89424
(July 29, 2020), 85 FR 47262 (‘‘Notice’’).
4 15 U.S.C. 78s(b)(2).
5 See Securities Exchange Act Release No. 89820,
85 FR 57891 (September 16, 2020). The
Commission designated November 2, 2020 as the
date by which the Commission shall approve or
disapprove, or institute proceedings to determine
whether to disapprove, the proposed rule change.
6 Comments on the proposal, including
Amendments No. 1 and No. 2, can be found on the
Commission’s website at: https://www.sec.gov/
1 15
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Agencies
[Federal Register Volume 85, Number 215 (Thursday, November 5, 2020)]
[Notices]
[Pages 70667-70678]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-24598]
[[Page 70667]]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-90308; File Nos. S7-27-11 and S7-24-11]
Order Granting Exemptions From Sections 8 and 15(a)(1) of the
Securities Exchange Act of 1934 and Rules 3b-13(b)(2), 8c-1, 10b-10,
15a-1(c), 15a-1(d) and 15c2-1 Thereunder in Connection With the
Revision of the Definition of ``Security'' To Encompass Security-Based
Swaps and Determining the Expiration Date for a Temporary Exemption
From Section 29(b) of the Securities Exchange Act of 1934 in Connection
With Registration of Security-Based Swap Dealers and Major Security-
Based Swap Participants
November 2, 2020.
I. Exemptions in Connection With the Revision of the Definition of
``Security'' To Encompass Security-Based Swaps
A. Background
Title VII of the Dodd-Frank Wall Street Reform and Consumer
Protection Act \1\ amended the definition of ``security'' under the
Exchange Act to expressly encompass security-based swaps. The expansion
of the definition of the term ``security'' to include security-based
swaps had the effect of changing the scope of the Exchange Act
regulatory provisions that apply to security-based swaps and, in doing
so, raised certain complex questions that required further
consideration. In July 2011, the Commission issued an order, granting
temporary exemptions from compliance with certain provisions of the
Exchange Act, and the rules and regulations thereunder.\2\ The overall
approach of that order was directed toward maintaining the status quo
during the implementation process for the Dodd-Frank Act.\3\
---------------------------------------------------------------------------
\1\ Dodd-Frank Wall Street Reform and Consumer Protection Act,
Public Law 111-203, 124 Stat. 1376 (2010) (``Dodd-Frank Act'').
\2\ See Order Granting Temporary Exemptions under the Securities
Exchange Act of 1934 in Connection with the Pending Revisions of the
Definition of ``Security'' to Encompass Security-Based Swaps,
Exchange Act Release No. 64795 (Jul. 1, 2011), 76 FR 39927 (Jul. 7,
2011) (``2011 Exchange Act Exemptive Order''). The 2011 Exchange Act
Exemptive Order included two relevant exemptions. First, the
Commission granted to any person who meets the definition of
``eligible contract participant'' set forth in Section 1a(12) of the
Commodity Exchange Act as in effect on July 20, 2010 (i.e., the day
prior to the date the Dodd-Frank Act was signed into law) and who is
not a registered broker or dealer or a self-regulatory organization
a temporary exemption from certain provisions of the Exchange Act,
and the rules and regulations thereunder, solely in connection with
the person's activities involving security-based swaps. This
temporary exemption was made available to a broker or dealer
registered under Exchange Act Section 15(b)(11) and to a self-
regulatory organization in limited circumstances. Second, the
Commission granted to a broker or dealer registered under Section
15(b) of the Exchange Act (other than a broker or dealer registered
under Section 15(b)(11) of the Exchange Act), a temporary exemption
from certain provisions of the Exchange Act, and the rules and
regulations thereunder, solely with respect to security-based swaps.
See 2011 Exchange Act Exemptive Order, 76 FR at 39938-39. The 2011
Exchange Act Exemptive Order did not provide exemptive relief for
any provisions or rules prohibiting fraud, manipulation, or insider
trading (other than prophylactic reporting or recordkeeping
requirements such as the confirmation requirements of Exchange Act
Rule 10b-10). In addition, the 2011 Exchange Act Exemptive Order did
not affect the Commission's investigative, enforcement, and
procedural authority related to those provisions and rules. See 2011
Exchange Act Exemptive Order, 76 FR at 39931 n.34. The 2011 Exchange
Act Exemptive Order also did not address Sections 12, 13, 14, 15(d),
16, and 17A of the Exchange Act and the rules and regulations
thereunder.
\3\ See 2011 Exchange Act Exemptive Order, 76 FR at 39929. Under
the 2011 Exchange Act Exemptive Order, instruments that were
security-based swap agreements before July 16, 2011 (360 days after
the enactment of the Dodd-Frank Act) (``Effective Date'') and
constituted security-based swaps after the Effective Date were still
subject to the application of those Exchange Act provisions. See
2011 Exchange Act Exemptive Order, 76 FR at 39930 nn.24-25.
---------------------------------------------------------------------------
The Commission in 2011 set the temporary exemptions to expire on
the compliance date for final rules defining the terms ``security-based
swap'' and ``eligible contract participant,'' \4\ and since that time
periodically has extended this deadline.\5\ Notably, in 2014, the
Commission extended the expiration date for the temporary exemptions,
distinguishing between: (1) The temporary exemptions related to pending
security-based swap rulemakings (``Linked Temporary Exemptions''), the
expiration dates for which were extended to the compliance dates for
the specific rulemakings to which they were ``linked''; and (2) the
temporary exemptions that generally were not directly related to a
specific security-based swap rulemaking (``Unlinked Temporary
Exemptions'').\6\
[[Page 70668]]
The approach to the Linked Temporary Exemptions was designed to
facilitate timely, phased-in application of the relevant provisions of
the Exchange Act to security-based swaps based on the Commission's
finalization of the relevant rules mandated by the Dodd-Frank Act.\7\
The approach to the Unlinked Temporary Exemptions provided the
Commission with flexibility, while its relevant rulemaking was still in
progress, to determine whether continuing relief should be provided for
any of the Exchange Act provisions subject to the Unlinked Temporary
Exemptions.\8\ In January 2020, the Commission issued an order
extending until November 5, 2020, the temporary exemptions related to
three commenter requests discussed below.\9\ The remainder of the
Unlinked Temporary Exemptions expired on February 5, 2020.\10\
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\4\ See 2011 Exchange Act Exemptive Order, 76 FR at 39938.
\5\ See Further Definition of ``Swap,'' ``Security-Based Swap,''
and ``Security-Based Swap Agreement''; Mixed Swaps; Security-Based
Swap Agreement Recordkeeping, Exchange Act Release No. 67453 (Jul.
18, 2012), 77 FR 48208 (Aug. 13, 2012) (``Product Definitions
Adopting Release'') (extending the expiration date of the temporary
exemptions to February 11, 2013); Order Extending Temporary
Exemptions under the Securities Exchange Act of 1934 in Connection
with the Revision of the Definition of ``Security'' to Encompass
Security-Based Swaps, and Request for Comment, Exchange Act Release
No. 68864 (Feb. 7, 2013), 78 FR 10218 (Feb. 13, 2013) (``2013
Extension Order'') (extending the expiration date of the temporary
exemptions to February 11, 2014); Order Extending Temporary
Exemptions under the Securities Exchange Act of 1934 in Connection
with the Revision of the Definition of ``Security'' to Encompass
Security-Based Swaps, and Request for Comment, Exchange Act Release
No. 71485 (Feb. 5, 2014), 79 FR 7731 (Feb. 10, 2014) (``2014
Extension Order'') (extending the expiration dates (i) for certain
``linked'' temporary exemptions related to then-pending security-
based swap rulemakings to the compliance dates for the related
rulemakings and (ii) for certain other ``unlinked'' temporary
exemptions not related to then-pending rulemakings to February 5,
2017); Order Extending Certain Temporary Exemptions Under the
Securities Exchange Act of 1934 in Connection With the Revision of
the Definition of ``Security'' To Encompass Security-Based Swaps and
Request for Comment, Exchange Act Release No. 79833 (Jan. 18, 2017),
82 FR 8467 (Jan. 25, 2017) (``2017 Extension Order'') (extending the
expiration date for the unlinked temporary exemptions to February 5,
2018); Order Extending Until February 5, 2019 Certain Temporary
Exemptions under the Securities Exchange Act of 1934 in Connection
with the Pending Revision of the Definition of ``Security'' to
Encompass Security-Based Swaps and Request for Comment, Exchange Act
Release No. 82626 (Feb. 2, 2018), 83 FR 5665 (Feb. 18, 2018) (``2018
Extension Order'') (extending the expiration date for the unlinked
temporary exemptions to February 5, 2019); Order Granting a Limited
Exemption from the Exchange Act Definition of ``Penny Stock'' for
Security-Based Swap Transactions between Eligible Contract
Participants; Granting a Limited Exemption from the Exchange Act
Definition of ``Municipal Securities'' for Security-Based Swaps; and
Extending Certain Temporary Exemptions under the Exchange Act in
Connection with the Revision of the Definition of ``Security'' to
Encompass Security-Based Swaps, Exchange Act Release No. 84991 (Jan.
25, 2019), 84 FR 863 (Jan. 31, 2019) (``2019 Extension Order'')
(extending the expiration date for the unlinked temporary exemptions
to February 5, 2020); Order Extending Temporary Exemptions from
Exchange Act Section 8 and Exchange Act Rules 8c-1, 10b-16, 15a-1,
15c2-1 and 15c2-5 in Connection with the Revision of the Definition
of ``Security'' to Encompass Security-Based Swaps, Exchange Act
Release No. 87943 (Jan. 10, 2020), 85 FR 2763 (Jan. 16, 2020)
(``January 2020 Extension Order'') (extending the expiration date
for the unlinked temporary exemptions to November 5, 2020).
\6\ See 2014 Extension Order, 79 FR at 7732-35. The 2014
Extension Order identified the Linked Temporary Exemptions as those
Expiring Temporary Exemptions related to: (1) Capital and margin
requirements applicable to a broker or dealer (Exchange Act Sections
7 and 15(c)(3), Regulation T, and Exchange Act Rules 15c3-1, 15c3-3,
and 15c3-4); (2) recordkeeping requirements applicable to a broker
or dealer (Exchange Act Sections 17(a) and 17(b) and Exchange Act
Rules 17a-3, 17a-4, 17a-5, 17a-11, and 17a-13); (3) registration
requirements under Exchange Act Section 15(a)(1), and the other
requirements of the Exchange Act and the rules and regulations
thereunder that apply to a ``broker'' or ``dealer'' that is not
registered with the Commission; (4) Exchange Act Rule 10b-10; and
(5) Regulation ATS. The remaining Expiring Temporary Exemptions are
the Unlinked Temporary Exemptions. The Commission extended the
Linked Temporary Exemptions until the compliance date for pending
rulemakings concerning, as applicable: Capital, margin, and
segregation requirements for security-based swap dealers and major
security-based swap participants; recordkeeping and reporting
requirements for security-based swap dealers and major security-
based swap participants; security-based swap trade acknowledgement
and verification requirements; and registration requirements for
security-based swap execution facilities. The Linked Temporary
Exemptions linked to registration requirements for security-based
swap execution facilities are not addressed in this Order and will
be separately considered in connection with the rulemaking
concerning those requirements. The Commission already has addressed
other Linked Temporary Exemptions in the related security-based swap
rulemakings. See, e.g., Capital, Margin, and Segregation
Requirements for Security-Based Swap Dealers and Major Security-
Based Swap Participants and Capital and Segregation Requirements for
Broker-Dealers, Exchange Act Release No. 86175 (Jun. 21, 2019), 84
FR 43872, 43955-56 (Aug. 22, 2019) (``Capital, Margin and
Segregation Adopting Release''); Recordkeeping and Reporting
Requirements for Security-Based Swap Dealers, Major Security-Based
Swap Participants, and Broker-Dealers, Exchange Act Release No.
87005 (Sept. 19 2019), 84 FR 68550, 68601-02 (Dec. 16, 2019)
(``Recordkeeping and Reporting Adopting Release''); Trade
Acknowledgment and Verification of Security-Based Swap Transactions,
Exchange Act Release No. 78011 (Jun. 8, 2016), 81 FR 39807, 39824-25
n.189 (Jun. 17, 2016) (``Trade Acknowledgment and Verification
Adopting Release'').
\7\ See 2014 Extension Order, 79 FR at 7731.
\8\ See 2014 Extension Order, 79 FR at 7731.
\9\ See January 2020 Extension Order, 85 FR at 2766.
\10\ See January 2020 Extension Order, 85 FR at 2766.
---------------------------------------------------------------------------
The Commission has requested comment on the initial issuance and
subsequent extensions of these temporary exemptions several times
during consideration of the various exemptive orders.\11\ In response,
some commenters requested that the Commission make permanent some of
the Linked Temporary Exemptions and Unlinked Temporary Exemptions.\12\
The Commission has addressed some aspects of these requests in two
previous orders.\13\ Some of the requests for permanent exemptions have
been withdrawn \14\ or superseded.\15\
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\11\ See 2011 Exchange Act Exemptive Order, 76 FR at 39938; 2013
Extension Order, 78 FR at 10219-20 (discussion of comments on 2011
Exchange Act Exemptive Order and additional request for comment);
2014 Extension Order, 79 FR at 7734 (additional request for
comment); 2017 Extension Order, 82 FR at 8469 (additional request
for comment); 2018 Extension Order, 83 FR at 5667-68 (discussion of
comments on 2017 Extension Order and additional request for
comment). In response to its 2018 request for comment, the
Commission received four letters from two different commenters. See
letter from Kyle Brandon, Managing Director, Securities Industry and
Financial Markets Association (``SIFMA''), dated Nov. 8, 2018
(``SIFMA November 2018 Letter'') (requesting that the Commission
further extend the Unlinked Temporary Exemptions, and also
requesting certain permanent exemptive and other relief); letter
from Kyle Brandon, Managing Director, SIFMA, dated Dec. 20, 2018
(``SIFMA December 2018 Letter'') (supplementing the SIFMA November
2018 Letter with additional detail regarding the Unlinked Temporary
Exemptions and recommending a twelve-month transition period before
expiration of any Unlinked Temporary Exemptions); letter from Walt
L. Lukken, President and Chief Executive Officer, Futures Industry
Association, dated Nov. 14, 2018 (``FIA November 2018 Letter I'')
(expressing support for the permanent exemptions requested in the
SIFMA November 2018 Letter); letter from Walt L. Lukken, President
and Chief Executive Officer, Futures Industry Association, dated
Nov. 29, 2018 (``FIA November 2018 Letter II'') (same). All comments
received are available at https://www.sec.gov/comments/s7-27-11/s72711.shtml.
\12\ See SIFMA November 2018 Letter at 1-4; SIFMA December 2018
Letter at 1-7; see also FIA November 2018 Letter I at 10; FIA
November 2018 Letter II at 10-11.
\13\ In 2019, the Commission provided limited exemptions from
the definition of ``penny stock'' in Exchange Act Section 3(a)(51)
and Exchange Act Rule 3a51-1 for transactions in security-based
swaps between eligible contract participants and from the definition
of ``municipal securities'' in Exchange Act Section 3(a)(29) for
security-based swaps. See 2019 Extension Order, 84 FR at 867. In
response to the commenter's request for guidance regarding the
definition of ``government securities,'' the Commission noted that
the Unlinked Temporary Exemptions did not include an exemption from
the definition of ``government securities'' in Section 3(a)(42) of
the Exchange Act and noted that the Exchange Act does not permit the
Commission to provide such relief. See 2019 Extension Order, 84 FR
at 866 & n.40. In response to the commenter's request for exemptions
for security-based swap execution facilities, the Commission noted
that it would consider the request in connection with the
Commission's finalization of rules for security-based swap execution
facilities. See 2019 Extension Order, 84 FR at 864 n.10. In January
2020, the Commission allowed all of the Unlinked Temporary
Exemptions except for those related to three of the commenter's
requests to expire on February 5, 2020. See January 2020 Extension
Order, 85 FR at 2766.
\14\ See letter from Kyle Brandon, Managing Director, SIFMA,
dated Jan. 8, 2020 (``SIFMA January 2020 Letter''), at 5; letter
from Kyle L. Brandon, Managing Director, Head of Derivatives Policy,
SIFMA, dated September 10, 2020 (``SIFMA September 2020 Letter''),
at 8. All comments received are available at https://www.sec.gov/comments/s7-27-11/s72711.shtml.
\15\ See SIFMA September 2020 Letter at 5-6.
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On January 8, 2020, the Commission received a letter from SIFMA
supplementing its requests regarding the Unlinked Temporary
Exemptions.\16\ The commenter requested that the Commission make
permanent three aspects \17\ of the Unlinked Temporary Exemptions: (1)
A limited exemption from the hypothecation requirements of Exchange Act
Section 8 and in Exchange Act Rules 8c-1 and 15c2-1 for certain
securities carried for the account of a customer with respect to a
security-based swap transaction,\18\ (2) exemptions from broker and
dealer disclosure requirements relating to extensions of credit in
Exchange Act Rules 10b-16 and 15c2-5 as applied to security-based
swaps,\19\ and (3) exemptions for security-based swaps from certain
limitations on an OTC derivatives dealer's activities in Exchange Act
Rule 15a-1.\20\ On September 10, 2020, the Commission received a letter
supplementing the commenter's requests regarding those three aspects of
the Unlinked Temporary Exemptions, as well as three additional aspects
of the Linked Temporary Exemptions.\21\ In that letter, the commenter
requested that the Commission make permanent three aspects of the
Linked Temporary Exemptions: (1) an exemption from the broker and
dealer registration requirement in Exchange Act Section 15(a)(1) \22\
for a foreign broker or dealer, otherwise operating in compliance with
Exchange Act Rule 15a-6, solely in connection with security-based swap
dealing with or for an eligible contract participant,\23\ (2) an
exemption from the broker registration requirement in Section 15(a)(1)
for a registered security-
[[Page 70669]]
based swap dealer that arranges, negotiates or executes a security-
based swap with or for an eligible contract participant on behalf of a
majority-owned affiliate that is a registered security-based swap
dealer,\24\ and (3) an exemption from certain confirmation requirements
under Exchange Act Rule 10b-10 for a broker or dealer that arranges,
negotiates or executes a security-based swap with or for an eligible
contract participant on behalf of a majority-owned affiliate that is a
registered security-based swap dealer.\25\
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\16\ See SIFMA January 2020 Letter.
\17\ The commenter confirmed that it was no longer requesting
additional extensions for any Unlinked Temporary Exemptions other
than for the three issues cited in the letter. See SIFMA January
2020 Letter at 5.
\18\ See SIFMA January 2020 Letter at 3-4; SIFMA December 2018
Letter at 5; SIFMA November 2018 Letter at 3; Exchange Act Section
8, 15 U.S.C. 78h; Exchange Act Rule 8c-1, 17 CFR 240.8c-1; Exchange
Act Rule 15c2-1, 17 CFR 240.15c2-1. Section 8 of the Exchange Act
and Exchange Act Rules 8c-1 and 15c2-1 limit a broker or dealer's
ability to hypothecate securities carried for the account of a
customer.
\19\ See SIFMA January 2020 Letter at 4; SIFMA December 2018
Letter at 5-6; SIFMA November 2018 Letter at 3; Exchange Act Rule
10b-16, 17 CFR 240.10b-16; Exchange Act Rule 15c2-5, 17 CFR
240.15c2-5. Exchange Act Rules 10b-16 and 15c2-5 govern the
disclosures that a broker or dealer must provide to customers to
whom they extend credit.
\20\ See SIFMA January 2020 Letter at 4-5; SIFMA December 2018
Letter at 6-7; SIFMA November 2018 Letter at 4; Exchange Act Rule
15a-1, 17 CFR 240.15a-1. Exchange Act Rule 15a-1 limits an OTC
derivatives dealer's ability to engage in dealer activities in
listed instruments and in fungible instruments that are standardized
as to their material economic terms.
\21\ See SIFMA September 2020 Letter.
\22\ 15 U.S.C. 78o(a)(1).
\23\ See SIFMA September 2020 Letter at 3-4; Exchange Act
Section 15(a)(1), 15 U.S.C. 78o(a)(1); Exchange Act Rule 15a-6, 17
CFR 240.15a-6. This request updated the commenter's 2018 request for
exemption from registration as a broker or dealer for Rule 15a-6-
reliant foreign brokers and dealers that induce or attempt to
purchase or sell a security-based swap with or for an eligible
contract participant. See SIFMA November 2018 Letter at 2.
\24\ See SIFMA September 2020 Letter at 4; Exchange Act Section
15(a)(1), 15 U.S.C. 78o(a)(1).
\25\ See SIFMA September 2020 Letter at 4-5; Exchange Act Rule
10b-10, 17 CFR 240.10b-10. This request updated the commenter's 2018
request for exemption from broker and dealer confirmation
requirements. See SIFMA November Letter at 2.
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The Commission has finalized a majority of the rulemakings under
Title VII of the Dodd-Frank Act, including rules regarding the
registration and regulation of SBS Entities. The Commission also has
set the compliance date for rules regarding registration and regulation
of SBS Entities,\26\ which will be October 6, 2021. Market participants
will be required to assess whether their activities meet the
definitions of ``security-based swap dealer'' or ``major security-based
swap participant'' beginning two months before this compliance date, or
August 6, 2021.\27\ This Order addresses the commenter's current
requests regarding the Linked Temporary Exemptions and the Unlinked
Temporary Exemptions in light of those finalized rules and dates. The
remainder of the Unlinked Temporary Exemptions extended in January
2020, and not extended in this Order, will expire on November 5,
2020.\28\
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\26\ See Rule Amendments and Guidance Addressing Cross-Border
Application of Certain Security-Based Swap Requirements, Exchange
Act Release No. 87780 (Dec. 18, 2019), 85 FR 6270, 6345 (Feb. 4,
2020) (``Cross-Border Adopting Release'').
\27\ See Registration Process for Security-Based Swap Dealers
and Major Security-Based Swap Participants, Exchange Act Release No.
75611 (Aug. 5, 2015), 80 FR 48963, 48988 (Aug. 14, 2015) (``SBS
Entity Registration Adopting Release'').
\28\ See January 2020 Extension Order, 85 FR at 2766.
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B. Requests for Exemptions
The Commission has considered the commenter's six current requests
and is providing exemptions in response to five of those requests. Each
of the requests is discussed in turn below.
1. Request for an Exemption From Broker and Dealer Registration for a
Rule 15a-6-Reliant Foreign Broker or Dealer, Solely in Connection With
Security-Based Swap Dealing With or for an Eligible Contract
Participant
Exchange Act Section 15(a)(1) requires a person to register as a
broker or dealer if the person is a ``broker'' as defined in Exchange
Act Section 3(a)(4) \29\ or a ``dealer'' as defined in Exchange Act
Section 3(a)(5) \30\ and engages in certain activities in a
``security'' as defined in Exchange Act Section 3(a)(10),\31\ a term
that includes security-based swaps. Section 15(a)(1) currently is
subject to Linked Temporary Exemptions that exempt from the
registration requirement brokerage activities and dealing activities
involving security-based swaps with eligible contract participants.\32\
These Linked Temporary Exemptions will expire on October 6, 2021.\33\
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\29\ 15 U.S.C. 78c(a)(4).
\30\ 15 U.S.C. 78c(a)(5).
\31\ 15 U.S.C. 78c(a)(10).
\32\ See 2011 Exchange Act Exemptive Order, 76 FR at 39938-39;
2014 Extension Order, 79 FR at 7734-35.
\33\ See 2014 Extension Order, 79 FR at 7734-35; Recordkeeping
and Reporting Adopting Release, 84 FR at 68600; Cross-Border
Adopting Release, 85 FR at 6345.
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Dealing in security-based swaps with or for an eligible contract
participant is excluded from the definition of the term ``dealer,''
\34\ and that will remain true after the Linked Temporary Exemptions
expire. Similarly, market participants that conduct other activities
meeting the definitions of ``broker'' and/or ``dealer'' may
nevertheless avoid registration as a broker or dealer by availing
themselves of the exemption from registration in Exchange Act Rule 15a-
6. Yet, the commenter expressed concern that if a person combines these
types of securities activities--that is, dealing in a security-based
swap with or for an eligible contract participant (which is excluded
from the definition of the term ``dealer'') and Rule 15a-6-compliant
securities activities (which cause the person to meet the definition of
``broker'' and/or ``dealer'' but that do not require registration as
such)--Section 15(a)(1) may require the person to register as a broker
and/or dealer. The commenter's concern is that this result may follow
from Section 15(a)(1)'s requirement for any person that meets the
definition of ``broker'' or ``dealer'' \35\--a category that includes
foreign brokers and dealers relying on Rule 15a-6--to register with the
Commission if it makes use of the mails or any means or instrumentality
of interstate commerce to effect any transactions in, or to induce or
attempt to induce the purchase or sale of, any security,\36\ including
security-based swaps. The commenter requested that foreign brokers and
dealers relying on Exchange Act Rule 15a-6 be exempted from Section
15(a)(1)'s broker and dealer registration requirement in connection
with any security-based swap dealing with or for an eligible contract
participant that is excluded from the definition of ``dealer.'' \37\
The commenter also provided an example unrelated to Rule 15a-6,
expressing concern that if a non-U.S. person combines dealing in a
security-based swap in the United States with or for an eligible
contract participant, on the one hand, with brokerage activity outside
the United States, on the other hand, Section 15(a)(1) would require
the person to register as a broker and/or dealer.\38\
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\34\ See Exchange Act Section 3(a)(5)(A).
\35\ This registration requirement does not apply to a broker or
dealer whose business is exclusively intrastate and who does not
make use of any facility of a national securities exchange. See
Exchange Act Section 15(a)(1).
\36\ This registration requirement does not apply to activities
in an exempted security or commercial paper, bankers' acceptances or
commercial bills. See Exchange Act Section 15(a)(1).
\37\ See SIFMA September 2020 Letter at 3-4; SIFMA November 2018
Letter at 2.
\38\ See SIFMA September 2020 Letter at 3-4.
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The Commission agrees that broker-dealer registration should not be
required in the circumstances described by the commenter. To provide
certainty about this result, the Commission is providing an exemption
from Section 15(a)(1) for security-based swap dealing with or for
eligible contract participants, available to foreign brokers and
dealers whose activities in securities other than security-based swaps
with or for an eligible contract participant comply with Rule 15a-6.
The Commission believes this exemption would further the purpose of the
exclusion of that type of security-based swap dealing from the
definition of ``dealer.'' Similarly, the Commission believes that a
limited exemption from Section 15(a)(1) for security-based swap dealing
with or for eligible contract participants, available to foreign
brokers and dealers whose activities in securities other than security-
based swaps with or for an eligible contract participant lack a U.S.
jurisdictional nexus, also would further the purpose of the exclusion
of that type of security-based swap dealing from the definition of
``dealer.'' This exemption addresses the commenter's concern that,
without this limited exemptive relief from the registration requirement
of
[[Page 70670]]
Section 15(a)(1), the exclusion of security-based swaps with or for
eligible contract participants from the definition of ``dealer'' might
effectively become unavailable to foreign brokers and dealers whose
other securities activities either comply with Rule 15a-6 or lack any
U.S. jurisdictional nexus. Requiring registration in this circumstance
could undermine the market structure for security-based swaps by making
it more costly and complex to engage in that type of security-based
swap dealing with eligible contract participants in the United States,
to the detriment of investors. Accordingly, pursuant to its authority
under Exchange Act Section 15(a)(2), the Commission finds that it is
consistent with the public interest and the protection of investors to
exempt a ``foreign broker or dealer,'' as such term is defined in Rule
15a-6(b)(3) under the Exchange Act, whose activities in securities
other than security-based swaps with or for an eligible contract
participant are conducted either in compliance with Rule 15a-6 under
the Exchange Act or without the jurisdiction of the United States, from
the registration requirement of Exchange Act Section 15(a)(1) solely in
connection with the foreign broker or dealer's security-based swap
dealing with or for an eligible contract participant. Consistent with
the commenter's request, this exemption would not extend to foreign
brokers' and dealers' security-based swap brokerage activity.
2. Request for Exemption From Broker Registration for a Registered
Security-Based Swap Dealer That Arranges, Negotiates or Executes a
Security-Based Swap With or for an Eligible Contract Participant on
Behalf of a Majority-Owned Affiliate That Is a Registered Security-
Based Swap Dealer
As described above, Exchange Act Section 15(a)(1) requires a person
to register as a broker if the person is a ``broker'' as defined in
Exchange Act Section 3(a)(4) and engages in certain activities in a
``security'' as defined in Exchange Act Section 3(a)(10), a term that
includes security-based swaps. Though dealing in security-based swaps
with or for an eligible contract participant is excluded from the
definition of the term ``dealer,'' \39\ the statutory definition of the
term ``broker'' contains no such exclusion.\40\ Section 15(a)(1)
currently is subject to Linked Temporary Exemptions that exempt from
the registration requirement brokerage activities involving security-
based swaps with eligible contract participants.\41\ These Linked
Temporary Exemptions will expire on October 6, 2021.\42\
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\39\ See Exchange Act Section 3(a)(5)(A).
\40\ See Exchange Act Section 3(a)(4).
\41\ See 2011 Exchange Act Exemptive Order, 76 FR at 39938-39;
2014 Extension Order, 79 FR at 7734.
\42\ See 2014 Extension Order, 79 FR at 7734-35; SBS Entity
Registration Adopting Release, 80 FR at 48988; Cross-Border Adopting
Release, 85 FR at 6345.
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As part of its consideration of cross-border issues in the
registration of security-based swap dealers, the Commission recently
determined that a limited exemption from the broker registration
requirement was appropriate for a registered security-based swap dealer
and its associated persons who conduct certain security-based swap
``arranging, negotiating or executing'' activity (``ANE activity'')
with or for a non-U.S. person eligible contract participant on behalf
of a non-U.S. majority-owned affiliate that is relying on an exception
to the de minimis thresholds for registration as a security-based swap
dealer.\43\ The commenter requested that this limited exemption from
the broker registration requirement be extended to situations in which
the majority-owned affiliate is not relying on the de minimis exception
but, rather, is a registered security-based swap dealer.\44\ When
adopting this limited exemption in the context of the de minimis
exception, the Commission noted that a security-based swap dealer not
dually registered as a broker or dealer and approved to use models to
compute deductions for market or credit risk is subject to a minimum
net capital requirement of $20 million and a minimum tentative net
capital requirement of $100 million, versus minimum requirements of $1
billion and $5 billion, respectively, for a broker or dealer approved
to use models.\45\ The Commission adopted that exemption to avoid a
situation in which ``applying the heightened broker-dealer capital
requirements to all security-based swap dealers approved to use models
who serve as the registered entity for purposes of the [de minimis]
exception could limit the usefulness of the exception.'' \46\ The
commenter argued that extending the limited exemption would be
appropriate because the same concerns also apply when the majority-
owned affiliate is a registered, rather than unregistered, security-
based swap dealer.\47\
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\43\ See Exchange Act Rule 3a71-3(d)(4); Cross-Border Adopting
Release, 85 FR at 6279-80.
\44\ See SIFMA September 2020 Letter at 4.
\45\ See Cross-Border Adopting Release, 85 FR at 6279.
\46\ See Cross-Border Adopting Release, 85 FR at 6279.
\47\ See SIFMA September 2020 Letter at 4.
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The Commission continues to believe that ANE activity generally
would constitute activity of a ``broker'' as that term is defined in
Exchange Act Section 3(a)(4).\48\ The Commission acknowledges the
concerns regarding the heightened capital requirements for brokers
approved to use models as applied to the security-based swap ANE
activity described in the commenter's request. At the same time, the
statutory definition of ``broker'' does not contain an exclusion for
this activity.\49\ Moreover, the Commission also is concerned that an
exemption for ANE activity from the broker registration requirement
could prompt changes in market structure that make it more difficult
for the Commission to oversee that activity. In the Commission's view,
however, a temporary exemption should not encourage such market
structure changes, but could provide the Commission an opportunity to
consider these concerns in light of market conditions prevailing after
registration of security-based swap dealers begins.\50\ Accordingly,
pursuant to its authority under Exchange Act Section 15(a)(2), the
Commission finds that it is consistent with the public interest and the
protection of investors to provide a conditional temporary exemption
from the broker registration requirement of Section 15(a)(1) until
November 1, 2022 (i.e., one year after the earliest due date for
applications for registration as a security-based swap dealer) for a
registered security-based swap dealer and its associated persons solely
in connection with such registered security-based swap dealer or
associated person arranging, negotiating or executing a security-based
swap transaction with or for a non-U.S. person eligible contract
participant on behalf of a non-U.S. person qualified majority-owned
affiliate. Consistent with the exemption from broker registration in
the context of the de minimis exception, this exemption is limited to
ANE activity with or for a non-U.S. person eligible contract
participant. The Commission continues to believe that requiring broker
registration with respect to ANE activity with or for a counterparty
that is not an eligible contract participant is consistent with the
heightened
[[Page 70671]]
protections that Congress applied to security-based swap transactions
with or for non-eligible contract participants.\51\ For purposes of
this exemption, the term ``qualified majority-owned affiliate'' means a
majority-owned affiliate (as such term is defined in Exchange Act Rule
3a71-3(a)(10)) of the registered security-based swap dealer that is
itself also a registered security-based swap dealer.
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\48\ See Cross-Border Adopting Release, 85 FR at 6279 & n.104.
\49\ See Exchange Act Section 3(a)(4).
\50\ The Commission welcomes engagement with market participants
to discuss developments that may occur in this market after
security-based swap dealers begin to register.
\51\ See Cross-Border Adopting Release, 85 FR at 6279 & n.109
(citing Exchange Act Section 6(l), 15 U.S.C. 78f(l), and Exchange
Act Section 3(a)(5), 15 U.S.C. 78c(a)(5)).
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To be eligible for the exemption, the registered security-based
swap dealer must comply with two relevant conditions to the parallel
exemption from broker registration in the context of the de minimis
exception. First, the registered security-based swap dealer must create
and maintain books and records relating to such ANE activity that are
required by Exchange Act Rules 18a-5 and 18a-6. This condition differs
slightly from the parallel condition in the context of the de minimis
exception \52\ in that the required books and records relate only to
the ANE activity by the registered security-based swap dealer relying
on the exemption, rather than to the entire security-based swap
transaction subject to the de minimis exception. The Commission
believes this difference is appropriate because the de minimis
exception applies to transactions on behalf of an unregistered
affiliate, whereas the exemption granted in this Order applies only to
ANE activity on behalf of a registered security-based swap dealer
affiliate. Because the affiliate also must maintain books and records
relating to the transaction, the Commission believes that the exemption
should require the registered security-based swap dealer relying on
this exemption to create and maintain only those books and records that
relate to its own ANE activity. Second, if Exchange Act Rule 10b-10
would apply to such ANE activity, the registered security-based swap
dealer also must provide to the customer the disclosures required by
Rule 10b-10(a)(2) (excluding Rule 10b-10(a)(2)(i) and (ii)) and Rule
10b-10(a)(8) in accordance with the time and form requirements set
forth in Exchange Act Rule 15Fi-2(b) and (c) or, alternatively,
promptly after discovery of any defect in such registered security-
based swap dealer's good faith effort to comply with such
requirements.\53\
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\52\ See Exchange Act Rule 3a71-4(d)(1)(iii)(B)(1).
\53\ The other conditions to the availability of the exemption
from broker registration in the context of the de minimis exception
are not applicable to ANE activity on behalf of a registered
security-based swap dealer and thus are not included as conditions
to the exemption granted in this Order. For example, registered
security-based swap dealers already have to comply with the
provisions listed in Exchange Act Rule 3a71-3(d)(1)(ii), provide the
Commission with the access to books and records described in Rule
3a71-3(d)(1)(iii)(A) and maintain the books and records and consent
to service of process described in Rule 3a71-3(d)(1)(iii)(B)(3)-(4).
The conditions described in Rule 3a71-3(d)(1)(iii)(B)(2) and
(d)(1)(iv)-(vii) are specific to the operation of the de minimis
exception and are not relevant to the exemption granted in this
Order.
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3. Request for Exemption From Certain Confirmation Requirements for a
Broker or Dealer That Arranges, Negotiates or Executes a Security-Based
Swap With or for an Eligible Contract Participant on Behalf of a
Majority-Owned Affiliate That Is a Registered Security-Based Swap
Dealer
Exchange Act Rule 10b-10 \54\ requires a broker or dealer to
deliver to a customer certain disclosures about transactions in
securities, including security-based swaps. Exchange Act Rule 15Fi-2
\55\ requires an SBS Entity to deliver to a counterparty a trade
acknowledgment containing certain terms of the security-based swap or
to verify the trade acknowledgment received from the counterparty.
Certain information required to be included in a Rule 10b-10
confirmation is not required in the Rule 15Fi-2 trade acknowledgment,
such as a description of the broker or dealer's role as agent for the
customer, agent for some other person, agent for both the customer and
another person or principal for its own account in the transaction, as
well as information about the source and/or amount of certain other
remuneration received or to be received by the broker or dealer in
connection with the transaction.\56\ Rule 10b-10 currently is subject
to a Linked Temporary Exemption that exempts brokers and dealers from
these disclosure requirements with respect to security-based swaps.\57\
This Linked Temporary Exemption will expire on October 6, 2021.\58\
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\54\ 17 CFR 240.10b-10.
\55\ 17 CFR 240.15Fi-2.
\56\ See Exchange Act Rule 10b-10(a).
\57\ See 2011 Exchange Act Exemptive Order, 76 FR at 39939; 2014
Extension Order, 79 FR at 7734.
\58\ See 2014 Extension Order, 79 FR at 7734; Trade
Acknowledgment and Verification Adopting Release, 81 FR at 39828;
Recordkeeping and Reporting Adopting Release, 84 FR at 68600; Cross-
Border Adopting Release, 85 FR at 6345.
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A registered broker that conducts ANE activity pursuant to the de
minimis exception in Exchange Act Rule 3a71-3(d) is exempt from
providing the disclosures described in Rule 10b-10, except for those
regarding the broker's role as agent or principal in the transaction
and the broker or dealer's status as a member of SIPC.\59\ In addition,
a registered security-based swap dealer that conducts ANE activity
pursuant to the de minimis exception is exempt from registration as a
broker so long as it provides these same Rule 10b-10 disclosures.\60\
Because Rule 10b-10 and Rule 15Fi-2 have different form and timing
requirements,\61\ the de minimis exception allows these Rule 10b-10
disclosures to be provided in accordance with the form and timing
requirements in Rule 15Fi-2(b) and (c).\62\
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\59\ See Exchange Act Rule 3a71-(d)(5).
\60\ See Exchange Act Rule 3a71-3(d)(4)(ii).
\61\ Rule 10b-10(a) requires a broker or dealer to give or send
a confirmation in the form of a ``written notification,'' whereas
Rule 15Fi-2(c) requires a trade acknowledgment to be provided by
``electronic means that provide reasonable assurance of delivery and
a record of transmittal.'' A broker or dealer must give or send a
transaction confirmation under Rule 10b-10(a) ``at or before the
completion of such transaction,'' whereas a trade acknowledgment
pursuant to Rule 15Fi-2(b) must be provided ``promptly, but in any
event by the end of the first business day following the day of
execution.''
\62\ See Exchange Act Rule 3a71-3(d)(4)(ii), (5)(ii).
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The commenter requests that a parallel exemption from Rule 10b-10
apply to situations in which a registered broker or dealer conducts ANE
activity not pursuant to the de minimis exception but, rather, on
behalf of a majority-owned affiliate that is a registered security-
based swap dealer.\63\ Though Rule 10b-10 requires disclosures not
duplicated in the trade acknowledgment required under Rule 15Fi-2, the
commenter claims that some of these disclosures are ``irrelevant'' in
the situations covered by its request because a broker or dealer would
be ``solely compensated by its [security-based swap dealer]
affiliate.'' \64\ Rule 10b-10, however, contains no exemption for
transactions in which compensation is paid by an affiliate. Moreover,
compensation disclosure is not available through other means, as the
trade acknowledgment required by Rule 15Fi-2 would disclose only the
terms of the security-based swap transaction, which do not necessarily
include compensation regarding the brokerage activity to which Rule
10b-10 applies. Security-based swap trade acknowledgments thus do not
duplicate or replace Rule 10b-10 disclosures for brokerage
activity.\65\ In response to the commenter's previous request for
exemption from Rule 10b-10 for
[[Page 70672]]
security-based swap brokerage activity,\66\ the Commission stated that,
``since Rule 15Fi-2 does not require a trade acknowledgment for an SBS
Entity's brokerage or agency transactions, and therefore would not
result in any duplication of efforts by the SBS Entity effecting the
brokerage or agency transaction, the Commission does not believe that
there is a need to provide an exemption from providing a confirmation
under Rule 10b-10 for an SBS Entity's brokerage or agency
transactions.'' \67\ Indeed, the Commission believes that customers
would benefit from disclosure about brokerage costs even when gross
costs may be reflected in the transaction price reported in the trade
acknowledgment. For these reasons, the Commission is not providing an
exemption from Rule 10b-10's disclosure requirements in connection with
a broker or dealer's security-based swap ANE activity.
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\63\ See SIFMA September 2020 Letter at 5.
\64\ See SIFMA September 2020 Letter at 5.
\65\ See Trade Acknowledgment and Verification Adopting Release,
81 FR at 39824-25 (``[Rule 15Fi-2] thus does not apply to brokerage
or agency transactions, which are different in structure and involve
different activity by a broker than principal transactions by [a
security-based swap dealer].'').
\66\ See letter from Securities Industry and Financial Markets
Association, dated Dec. 5, 2011, available at https://www.sec.gov/comments/s7-27-11/s72711.shtml.
\67\ See Trade Acknowledgment and Verification Adopting Release,
81 FR at 39825.
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In the context described by the commenter--that is, a broker or
dealer's ANE activity on behalf of a majority-owned affiliate that is a
registered security-based swap dealer--the broker or dealer may wish to
deliver the Rule 10b-10 disclosures regarding the ANE activity in the
same document or communication as the trade acknowledgment or
verification that its affiliate delivers pursuant to Rule 15Fi-2. The
Commission recognizes, however, the potential for the different time
and form requirements in Rule 10b-10 and Rule 15Fi-2(b) and (c) to
frustrate attempts to deliver a single document or communication and
could, as a result, increase the costs and other burdens to investors
of responding to multiple communications regarding the ANE activity. As
a result, the Commission is granting the commenter's request for an
exemption from Rule 10b-10's requirement to deliver disclosures to a
customer at or before completion of the transaction, so as to allow
disclosures related to ANE activity to be provided at the time and in
the form of a trade acknowledgment as required by Rule 15Fi-2(b) and
(c), except that disclosures requested by the customer as allowed by
Rule 10b-10, which are not addressed in Rule 15Fi-2, must be delivered
in accordance with the deadlines specified in Rule 10b-10(c).\68\
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\68\ Rule 10b-10(c) requires a broker or dealer to ``give or
send to a customer information requested pursuant to [Rule 10b-10]
within five business days of receipt of the request,'' except that
``in the case of information pertaining to a transaction effected
more than 30 days prior to receipt of the request, the information
shall be given or sent to the customer within 15 business days.''
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Consistent with the Rule 10b-10-related exemptions and requirements
in the de minimis exception, the commenter requested that any relief
from Rule 10b-10's timing requirements also include the ability to
avoid violation of Rule 10b-10 so long as the broker or dealer provides
the disclosures promptly after discovery of a defect in its good faith
efforts to comply.\69\ This ability to provide disclosures either at
the time specified in the de minimis exception or promptly after
discovery of a defect in good faith efforts to do so was necessary, in
the context of the de minimis exception, to avoid a situation in which
a ``foot fault'' in Rule 10b-10 compliance would make the exemption
from broker registration unavailable.\70\ Because no exemption from
broker registration is at risk if the broker or dealer does not comply
with the conditions of the Rule 10b-10 exemption in this Order, this
``foot fault'' relief is not necessary. Rather, the consequence of not
complying with either Rule 10b-10's timing requirements, or Rule 15Fi-
2(b) and (c)'s form and timing requirements (and Rule 10b-10(c)'s
timing requirements as applicable) if the broker or dealer is relying
on this exemption, is that a broker or dealer would find itself out of
compliance with Rule 10b-10.
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\69\ See SIFMA September 2020 Letter at 5.
\70\ See Cross-Border Adopting Release, 85 FR at 6280 n.113.
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Accordingly, pursuant to its authority under Exchange Act Section
36, the Commission finds that it is necessary or appropriate in the
public interest, and consistent with the protection of investors, to
exempt a broker or dealer from the requirement to give or send to a
customer the disclosures required by Rule 10b-10(a) at or before
completion of the transaction solely in connection with such broker or
dealer or its associated persons arranging, negotiating or executing a
security-based swap transaction on behalf of a qualified majority-owned
affiliate, provided that such broker or dealer gives or sends to the
customer written notification containing the disclosures required by
Rule 10b-10(a) in connection with such arranging, negotiating or
executing in accordance with the time and form requirements for a trade
acknowledgment set forth in Rule 15Fi-2(b) and (c) under the Exchange
Act and, as applicable, Rule 10b-10(c) under the Exchange Act. For
purposes of this exemption, the term ``qualified majority-owned
affiliate'' means a majority-owned affiliate (as such term is defined
in Rule 3a71-3(a)(10) under the Exchange Act) of such broker or dealer
that is a registered security-based swap dealer.
4. Request for Relief From the Hypothecation Requirements With Respect
to Security-Based Swap Accounts
Exchange Act Section 8 provides, in pertinent part, that it shall
be unlawful for any broker or dealer, in contravention of such rules
and regulations as the Commission shall prescribe for the protection of
investors, to hypothecate or arrange for the hypothecation of any
securities carried for the account of any customer under circumstances:
(1) That will permit the commingling of the customer's securities
without the customer's written consent with the securities of any other
customer; (2) that will permit such securities to be commingled with
the securities of any person other than a bona fide customer; or (3)
that will permit such securities to be hypothecated, or subjected to
any lien or claim of the pledgee, for a sum in excess of the aggregate
indebtedness of such customers in respect of such securities.\71\
Pursuant to this authority, the Commission adopted Exchange Act Rules
8c-1 and 15c2-1. Exchange Act Rule 8c-1 places limitations on the
ability of a broker or dealer to hypothecate ``any securities carried
for the account of any customer.'' \72\ Exchange Act Rule 15c2-1
defines the phrase ``fraudulent, deceptive, or manipulative act or
practice'' as used in Exchange Act Section 15(c)(2) to include the
hypothecation of ``any securities carried for the account of any
customer'' that would be inconsistent with the limitations imposed by
Rule 8c-1.\73\ The commenter made two requests related to these
provisions.
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\71\ 15 U.S.C. 78h.
\72\ See 17 CFR 240.8c-1.
\73\ See 17 CFR 240.15c2-1.
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First, the commenter asked the Commission to clarify how the phrase
``securities carried for the account of any customer'' as used in
Exchange Act Rules 8c-1 and 15c2-1 applies to security-based swaps.\74\
The commenter stated that, for the purposes of the possession or
control requirements of Exchange Act Rule 15c3-3 as applied to
security-based swaps, the Commission, among other amendments, added a
definition of ``excess securities
[[Page 70673]]
collateral'' to the Rule 15c3-3.\75\ Rule 15c3-3 was further amended to
require a broker or dealer to promptly obtain and thereafter maintain
physical possession or control of all excess securities collateral
carried for the security-based swap accounts of security-based swap
customers.\76\ The commenter requested confirmation that, for the
purposes of Exchange Act Rules 8c-1 and 15c2-1, the term ``securities
carried for the account of any customer'' be interpreted in connection
with security-based swaps to have the same meaning as ``excess
securities collateral'' has for the purposes of Exchange Act Rule 15c3-
3. For the reasons discussed below, the Commission is not issuing the
interpretation suggested by the commenter and instead is issuing a
conditional exemption from Rules 8c-1 and 15c2-1 for securities and
money market instruments carried in a security-based swap account of a
security-based swap customer.
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\74\ See SIFMA January 2020 Letter at 3-4.
\75\ Id.; see also Capital, Margin and Segregation Adopting
Release, 84 FR at 43935-38; 17 CFR 240.15c3-3(p)(1)(ii). Exchange
Act Rule 18a-4 imposes segregation requirements on security-based
swap dealers that are not brokers or dealers (other than OTC
derivatives dealers). 17 CFR 240.18a-4. Exchange Act Rule 18a-4 has
a parallel definition of ``excess securities collateral.'' See 17
CFR 240.18a-4(a)(2).
\76\ See 17 CFR 240.15c3-3(p)(2). Exchange Act Rule 18a-4 has a
parallel requirement that the security-based swap dealer promptly
obtain and thereafter maintain physical possession or control of all
excess securities collateral carried for the security-based swap
accounts of security-based swap customers. See 17 CFR 240.18a-4(b).
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The term ``excess securities collateral'' as used in Exchange Act
Rules 15c3-3 and 18a-4 \77\ with respect to security-based swaps is
modelled on the terms ``fully paid securities'' and ``excess margin
securities'' as used in Exchange Act Rule 15c3-3 with respect to
securities that are not security-based swaps.\78\ Exchange Act Rule
15c3-3 requires a broker or dealer to promptly obtain and thereafter
maintain physical possession or control of all fully paid and excess
margin securities carried for the account of customers.\79\ Securities
that have been hypothecated are not in the physical possession or
control of the broker or dealer.\80\ However, securities that meet the
definition of ``margin securities'' in Exchange Act Rule 15c3-3 may be
hypothecated, subject to the requirements of that rule. Similarly, with
respect to security-based swaps, Exchange Act Rules 15c3-3 and 18a-4
require that a broker, dealer or security-based swap dealer promptly
obtain and thereafter maintain physical possession or control of
securities and money market instruments carried for the account of a
security-based swap customer that meet the rules' definitions of
``excess securities collateral.'' \81\ Securities or money market
instruments carried in the accounts of security-based swap customers
that do not meet the definition of ``excess securities collateral'' may
be hypothecated subject to the requirements of Exchange Act Rules 15c3-
3 and 18a-4. Consequently, while the respective limitations and anti-
fraud provisions of Rules 8c-1 and 15c2-1 apply to ``any securities
carried for the account of any customer,'' the possession or control
requirements of Rules 15c3-3 and 18a-4 apply to fully paid and excess
margin securities and excess securities collateral, respectively.
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\77\ 17 CFR 240.18a-4.
\78\ See Capital, Margin, and Segregation Adopting Release, 84
FR at 43935; 17 CFR 240.15c3-3(a)(3), (a)(5) and (p)(1)(ii).
\79\ See 17 CFR 240.15c3-3(b).
\80\ See 17 CFR 240.15c3-3(c) and (d); see also 17 CFR 240.15c3-
3(p)(2); 17 CFR 240.18a-4(b).
\81\ See 17 CFR 240.15c3-3(p)(2); 17 CFR 240.18a-4(b).
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Because Exchange Act Rules 8c-1 and 15c2-1 apply to any securities
carried for the account of any customer, interpreting the term ``any
securities carried for the account of any customer'' in those rules to
mean ``excess securities collateral'' as defined in Rules 15c3-3 and
18a-4 for the purposes of a security-based swap would not be
appropriate. Doing so could imply that the hypothecation rules do not
apply to certain securities carried for the accounts of customers when
the rules, in fact, apply to ``any securities carried for the account
of any customer.'' However, a limited exemption from Rules 8c-1 and
15c2-1 with respect to securities and money market instruments carried
in the security-based swap accounts of security-based swap customers
would be appropriate for the following reasons.
When adopting the segregation requirements for security-based
swaps, the Commission did not contemplate imposing the respective
limitations and anti-fraud provisions of Exchange Act Rules 8c-1 and
15c2-1 to securities and money market instruments carried in security-
based swap accounts of security-based swap customers. Moreover, the
Dodd-Frank Act did not mandate that the Commission implement
requirements with respect to security-based swaps that are analogous to
Rules 8c-1 and 15c2-1. Further, Rules 8c-1 and 15c2-1 were adopted in
1940 and were not designed to address security-based swaps.\82\
Exchange Act Rule 15c3-3 was adopted in 1972 to provide comprehensive
protection to customer funds and securities held by brokers and
dealers.\83\ The Commission addressed the protection of securities and
money market instruments carried in security-based swap accounts of
security-based swap customers through the recent amendments to Exchange
Act Rule 15c3-3 and the adoption of new Exchange Act Rule 18a-4.\84\
The amendments and new rule addressing security-based swaps were
modelled on the requirements and limitations in Exchange Rule 15c3-3
applicable to securities that are not security-based swaps. They were
not modelled on Exchange Act Rules 8c-1 and 15c2-1. Finally, Rules 8c-1
and 15c2-1 provide OTC derivatives dealers exemptions from their
requirements. Therefore, it is not necessary to impose the limitations
and anti-fraud provisions of Exchange Act Rules 8c-1 and 15c2-1 to
securities and money market instruments carried in security-based swap
accounts of security-based swap customers.\85\ This approach will
achieve the objective sought by the commenter in proposing the
interpretation discussed above: That Rules 8c-1 and 15c2-1 not apply to
securities and money market instruments carried in a security-based
swap account of a security-based swap customer.
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\82\ Hypothecation of Customers' Securities, 5 FR 4530 (Nov. 19,
1940) (adopting Exchange Act Rule 8c-1); Hypothecation of Customers'
Securities, 5 FR 4531 (Nov. 19, 1940) (adopting Exchange Act Rule
15c2-1).
\83\ See Broker-Dealers; Maintenance of Certain Basic Reserves,
Exchange Act Release No. 9856 (Nov. 17, 1972), 37 FR 25224 (Nov. 29,
1972) (``Rule 15c3-3 as adopted herein is well fashioned to furnish
the protection for the integrity of customer funds and securities as
envisioned by Congress when it amended section 15(c) (3) of the
[Exchange] Act by adopting section 7(d) of the Securities Investor
Protection Act of 1970 . . .''); see also Pub. L. 91-598 (Dec. 30,
1970). The hypothecation rules (Rules 8c-1 and 15c2-1) require that
a broker-dealer segregate customer securities from its own
proprietary securities and prescribe limits on a broker-dealer's
ability to hypothecate customer securities.
\84\ See Capital, Margin, and Segregation Adopting Release, 84
FR at 43930-43, 17 CFR 240.15c3-3(p); 17 CFR 240.18a-4.
\85\ A security-based swap dealer that is not also registered as
a broker or dealer is not subject to Exchange Act Rules 8c-1 and
15c2-1. Moreover, a security-based swap dealer that is also
registered as an OTC derivatives dealer can provide notifications to
its counterparties to remove them from the definitions of
``customer'' in Exchange Act Rules 8c-1 and 15c2-1 and, thereby,
avoid the requirement to comply with those rules. See 17 CFR 8c-
1(b); 17 CFR 240.15c2-1(b).
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However, Rules 8c-1 and 15c2-1 continue to apply to any securities
carried for all other customers. For example, as discussed above, the
requirement to promptly obtain and thereafter maintain physical
possession or control of securities (other than security-based swaps)
carried for the account of customers in Exchange Act Rule 15c3-3 does
not apply to ``margin
[[Page 70674]]
securities'' as defined in the rule.\86\ The commenter did not request
that ``margin securities,'' as defined in Rule 15c3-3, should be exempt
from Exchange Act Rules 8c-1 and 15c2-1 or that the Commission
interpret the term in a manner that removes them from the requirements
of those rules.
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\86\ See 17 CFR 240.15c3-3(a)(3), (a)(4), (a)(5) and (b).
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For these reasons, the Commission finds that it is necessary or
appropriate in the public interest, and is consistent with the
protection of investors to exempt securities and money market
instruments carried in a security-based swap account of a security-
based swap customer from the requirements of Exchange Act Rules 8c-1
and 15c2-1; provided the account does not hold ``margin securities'' as
defined in Exchange Act Rule 15c3-3.\87\ Further, this exemption does
not modify the requirement that a broker, dealer or security-based swap
dealer promptly obtain and thereafter maintain physical possession or
control of securities or money market instruments carried for the
accounts of security-based swap customers that meet the definition of
``excess securities collateral'' as required by Exchange Act Rules
15c3-3 and 18a-4, as applicable.
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\87\ As indicated, the relief does not extend to accounts that
hold ``margin securities'' as that term is defined in Exchange Act
Rule 15c3-3. Therefore, the exemption would not apply if the account
holds securities positions, other than security-based swaps, that
trigger the margin requirements of Regulation T of the Board of
Governors of the Federal Reserve System and/or the margin
requirements of the self-regulatory organizations applicable to
securities that are not security-based swaps (e.g., long securities
positions (other than security-based swaps) that have been financed
by the broker or dealer, short securities positions (other than
security-based swaps), or listed options). However, as discussed
above, the exemption applies to securities and money market
instruments held in a security-based swap account of a security-
based swap customer; provided they are not ``margin securities'' as
defined in Rule 15c3-3. For the purposes of this exemption, a broker
or dealer need not treat fully paid securities and money market
instruments in a security-based swap account of a security-based
swap customer that serve as collateral for security-based swap
positions and/or to meet the margin requirements of Exchange Act
Rule 18a-3 as ``margin securities'' as that term is defined in Rule
15c3-3.
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Second, the commenter asked the Commission to extend most, but not
all, of the Unlinked Temporary Exemptions from the hypothecation
requirements for security-based swaps. The current Unlinked Temporary
Exemptions from the hypothecation requirements apply without regard to
whether these requirements applied to the broker or dealer's security-
based swap positions or activities as of July 15, 2011 (i.e., the day
before relevant provisions of the Dodd-Frank Act became effective),\88\
and are set to expire on November 5, 2020.\89\ By contrast, the Linked
Temporary Exemptions from related customer protection requirements in
Exchange Act Rule 15c3-3 are limited to security-based swap positions
and activities not subject to that rule as of July 15, 2011, and are
set to expire on October 6, 2021, which is the compliance date for the
Commission's security-based swap-related amendments to Rule 15c3-3.\90\
The commenter asked the Commission to extend the Unlinked Temporary
Exemptions from the hypothecation requirements so that they would
expire on the compliance date for these security-based swap-related
amendments to Rule 15c3-3.\91\ The commenter asked the Commission to
extend these exemptions consistent with the scope of the Linked
Temporary Exemptions from Rule 15c3-3--that is, only to the extent that
the hypothecation requirements did not apply to the broker or dealer's
security-based swap positions or activities as of July 15, 2011.\92\
The commenter stated that the policies, procedures, processes, systems
and controls that brokers and dealers use to comply with Rules 8c-1 and
15c2-1 are integrated with the policies, procedures, processes, systems
and controls that they use to comply with Rule 15c3-3. Therefore, the
commenter requested that the Unlinked Temporary Exemptions from Rules
8c-1 and 15c2-1 be extended to align with the expiration date for the
Linked Temporary Exemptions from Rule 15c3-3.\93\
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\88\ See 2011 Exchange Act Exemptive Order, 76 FR at 39939.
\89\ See January 2020 Extension Order, 85 FR at 2766.
\90\ See 2014 Extension Order, 79 FR at 7734.
\91\ See SIFMA January 2020 Letter at 3-4; SIFMA December 2018
Letter at 5.
\92\ See SIFMA January 2020 Letter at 3-4.
\93\ See id.
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For the reasons provided by the commenter, the Commission believes
that it would be appropriate to extend the Unlinked Temporary
Exemptions from Rules 8c-1 and 15c2-1 so that they expire at the same
time as the Linked Temporary Exemptions from Rule 15c3-3. This
extension would provide brokers and dealers time to implement a single
set of policies, procedures, and controls to comply with Rules 8c-1,
15c2-1 and 15c3-3 as they apply to security-based swap positions.
Accordingly, pursuant to its authority under Exchange Act Section 36,
the Commission finds that it is necessary or appropriate in the public
interest, and consistent with the protection of investors, to extend
the Unlinked Temporary Exemptions from Exchange Act Section 8 and
Exchange Act Rules 8c-1 and 15c2-1 until October 6, 2021.
5. Request for Exemptions From Broker and Dealer Disclosure
Requirements Relating to Extensions of Credit
Exchange Act Rule 15c2-5(a)(1) imposes disclosure requirements, and
Rule 15c2-5(a)(2) imposes suitability requirements, on brokers and
dealers that that directly or indirectly offer to extend credit to or
arrange any loan for, or extend to or participate in any loan for, any
person in connection with the offer or sale of any security to, or the
attempt to induce the purchase of any security by, such person, subject
to certain exceptions. Exchange Act Rule 10b-16 imposes additional
requirements on brokers and dealers that directly or indirectly extend
credit to any customer in connection with any securities transaction.
Subject to certain exceptions, these brokers and dealers must establish
procedures to assure that each customer receives certain lending
disclosures.\94\ Citing the Commission's 2002 guidance on the
application of certain securities laws to security futures
products,\95\ the commenter expressed the view that security-based
swaps ``should not in and of themselves constitute extensions of
credit'' subject to these suitability and disclosure requirements.\96\
The commenter asked the Commission to confirm this view or, in the
alternative, exempt security-based swap activity from these extension
of credit requirements.\97\
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\94\ See Exchange Act Rule 10b-16(a).
\95\ Commission Guidance on the Application of Certain
Provisions of the Securities Act of 1933, the Securities Exchange
Act of 1934, and Rules Thereunder to Trading in Security Futures
Products, Exchange Act Release No. 46101 (Jun. 21, 2002), 67 FR
43234 (Jun. 27, 2002) (``Security Futures Release'').
\96\ See SIFMA January 2020 Letter at 4.
\97\ See SIFMA September 2020 Letter at 6-7; SIFMA January 2020
Letter at 4; SIFMA December 2018 Letter at 5-6; SIFMA November 2018
Letter at 3.
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The Commission believes that, based on the facts and circumstances
of a particular transaction, an extension of credit subject to the
suitability and disclosure requirements of Rules 15c2-5 and 10b-16 may
or may not be made in connection with a security-based swap
transaction. This belief is consistent with both the Commission's 2002
guidance \98\ on the application of
[[Page 70675]]
extension of credit requirements to security futures products and the
Commission and the Commodity Futures Trading Commission's 2012 joint
release \99\ on the definition of ``security-based swap.'' The
relationship between an extension of credit and a security-based swap
thus does not shield the extension of credit from application of Rules
15c2-5 and 10b-16. When an extension of credit is made in connection
with a security-based swap transaction, however, brokers and dealers
may as appropriate to the facts and circumstances devise a single
suitability assessment to satisfy applicable provisions of Rule 15c2-
5(a)(2) and Exchange Act Rule 15Fh-3(f),\100\ as well as a single set
of disclosures to satisfy applicable provisions of Rules 10b-16 and
15c2-5(a)(1) and Exchange Act Rule 15Fh-3(b).\101\
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\98\ This guidance noted that ``Rule 10b-16 applies to all
extensions of credit, directly or indirectly, to any customer in
connection with any securities transaction, including a security
future. Investors in security futures, including those extended
credit in connection with margining, should benefit from the
transparency of credit terms fostered by this Rule.'' See Security
Futures Release, 67 FR at 43246. An extension of credit could be
part of a transaction involving a security future.
\99\ The Commissions noted that, depending on the facts and
circumstances, a loan participation may be a security but not a
``security-based swap,'' the definition of which excludes certain
agreements, contracts and transactions that provide for the purchase
or sale of 1 or more securities on a fixed or contingent basis and
that are subject to the Securities Act of 1933 and the Exchange Act.
See Product Definitions Adopting Release, 77 FR at 48251; Exchange
Act Section 3(a)(68)(A)(i) (a security-based swap must be a ``swap''
as defined in certain provisions of Section 1a of the Commodity
Exchange Act); Commodity Exchange Act Section 1a(47)(B)(v)-(vi)
(exclusion of these agreements, contracts and transactions from the
definition of ``swap''). Alternatively, a loan participation could
be a security-based swap if the grantor of the loan participation
extends financing to the participant. See Product Definitions
Adopting Release, 77 FR at 48251. This ``leverage could be
indicative of an instrument that is merely an exchange of payments
and not a transfer of the ownership of the underlying loan or
commitment, such as may be the case with a . . . security-based
swap.'' Product Definitions Adopting Release, 77 FR at 48251. An
extension of financing could be part of a transaction classified as
a security-based swap.
\100\ 17 CFR 240.15Fh-3(f).
\101\ 17 CFR 240.15Fh-3(b).
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Because an extension of credit may or may not be made in connection
with a security-based swap transaction, the Commission believes that a
permanent exemption from Rules 10b-16 and 15c2-5 for security-based
swap activity is not warranted. The Commission thus is not further
extending the Unlinked Temporary Exemptions from Exchange Act Rules
10b-16 and 15c2-5.
6. Request for Exemptions From Certain Limitations on an OTC
Derivatives Dealer's Activities
Exchange Act Rule 15a-1 limits the securities activities of an OTC
derivatives dealer. The commenter made three requests related to these
limitations. First, Rule 15a-1(a)-(b) permits OTC derivatives dealers
to engage in dealer activities when the security is an eligible OTC
derivatives instrument. Eligible OTC derivatives instruments are
defined to exclude any contract, agreement or transaction that is ``one
of a class of fungible instruments that are standardized as to their
material economic terms.'' \102\ The commenter noted that centrally
cleared security-based swaps might not qualify as eligible OTC
derivatives instruments and thus Rule 15a-1 might not permit OTC
derivatives dealers to deal in them.\103\ Based on this specific
concern, the commenter requested a permanent exemption for all
security-based swaps with or for eligible contract participants from
all provisions of Rule 15a-1.\104\
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\102\ See Exchange Act Rule 3b-13(b)(2), 17 CFR 240.3b-13(b)(2).
\103\ See SIFMA September 2020 Letter at 7; SIFMA January 2020
Letter at 4-5. In earlier requests, the commenter also noted that
``some [security-based swaps] might, in the future, be listed or
traded on an exchange.'' See SIFMA December 2018 Letter at 6-7;
SIFMA November 2018 Letter at 4. Because eligible OTC derivatives
also exclude any contract, agreement or transaction that is listed
or traded on a national securities exchange or registered national
securities association or facility or market thereof, in earlier
letters the commenter also requested an exemption from Rule 15a-1 to
allow OTC derivatives dealers to deal in those instruments. See
Exchange Act Rule 3b13(b)(2); SIFMA December 2018 Letter at 6-7;
SIFMA November 2018 Letter at 4. The Commission is not providing an
exemption or guidance regarding the application of Rule 15a-1 to
those security-based swaps because at this time no security-based
swap is listed or traded on a national securities exchange or
registered national securities association or facility or market
thereof. If a security-based swap becomes so listed or traded in the
future, the Commission would consider a request for exemption from
or guidance regarding Rule 15a-1 for those instruments based on the
facts and circumstances at that time.
\104\ See SIFMA January 2020 Letter at 4-5.
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Because centrally cleared security-based swaps typically contain
standardized terms, they might be fungible instruments standardized as
to their material economic terms and thus might not qualify as eligible
OTC derivatives instruments. Though not raised in the commenter's
request, the same also is true of security-based swaps that are
eligible for central clearing even if they are not in fact centrally
cleared. As a result, dealing in these types of security-based swaps
could eliminate a market participant's OTC derivatives dealer status
and require full registration as a dealer, even if that security-based
swap dealing is with an eligible contract participant and thus excluded
from the statutory definition of ``dealer.'' \105\ Because Exchange Act
Section 3(a)(5) excludes security-based swap dealing with or for an
eligible contract participant from the definition of ``dealer,'' the
Commission believes that this same dealing activity should not cause an
OTC derivatives dealer to lose its eligibility for Rule 15a-1's
exemption from full dealer registration. Such a result could be avoided
if eligible OTC derivative instruments included security-based swaps
with or for an eligible contract participant whose terms are
standardized to be eligible for central clearing. Because including
these security-based swaps within the scope of eligible OTC derivative
instruments would address the commenter's concern about OTC derivatives
dealers' ability to deal in centrally cleared security-based swaps (and
also allows OTC derivatives dealers to deal in security-based swaps
whose terms are standardized to be eligible for central clearing but
that are not in fact centrally cleared), the Commission does not
believe that an exemption for these security-based swaps from all
provisions of Rule 15a-1 is necessary. Accordingly, pursuant to its
authority under Exchange Act Section 15(a)(2) and Exchange Act Rule
15a-1(b)(2), the Commission finds that it is consistent with the public
interest and the protection of investors to determine that security-
based swaps with or for an eligible contract participant whose terms
are standardized to be eligible for central clearing are within the
scope of an ``eligible OTC derivative instrument'' as defined in Rule
3b-13(b)(2).
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\105\ See Exchange Act Rule 15a-1(a)(1)(i) (securities
activities of an OTC derivatives dealer must be limited, in relevant
part, to engaging in dealer activities in eligible OTC derivatives
instruments that are securities). Rule 15a-1's requirement that OTC
derivatives dealers limit their securities dealing to eligible OTC
derivatives instruments does not contain an exception for security-
based swaps with an eligible contract participant that are not
eligible OTC derivatives instruments.
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Second, Rule 15a-1(c) generally requires that all securities
transactions of an OTC derivatives dealer, including OTC derivatives
transactions, be effected through a full-purpose broker or dealer or
full-purpose broker or dealer affiliate.\106\ Further, Rule 15a-1(d)
requires OTC derivatives dealers to conduct certain customer-facing
contacts through registered representatives of a full-purpose broker or
full-purpose broker or dealer affiliate. These requirements do not
apply to transactions with a registered broker or dealer, a bank acting
in a dealer capacity, a foreign broker or dealer, or any affiliate of
the OTC derivatives dealer.\107\ The commenter requested that
[[Page 70676]]
the Commission exempt OTC derivatives dealers from the requirement in
Rule 15a-1(d) because standalone and bank-affiliated SBS Entities are
not required to employ registered representatives for customer-facing
SBS transactions.\108\ The commenter also requested a permanent
exemption for all security-based swaps with or for eligible contract
participants from all provisions of Rule 15a-1.\109\
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\106\ See Exchange Act Rule 15a-1(c).
\107\ See Exchange Act Rule 15a-1(c)-(d).
\108\ See SIFMA January 2020 Letter at 5.
\109\ See SIFMA January 2020 Letter at 4-5.
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SBS Entities are subject to the Title VII regulatory framework,
while standalone OTC derivatives dealers are not. The Commission thus
does not believe that it is necessary or appropriate to exempt
standalone OTC derivatives dealers from Rule 15a-1 simply because its
requirements do not apply to other market participants that are subject
to a separate, comprehensive regulatory framework. By contrast,
however, a dually-registered OTC derivatives dealer and SBS Entity
would be subject to the Title VII regulatory framework in relation to
its security-based swap transactions. Such a dually-registered entity
could find that Rule 15a-1 requires it either to effect security-based
swap transactions through a registered broker or dealer (in the case of
Rule 15a-1(c)) or utilize registered representatives for certain
customer-facing security-based swap transactions (in the case of Rule
15a-1(d)), on the one hand, or to register as a full-purpose dealer, on
the other hand, even if the security-based swap is with or for an
eligible contract participant and thus excluded from the definition of
``dealer.'' To avoid this result, the Commission believes that a
dually-registered OTC derivatives dealer and SBS Entity's security-
based swap transactions with or for an eligible contract participant,
and its communications and contacts with an eligible contract
participant concerning a security-based swap transaction, should be
exempt from Rules 15a-1(c) and (d), respectively.
Accordingly, pursuant to its authority under Exchange Act Section
15(a)(2), the Commission finds that it is consistent with the public
interest and the protection of investors to exempt a registered OTC
derivatives dealer that is also a registered SBS Entity from Rule 15a-
1(c) solely in connection with security-based swap transactions with or
for an eligible contract participant, and from Rule 15a-1(d) solely in
connection with communications and contacts with an eligible contract
participant concerning a security-based swap transaction.
Third, the commenter asked the Commission to extend the Unlinked
Temporary Exemptions from Rule 15a-1 until the compliance date for the
Commission's SBS Entity registration requirements,\110\ which is
October 6, 2021.\111\ The current Unlinked Temporary Exemptions from
Rule 15a-1 are set to expire on November 5, 2020.\112\
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\110\ See SIFMA December 2020 Letter at 6.
\111\ See Cross-Border Adopting Release, 85 FR at 6345.
\112\ See January 2020 Extension Order, 85 FR at 2766.
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As discussed above, the Commission is exempting a registered OTC
derivatives dealer that is also a registered SBS Entity from Rules 15a-
1(c) and (d) for certain security-based swap-related communications and
contacts. OTC derivatives dealers will not, however, begin counting
transactions towards the SBS Entity registration thresholds until
August 6, 2021. The Commission believes that requiring OTC derivatives
dealers to implement policies, procedures and controls to comply with
Rules 15a-1(c) and (d) for the short period until they begin to
register as SBS Entities potentially could impose undue cost and
resource burdens and cause unnecessary market disruption. Rather,
extending the Unlinked Temporary Exemptions from Rule 15a-1(c) and (d)
until October 6, 2021, would allow market participants to implement
policies, procedures and controls that take into account this new
limited exemptive relief from Rule 15a-1(c) and (d) at the time when
that relief can be utilized. Accordingly, pursuant to its authority
under Exchange Act Section 36, the Commission finds that it is
necessary or appropriate in the public interest, and consistent with
the protection of investors, to extend the Unlinked Temporary
Exemptions from Rules 15a-1(c) and (d) until October 6, 2021. This
limited temporary exemption addresses the commenter's concern about OTC
derivatives dealers' ability to conduct customer-facing contacts
without a registered representative until they can begin to register as
SBS Entities.
7. Exchange Act Section 29(b)
Exchange Act Section 29(b) \113\ generally provides that contracts
made in violation of any provision of the Exchange Act or the rules or
regulations thereunder shall be void ``(1) as regards the rights of any
person who, in violation of any such provision . . . shall have made or
engaged in the performance of any such contract, and (2) as regards the
rights of any person who, not being a party to such contracts, shall
have acquired any right thereunder with actual knowledge of the facts
by reason of which the making or performance of such contracts in
violation of any such provision.'' In 2011, the Commission provided
temporary exemptive relief from Section 29(b) in connection with the
temporary exemptions that include the Linked Temporary Exemptions and
Unlinked Temporary Exemptions discussed in this Order. By its terms,
that exemption from Section 29(b) will expire on November 5, 2020 (for
the Unlinked Temporary Exemptions discussed but not extended in this
Order) or October 6, 2021 (for the remaining Linked Temporary
Exemptions and Unlinked Temporary Exemptions discussed in this
Order).\114\ The Commission made clear that it did not believe that
Section 29(b) would apply to provisions subject to those temporary
exemptions, and that it provided the exemption from Section 29(b) only
to make that view clear to market participants and ``to eliminate any
possible legal uncertainty or market disruption.'' \115\ Likewise, the
Commission believes that Section 29(b) would not apply to circumstances
in which a market participant complies with the permanent exemptive
relief provided in this Order, and therefore, for the reasons discussed
above, is not providing further exemptive relief from Section 29(b).
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\113\ 15 U.S.C. 78cc(b).
\114\ See 2011 Exchange Act Exemptive Order, 76 FR at 39940
(Section 29(b) exemptive relief in connection with temporary
exemptive relief from other Exchange Act provisions expires at
``such time as the underlying exemptive relief expires'').
\115\ See 2011 Exchange Act Exemptive Order, 76 FR at 39926.
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II. Exemption in Connection With Registration of Security-Based Swap
Dealers and Major Security-Based Swap Participants
Also in 2011, the Commission issued an order providing separate
temporary exemptive relief from Section 29(b) in connection with the
portion of the Dodd-Frank Act's security-based swap-related amendments
to the Exchange Act for which the Commission has taken the view that
compliance will be triggered by registration of a person or by adoption
of final rules by the Commission, or for which the Commission provided
an exception or exemptive relief.\116\ By its terms, most of
[[Page 70677]]
this exemptive relief expires on such date as the Commission
specifies.\117\
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\116\ See Temporary Exemptions and Other Temporary Relief,
Together with Information on Compliance Dates for New Provisions of
the Securities Exchange Act of 1934 Applicable to Security-Based
Swaps, Exchange Act Release No. 64678 (Jun. 15, 2011), 76 FR 36287,
36307 (``2011 Compliance Date Order'').
\117\ See 2011 Compliance Date Order, 76 FR at 36307. The
Section 29(b) exemption related to exemptions from Exchange Act
Sections 3E(f) and 15F(b)(6) provided in the 2011 Compliance Date
Order expire on the compliance date for rules governing the
registration of SBS Entities, which will be October 6, 2021. See
Order Pursuant to Sections 15F(b)(6) and 36 of the Securities
Exchange Act of 1934 Extending Certain Temporary Exemptions and a
Temporary and Limited Exception Related to Security-Based Swaps,
Exchange Act Release No. 75919 (Sep. 15, 2015), 80 FR 56519 (Sep.
18, 2015). The exemption from Exchange Act Section 6(l) provided in
the 2011 Compliance Date Order expired 60 days after the August 13,
2012, publication of the Product Definitions Adopting Release in the
Federal Register. See Order Extending Temporary Conditional
Exemption in Connection with the Effectiveness of the Definition of
Eligible Contract Participant, Exchange Act Release No. 67480 (Jul.
20, 2012), 77 FR 43878, 43879 (Jul. 26, 2012). In a later release,
the Commission implied that the 2011 Compliance Date Order had
specified that the Section 29(b) exemption related to this exemption
from Section 6(l) would expire at the same time as the exemption
from Section 6(l). See Further Definition of ``Swap Dealer,''
``Security-Based Swap Dealer,'' ``Major Swap Participant,'' ``Major
Security-Based Swap Participant'' and ``Eligible Contract
Participant,'' Exchange Act Release No. 66868 (Apr. 27, 2012), 77 FR
30596, 30700 n.1248 (May 23, 2012). Rather, the 2011 Compliance Date
Order specified that this Section 29(b) exemption would expire on
such date as the Commission specifies. See 2011 Compliance Date
Order, 76 FR at 36307. Market participants thus may be uncertain
whether this portion of the 29(b) exemption has expired.
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The Commission made clear then that it did not believe that Section
29(b) would apply to the Dodd-Frank Act's security-based swap-related
amendments to the Exchange Act for which the Commission has taken the
view that compliance will be triggered by registration of a person or
by adoption of final rules by the Commission, or for which the
Commission provided an exception or exemptive relief, and that it
provided the exemption from Section 29(b) only ``to avoid possible
legal uncertainty or market disruption.'' \118\ The Commission granted
this temporary exemptive relief, however, ``to avoid possible legal
uncertainty or market disruption.'' \119\ The Commission believes now,
more than nine years after the relevant amendments to the Dodd-Frank
Act took effect, that the opportunity for possible legal uncertainty or
market disruption related to the effective date of these amendments has
passed. To provide market participants with certainty about when this
separate temporary exemptive relief from Section 29(b) will expire, the
Commission now believes that all of this exemptive relief from Section
29(b) should expire on the same date. Because some of this relief is
already scheduled to expire on the compliance date for rules regarding
registration and regulation of SBS Entities,\120\ which will be October
6, 2021, the Commission thus believes that it is appropriate for all of
this Section 29(b) relief to expire on that date. Accordingly, the
Commission has determined that this exemption from Section 29(b) shall
expire on October 6, 2021.
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\118\ See 2011 Compliance Date Order, 76 FR at 36305.
\119\ See id.
\120\ See Cross-Border Adopting Release, 85 FR at 6345.
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III. Conclusion
It is hereby ordered, pursuant to Section 15(a)(2) of the Exchange
Act, that a ``foreign broker or dealer,'' as such term is defined in
Rule 15a-6(b)(3) under the Exchange Act, whose activities in securities
other than security-based swaps with or for an eligible contract
participant are conducted either in compliance with Rule 15a-6 under
the Exchange Act or without the jurisdiction of the United States,
shall be exempt from the registration requirement of Section 15(a)(1)
of the Exchange Act solely in connection with the foreign broker or
dealer's security-based swap dealing with or for an eligible contract
participant.
It is hereby ordered, pursuant to Section 15(a)(2) of the Exchange
Act, that until November 1, 2022, a registered security-based swap
dealer and its associated persons shall be exempt from the broker
registration requirement of Section 15(a)(1) of the Exchange Act solely
in connection with such registered security-based swap dealer or
associated person arranging, negotiating or executing a security-based
swap transaction with or for a non-U.S. person eligible contract
participant on behalf of a non-U.S. person qualified majority-owned
affiliate; provided that (A) such registered security-based swap dealer
creates and maintains books and records relating to such arranging,
negotiating or executing activity that are required by Rules 18a-5 and
18a-6 under the Exchange Act and (B) if Rule 10b-10 under the Exchange
Act would apply to such arranging, negotiating or executing activity,
such registered security-based swap dealer provides to the customer the
disclosures required by Rule 10b-10(a)(2) (excluding Rule 10b-
10(a)(2)(i) and (ii)) and Rule 10b-10(a)(8) in accordance with the time
and form requirements set forth in Rule 15Fi-2(b) and (c) under the
Exchange Act or, alternatively, promptly after discovery of any defect
in such registered security-based swap dealer's good faith effort to
comply with such requirements. For purposes of this exemption, the term
``qualified majority-owned affiliate'' means a majority-owned affiliate
(as such term is defined in Rule 3a71-3(a)(10) under the Exchange Act)
of such registered security-based swap dealer that is itself also a
registered security-based swap dealer.
It is hereby further ordered, pursuant to Section 36 of the
Exchange Act, that a broker or dealer shall be exempt from the
requirement to give or send to a customer the disclosures required by
Rule 10b-10(a) under the Exchange Act at or before completion of the
transaction solely in connection with such broker or dealer or its
associated persons arranging, negotiating or executing a security-based
swap transaction on behalf of a qualified majority-owned affiliate;
provided that such broker or dealer gives or sends to the customer
written notification containing the disclosures required by Rule 10b-
10(a) under the Exchange Act in connection with such arranging,
negotiating or executing in accordance with the time and form
requirements for a trade acknowledgment set forth in Rule 15Fi-2(b) and
(c) under the Exchange Act and, as applicable, Rule 10b-10(c) under the
Exchange Act. For purposes of this exemption, the term ``qualified
majority-owned affiliate'' means a majority-owned affiliate (as such
term is defined in Rule 3a71-3(a)(10) under the Exchange Act) of such
broker or dealer that is a registered security-based swap dealer.
It is hereby further ordered, pursuant to Section 36 of the
Exchange Act, that brokers and dealers are exempt from the requirements
of Rules 8c-1 and 15c2-1 under the Exchange Act with respect to
securities and money market instruments carried in a security-based
swap account of a security-based swap customer; provided the account
does not hold ``margin securities'' as defined in Rule 15c3-3 under the
Exchange Act.
It is hereby further ordered, pursuant to Section 15(a)(2) of the
Exchange Act and Rule 15a-1(b)(2) under the Exchange Act, that a
security-based swap with or for an eligible contract participant whose
terms are standardized to make the security-based swap eligible for
central clearing shall be within the scope of an ``eligible OTC
derivative instrument'' as defined in Rule 3b-13 under the Exchange
Act.
It is hereby further ordered, pursuant to Section 15(a)(2) of the
Exchange Act, that a registered OTC derivatives dealer also registered
with the Commission as a security-based swap dealer or major security-
based swap participant shall be exempt from Rule 15a-1(c) under the
[[Page 70678]]
Exchange Act solely in connection with security-based swap transactions
with or for an eligible contract participant and Rule 15a-1(d) under
the Exchange Act solely in connection with communications and contacts
with an eligible contract participant concerning a security-based swap
transaction.
It is hereby further ordered, pursuant to Section 36 of the
Exchange Act, that the Unlinked Temporary Exemptions from Section 8 of
the Exchange Act and from Rules 8c-1, 15c2-1, 15a-1(c) and 15a-1(d)
under the Exchange Act in connection with the revision of the Exchange
Act definition of ``security'' to encompass security-based swaps, in
each case contained in the 2011 Exchange Act Exemptive Order and
extended in the January 2020 Extension Order, are extended until
October 6, 2021.
It is hereby further ordered, pursuant to Section 36 of the
Exchange Act, that the exemption from Section 29(b) of the Exchange Act
contained in the 2011 Compliance Date Order shall expire on October 6,
2021.
By the Commission.
Vanessa A. Countryman,
Secretary.
[FR Doc. 2020-24598 Filed 11-4-20; 8:45 am]
BILLING CODE 8011-01-P