Self-Regulatory Organizations; The Options Clearing Corporation; Order Approving Proposed Rule Change to Concerning the Options Clearing Corporation's System for Theoretical Analysis and Numerical Simulation (“STANS”) Methodology Documentation, 9410-9413 [2021-02859]
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Federal Register / Vol. 86, No. 28 / Friday, February 12, 2021 / Notices
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
• Use the Commission’s internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
CboeEDGX–2021–009 on the subject
line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE,
Washington, DC 20549–1090.
All submissions should refer to File
Number SR–CboeEDGX–2021–009. This
file number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
internet website (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for website viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE,
Washington, DC 20549, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change.
Persons submitting comments are
cautioned that we do not redact or edit
personal identifying information from
comment submissions. You should
submit only information that you wish
to make available publicly. All
submissions should refer to File
Number SR–CboeEDGX–2021–009 and
should be submitted on or before March
5, 2021.
CFR 200.30–3(a)(12).
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17:27 Feb 11, 2021
[FR Doc. 2021–02857 Filed 2–11–21; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
Electronic Comments
25 17
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.25
J. Matthew DeLesDernier,
Assistant Secretary.
Jkt 253001
[Release No. 34–91079; File No. SR–OCC–
2020–016]
Self-Regulatory Organizations; The
Options Clearing Corporation; Order
Approving Proposed Rule Change to
Concerning the Options Clearing
Corporation’s System for Theoretical
Analysis and Numerical Simulation
(‘‘STANS’’) Methodology
Documentation
February 8, 2021.
I. Introduction
On December 9, 2020, the Options
Clearing Corporation (‘‘OCC’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change SR–OCC–2020–
016 (‘‘Proposed Rule Change’’) pursuant
to Section 19(b) of the Securities
Exchange Act of 1934 (‘‘Exchange
Act’’) 1 and Rule 19b–4 2 thereunder to
adopt a new document describing OCC’s
system for calculating daily and intraday margin requirements for its Clearing
Members.3 The Proposed Rule Change
was published for public comment in
the Federal Register on December 29,
2020.4 The Commission has received no
comments regarding the Proposed Rule
Change. This order approves the
Proposed Rule Change.
II. Background
To manage the credit risk posed by its
Clearing Members, OCC collects margin
collateral both daily and intraday. OCC
uses its System for Theoretical Analysis
and Numerical Simulation (‘‘STANS’’)
to set risk-based margin requirements
for its Clearing Members. The margin
requirements calculated using STANS
consist of an estimate of a 99 percent
expected shortfall (‘‘ES’’) over a two-day
time horizon with additional charges for
model risk, stress tests, liquidation
costs, and various add-ons.
OCC maintains technical
documentation that describes how the
various quantitative components of
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Notice of Filing infra note 4, 85 FR at 85788.
4 Securities Exchange Act Release No. 34–90763
(Dec. 21, 2020), 85 FR 85788 (Dec. 29, 2020) (File
No. SR–OCC–2020–016) (‘‘Notice of Filing’’).
2 17
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STANS were developed and operate,
including the various parameters and
assumptions contained within those
components 5 and the mathematical
theories underlying the selection of
those quantitative methods (‘‘Model
Whitepapers’’). The Model Whitepapers
are currently synthesized in a single
document, the Margins Methodology,
describing how STANS operates from
end to end. Pursuant to section 19(b) of
the Exchange Act and Rule 19b–4
thereunder,6 OCC has filed, and the
Commission has approved, sections of
OCC’s Margins Methodology as rules in
the past.7 OCC has not, however, filed
the Margins Methodology in its entirety.
Additionally, OCC has requested
confidential treatment for those sections
of the Margins Methodology that it has
filed with the Commission.8
OCC now proposes to replace the
Margins Methodology in its entirety
(both sections that have and have not
been filed as rules) with a description of
OCC’s system for calculating daily and
intra-day margin requirements for its
Clearing Members (the ‘‘STANS
Methodology Description’’).9 OCC stated
that the proposed STANS Methodology
Description includes the material
aspects of OCC’s risk-based margin
system.10 OCC intends to make the
proposed STANS Methodology
5 See Securities Exchange Act Release No. 82473
(Jan. 9, 2018), 83 FR 2271 (Jan. 16, 2018) (File No.
SR–OCC–2017–011), which describes how OCC
periodically reviews the parameters and
assumptions used by STANS pursuant to its Model
Risk Management Policy and in accordance with 17
CFR 240.17Ad–22(e)(6).
6 15 U.S.C. 78s(b)(1) and 17 CFR 240.19b–4.
7 See Securities Exchange Act Release No. 74966
(May 14, 2015), 80 FR 29784 (May 22, 2015) (File
No. SR–OCC–2015–010); Securities Exchange Act
Release No. 76128 (Dec. 28, 2015), 81 FR 135 (Jan.
4, 2016) (File No. SR–OCC–2015–016); Securities
Exchange Act Release No. 79818 (Jan. 18, 2017), 82
FR 8455 (Jan. 25, 2017) (File No. SR–OCC–2017–
001); Securities Exchange Act Release No. 82161
(Nov. 28, 2017), 82 FR 57306 (Dec. 4, 2017) (File
No. SR–OCC–2017–022); Securities Exchange Act
Release No. 84524 (Nov. 2, 2018), 83 FR 55918
(Nov. 8, 2018) (File No. SR–OCC–2018–014);
Securities Exchange Act Release No. 85440 (Mar.
28, 2019), 84 FR 13082 (Apr. 3, 2019) (File No. SR–
OCC–2019–002); Securities Exchange Act Release
No. 85755 (Apr. 30, 2019), 87 FR 19815 (May 6,
2019) (File No. SR–OCC–2019–004); Securities
Exchange Act Release No. 86296 (Jul. 3, 2019), 84
FR 32816 (Jul. 9, 2019) (File No. SR–OCC–2019–
005); Securities Exchange Act Release No. 87387
(Oct. 23, 2019), 84 FR 57890 (Oct. 29, 2019) (File
No. SR–OCC–2019–010); Securities Exchange Act
Release No. 89392 (Jul. 24, 2020), 85 FR 45938 (Jul.
30,2020) (File No. SR–OCC–2020–007); Securities
Exchange Act Release No. 90139 (Oct. 8, 2020), 85
FR 65886 (Oct. 16, 2020) (File No. SR– OCC–2020–
012).
8 See id.
9 OCC also proposes conforming changes to its
Margin Policy.
10 See Notice of Filing, 85 FR at 85789.
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Federal Register / Vol. 86, No. 28 / Friday, February 12, 2021 / Notices
Description available to Clearing
Members.11
The proposed STANS Methodology
Description would include substantially
the same information as the Margins
Methodology with the exception of
various details, described below, that
OCC does not believe would be
appropriately included in the STANS
Methodology Description.12 OCC stated
that the purpose of the STANS
Methodology Description would be to
enable an informed reader to
understand OCC’s modeling choices and
the interconnectedness of STANS model
components in producing OCC margin
requirements, and that the portions of
the Margins Methodology not carried
forward in the STANS Methodology
Description are extraneous to this
purpose.13
Proposed STANS Methodology
Description
As noted above, the proposed STANS
Methodology Description covers OCC’s
system for calculating daily and intraday margin requirements for its Clearing
Members. The proposed document
includes three sections with various
subsections as described below and in
greater detail in the Notice of Filing.
The STANS Methodology Description
begins with an executive summary. The
executive summary would state that the
purpose of STANS is to determine
margin requirements for OCC’s Clearing
Members, and would describe the types
of positions and collateral modeled
through STANS. The executive
summary would also briefly describe
OCC’s procedures related to both model
monitoring and price editing.
Model components. The bulk of the
STANS Methodology Description covers
the model components in STANS,
including model and econometric
calibration, copula construction,
implied volatility smoothing and
options pricing, and the application of
the theoretical derivatives prices to
actual positions in Clearing Members’
accounts to calculate margin
requirements through the aggregation of
various component charges. The subsections related to model and
econometric calibration cover the use of
(i) returns on equity securities that are
based on current market prices to create
econometric parameters and for pricing;
(ii) implied volatility risk factors to
measure the expected future volatility of
an option’s underlying security at
expiration; (iii) Nelson-Siegel
11 See
Notice of Filing, 85 FR at 85790.
does not propose to change its margin
methodology as part of the Proposed Rule Change.
13 See Notice of Filing, 85 FR at 85790.
12 OCC
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framework to price treasury securities;
(iv) a generic futures model to price
linear derivatives with limited term
structures; (v) a specialized factor model
to price variance futures; (vi) a synthetic
futures model to price specified
products such as volatility index-based
futures (e.g., VIX futures); and (vii)
econometric parameters related to
volatility forecasts and marginal
distributions, and calibrates these
parameters using ten-year histories of
the foregoing data inputs.
The sub-sections related to copula
construction describes the use of a
copula to quantify the joint behavior
and dependence structure of the risk
factors used by STANS.14 The STANS
Methodology Description covers OCC’s
process for estimating the copula as well
as simulating price movements based on
random draws from the multivariate
Student’s t-distribution described by the
copula. The document also describes
OCC’s process for identifying and
separately processing risk factors with
incomplete data sets that lack sufficient
data to estimate the copula. Specifically,
the STANS Methodology Description
addresses the application of conditional
and default simulations to estimate
correlations for risk factors excluded
from the copula simulation in STANS
due to a lack of data.
The sub-sections related to implied
volatility smoothing and options pricing
describe how OCC uses the inputs and
outputs described in the subsections on
model and econometric calibration and
copula construction. Specifically, the
STANS Methodology Description
discusses OCC’s processing for
performing implied volatility smoothing
as well as pricing European-style
options, American-style options, Asian
FLEX options,15 and Cliquet options.16
The document also discusses how
STANS can also be used to price
forward start options.17
The sub-sections related to the
aggregation of various component
14 A copula is a mathematical construct used in
probability theory to calculate the cumulative
distribution of a set of random variables.
15 Asian options are European-style options for
which the settlement price is determined based on
the difference between the aggregate exercise price
and the aggregate current underlying interest value,
which is based on the average of twelve monthly
price observations. See Securities Exchange Release
No. 74966 (May 14, 2015), 80 FR 29784 (May 22,
2015) (File No. SR–OCC–2015–010).
16 Cliquet options are European-style options for
which the settlement price is determined based on
the (positive) sum of capped returns of an index on
pre-determined dates over a specified period of
time. See id., n. 9.
17 Forward start options are options for which the
strike price in dollars is unknown prior to the
determination date of the strike shortly before
expiration. See Notice of Filing, 85 FR at 85796.
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charges discuss a based margin charge,
error compensation charge, liquidation
cost charge, and positive risk reversal
charge. The base margin charge consists
of an ES calculation with the addition
of Extreme Value Theory loss modeling
and a stress test component. The error
compensation charge is designed to
compensate for the estimation error
inherent in ES calculations. The
liquidation cost charge is designed to
cover the costs of selling long positions
at the current bid price and covering
short positions at the current ask price
following the default of a Clearing
Member. The positive risk reversal
charge ensures that total calculated
margin requirement is at least equal to
the estimated liquidation cost, even in
the event a position is liquidated at the
current market price.
Model utilities. The final substantive
section of the STANS Methodology
Description addresses several model
utilities that OCC applies at various
points in the STANS methodology, to
incorporate various market and
operational factors that affect options
pricing and thereby produce model
results which more accurately reflect
current and potential market conditions.
Such utilities include the incorporation
of expected cash dividends on a stock
into options pricing in STANS. The
STANS Methodology Description also
addresses OCC’s processes for obtaining
relevant risk factors for both the most
recent opening price and the most
recent closing price to include a joint
distribution of both overnight and daily
returns on relevant risk factors within
the copula described above. Further, the
STANS Methodology Description
discusses OCC’s process for addressing
option expirations occurring during the
period in which OCC closes out a
defaulted Clearing Member’s portfolio.
Finally, the document describes the
portfolio specific haircut model that
OCC uses to haircut values for
withdrawals or deposits of collateral
made throughout the day.
Additional Details
As noted above, STANS Methodology
Description would not include details
from the Margins Methodology that OCC
believes are extraneous to the purpose
of enabling an informed reader to
understand OCC’s modeling choices and
the interconnectedness of STANS model
components in producing OCC margin
requirements. As described below, and
in greater detail in the Notice of Filing,
the details in the Margins Methodology
that would not be included in the
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STANS Methodology Description fall
thematically into eight categories.18
First, the STANS Methodology
Description would not describe
historical modeling practices and
potential future enhancements that do
not describe how a model currently
functions. For example, the STANS
Methodology Description would not
include background on OCC’s decision
to incorporate implied volatility
modeling into STANS. Similarly, the
STANS Methodology Description would
not summarize historical changes OCC
has made to the manner in which
STANS calculates a total margin charge.
Second, the STANS Methodology
Description would not describe the set
of current products to which each
STANS component applies. For
example, the STANS Methodology
Description would list products eligible
for implied volatility scenarios
modeling in STANS.
Third, the STANS Methodology
Description would not describe OCC’s
model configuration choices. Such
configuration choices include a list of
control parameters of the NewtonRaphson method OCC uses to calculate
implied volatilities for vanilla options.
Similarly, the STANS Methodology
Description would not describe the
parameters that OCC uses to calibrate
liquidation grids when calculating its
liquidation cost charge.
Fourth, the STANS Methodology
Description would not describe model
testing results and supporting rationale.
Such testing results would include
model testing and validation results for
OCC’s implied volatility model.
Similarly, the STANS Methodology
Description would not describe the
mathematical rationale for the
cumulative distribution function,
inverse cumulative distribution
function, and degrees of freedom for the
Student’s t-distribution used by the
GARCH model for implied volatility risk
factors.
Fifth, the STANS Methodology
Description would not describe
standard mathematical and economic
theories and techniques that are wellknown in quantitative finance, readily
found in public sources, and do not
include OCC-specific modifications or
applications. For example, the STANS
Methodology Description would not
describe the standard GlostenJagannathan-Runkle GARCH model and
the use of a Student’s t-distribution.
Similarly, the STANS Methodology
Description would not describe the
Vega-weighted least squares calculation
performed during the first round of
18 See
Notice of Filing, 85 FR at 85790.
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optimization to produce arbitrage-free
options prices for European options.
Sixth, the STANS Methodology
Description would not include
redundant descriptions of a model
component appearing in multiple
chapters. For example, the Executive
Summary of the STANS Methodology
Description would not include details of
the STANS methodology also found in
the main body of the document.
Similarly, the section of the proposed
STANS Methodology Description
discussing conditional and default
simulations would not include
introductory text restating the use of
time series in STANS, which is
described elsewhere in the document.
Seventh, the STANS Methodology
Description would not describe OCC’s
implementation of a model in its
internal technology systems. Such
details include detailed steps for a
linear interpolation/extrapolation used
to construct a volatility surface from
smoothed volatilities. Similarly, the
STANS Methodology Description would
not include discussion of the processes
OCC uses to operationalize the STANS
methodology in its systems.
Finally, the STANS Methodology
Description would not describe manual
margin adjustments and add-ons that
OCC employs pursuant to OCC rules,
policies, or procedures outside of
STANS. Such adjustments include
additional margin charges related to
cross-margin accounts established under
OCC’s Rule 704. Similarly, the STANS
Methodology Description would not
describe ‘‘derived scenarios,’’ which are
a special case of conditional simulations
related to exchange rate risk factors
addressed elsewhere in OCC’s
procedures.
Changes to Margin Policy
OCC also proposes conforming
changes to its Margin Policy to reflect
the adoption of the STANS
Methodology Description and the
retirement of the Margins Methodology.
Additionally, OCC proposes to make
other non-substantive changes to the
Margin Policy to correct typographical
errors, update references to other related
internal OCC policies and procedures,
and conform the policy to OCC’s current
internal policy template.
III. Discussion and Commission’s
Findings
Section 19(b)(2)(C) of the Exchange
Act directs the Commission to approve
a proposed rule change of a selfregulatory organization if it finds that
such proposed rule change is consistent
with the requirements of the Exchange
Act and the rules and regulations
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thereunder applicable to such
organization.19 After carefully
considering the Proposed Rule Change,
the Commission finds that the proposal
is consistent with the requirements of
the Exchange Act and the rules and
regulations thereunder applicable to
OCC. More specifically, the Commission
finds that the proposal is consistent
with Section 17A(b)(3)(F) of the
Exchange Act,20 Rule 17Ad–22(e)(6) 21
thereunder, as described in detail
below.
A. Consistency With Section
17A(b)(3)(F) of the Exchange Act
Section 17A(b)(3)(F) of the Exchange
Act requires, among other things, that
the rules of a clearing agency be
designed to assure the safeguarding of
securities and funds which are in its
custody or control or for which it is
responsible.22 OCC uses STANS to set
risk-based margin requirements for its
Clearing Members. OCC proposes to
describe its modeling choices and the
interconnectedness of STANS model
components in producing such margin
requirements within its rules by
adopting the STANS Methodology
Description. The aspects of STANS
described in the STANS Methodology
Description directly relate to OCC’s
ability to accurately risk manage
Clearing Member portfolios by
calculating and collecting an
appropriate amount of collateral. The
Commission notes that only some of the
aspects of STANS addressed in the
STANS Methodology Description are
currently addressed in the portions of
the Margins Methodology that OCC has
filed with the Commission.
The Commission believes that, even
with the removal of the additional
details from the Margins Methodology
described above, the proposed STANS
Methodology Description is designed to
help ensure that OCC’s margin
methodology calculates and collects
margin sufficient to mitigate OCC’s
credit exposure to a Clearing Member
default. The Commission also believes
that accurate calculation of margin is
necessary to help ensure that OCC is
able to risk manage the default of a
Clearing Member without recourse to
the assets of non-defaulting Clearing
Members, which supports the
safeguarding of securities and funds in
OCC’s custody. Accordingly, the
Commission believes that the
replacement of the Margins
Methodology with the STANS Margin
19 15
U.S.C. 78s(b)(2)(C).
U.S.C. 78q–1(b)(3)(F).
21 17 CFR 240.17Ad–22(e)(6).
22 15 U.S.C. 78q–1(b)(3)(F).
20 15
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Description is consistent with the
requirements of Section 17A(b)(3)(F) of
the Exchange Act.23
B. Consistency With Rule 17Ad–22(e)(6)
Under the Exchange Act
Rules 17Ad–22(e)(6) generally
requires each covered clearing agency
that provides central counterparty
services to establish, implement,
maintain, and enforce written policies
and procedures reasonably designed to
cover its credit exposure to its
participants by establishing a risk-based
margin system that meets certain
standards.24 As described above, the
STANS Methodology Description
addresses OCC’s modeling choices and
the interconnectedness of STANS model
components in producing risk-based
margin requirements.
Section (i) under Rule 17Ad–22(e)(6)
requires that the policies and
procedures required pursuant to Rule
17Ad–22(e)(6) describe a risk-based
margin system that considers and
produces margin levels commensurate
with the risks and particular attributes
of each relevant product, portfolio, and
market.25 As described above, the
STANS Methodology Description covers
various components of STANS designed
to address the particular attributes of the
products that OCC clears (e.g.,
American-style options, European-style
options, Asian FLEX options, Cliquet
options) as well as the risks presented
by a specific portfolio (e.g., liquidation
cost charges). Further, the STANS
Methodology Description also describes
OCC’s process addressing the entrance
of new products into the markets for
which it clears (identifying and
separately processing risk factors with
incomplete data sets that lack sufficient
data to estimate the copula).
Section (iii) under Rule 17Ad–22(e)(6)
requires that the policies and
procedures required pursuant to Rule
17Ad–22(e)(6) describe a risk-based
margin system that calculates margin
sufficient to cover its potential future
exposure to participants in the interval
between the last margin collection and
the close out of positions following a
participant default.26 As described
above, the STANS Methodology
Description discusses various model
utilities that pertain to events occurring
between the collection of margin and
closing out of a defaulted Clearing
Member’s portfolio (e.g., cash dividend
payments, option expiration, and
changes to portfolio specific haircuts
23 15
U.S.C. 78q–1(b)(3)(F).
CFR 240.17Ad–22(e)(6).
25 17 CFR 240.17Ad–22(e)(6)(i).
26 17 CFR 240.17Ad–22(e)(6)(iii).
24 17
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due to the withdrawal or deposit of
collateral).
Section (v) under Rule 17Ad–22(e)(6)
requires that the policies and
procedures required pursuant to Rule
17Ad–22(e)(6) describe a risk-based
margin system that uses an appropriate
method for measuring credit exposure to
accounts for relevant product risk
factors and portfolio effects across
products.27 As discussed above, the
STANS Methodology Description covers
the various STANS components that
provide the inputs and outputs
necessary for OCC to conduct implied
volatility smoothing and options pricing
(e.g., model components addressing
derivatives based on equities and
treasuries as well as generic futures,
variance futures, and volatility indexbased futures) as well as the implied
volatility smoothing and options pricing
themselves.
Based on the foregoing, the
Commission believes that the
replacement of the Margins
Methodology with the STANS Margin
Description is consistent with the
requirements of Rule 17Ad–22(e)(6)
under the Exchange Act.28
IV. Conclusion
On the basis of the foregoing, the
Commission finds that the Proposed
Rule Change is consistent with the
requirements of the Exchange Act, and
in particular, the requirements of
Section 17A of the Exchange Act 29 and
the rules and regulations thereunder.
It is therefore ordered, pursuant to
Section 19(b)(2) of the Exchange Act,30
that the Proposed Rule Change (SR–
OCC–2020–016) be, and hereby is,
approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.31
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2021–02859 Filed 2–11–21; 8:45 am]
BILLING CODE 8011–01–P
27 17
CFR 240.17Ad–22(e)(6)(v).
CFR 240.17Ad–22(e)(6).
29 In approving this Proposed Rule Change, the
Commission has considered the proposed rules’
impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
30 15 U.S.C. 78s(b)(2).
31 17 CFR 200.30–3(a)(12).
28 17
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9413
SECURITIES AND EXCHANGE
COMMISSION
[SEC File No. 270–125, OMB Control No.
3235–0104]
Proposed Collection; Comment
Request
Upon Written Request Copies Available
From: Securities and Exchange
Commission, Office of FOIA Services,
100 F Street NE, Washington, DC
20549–2736
Extension:
Form 3
Notice is hereby given that pursuant,
to the Paperwork Reduction Act of 1995
(44 U.S.C. 3501 et seq.), the Securities
and Exchange Commission
(‘‘Commission’’) is soliciting comments
on the collections of information
summarized below. The Commission
plans to submit this existing collection
of information to the Office of
Management and Budget for extension
and approval.
Exchange Act Forms 3 is filed by
insiders of public companies that have
a class of securities registered under
Section 12 of the Exchange Act. Form 3
is an initial statement beneficial
ownership of securities. Approximately
21,968 insiders file Form 3 annually and
it takes approximately 0.50 hours to
prepare for a total of 10,984 annual
burden hours (0.50 hours per response
× 21,968 responses).
Written comments are invited on: (a)
Whether this proposed collection of
information is necessary for the proper
performance of the functions of the
agency, including whether the
information will have practical utility;
(b) the accuracy of the agency’s estimate
of the burden imposed by the collection
of information; (c) ways to enhance the
quality, utility, and clarity of the
information collected; and (d) ways to
minimize the burden of the collection of
information on respondents, including
through the use of automated collection
techniques or other forms of information
technology. Consideration will be given
to comments and suggestions submitted
in writing within 60 days of this
publication.
An agency may not conduct or
sponsor, and a person is not required to
respond to, a collection of information
unless it displays a currently valid
control number.
Please direct your written comment to
David Bottom, Director/Chief
Information Officer, Securities and
Exchange Commission, c/o Cynthia
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E:\FR\FM\12FEN1.SGM
12FEN1
Agencies
[Federal Register Volume 86, Number 28 (Friday, February 12, 2021)]
[Notices]
[Pages 9410-9413]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2021-02859]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-91079; File No. SR-OCC-2020-016]
Self-Regulatory Organizations; The Options Clearing Corporation;
Order Approving Proposed Rule Change to Concerning the Options Clearing
Corporation's System for Theoretical Analysis and Numerical Simulation
(``STANS'') Methodology Documentation
February 8, 2021.
I. Introduction
On December 9, 2020, the Options Clearing Corporation (``OCC'')
filed with the Securities and Exchange Commission (``Commission'') the
proposed rule change SR-OCC-2020-016 (``Proposed Rule Change'')
pursuant to Section 19(b) of the Securities Exchange Act of 1934
(``Exchange Act'') \1\ and Rule 19b-4 \2\ thereunder to adopt a new
document describing OCC's system for calculating daily and intra-day
margin requirements for its Clearing Members.\3\ The Proposed Rule
Change was published for public comment in the Federal Register on
December 29, 2020.\4\ The Commission has received no comments regarding
the Proposed Rule Change. This order approves the Proposed Rule Change.
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Notice of Filing infra note 4, 85 FR at 85788.
\4\ Securities Exchange Act Release No. 34-90763 (Dec. 21,
2020), 85 FR 85788 (Dec. 29, 2020) (File No. SR-OCC-2020-016)
(``Notice of Filing'').
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II. Background
To manage the credit risk posed by its Clearing Members, OCC
collects margin collateral both daily and intraday. OCC uses its System
for Theoretical Analysis and Numerical Simulation (``STANS'') to set
risk-based margin requirements for its Clearing Members. The margin
requirements calculated using STANS consist of an estimate of a 99
percent expected shortfall (``ES'') over a two-day time horizon with
additional charges for model risk, stress tests, liquidation costs, and
various add-ons.
OCC maintains technical documentation that describes how the
various quantitative components of STANS were developed and operate,
including the various parameters and assumptions contained within those
components \5\ and the mathematical theories underlying the selection
of those quantitative methods (``Model Whitepapers''). The Model
Whitepapers are currently synthesized in a single document, the Margins
Methodology, describing how STANS operates from end to end. Pursuant to
section 19(b) of the Exchange Act and Rule 19b-4 thereunder,\6\ OCC has
filed, and the Commission has approved, sections of OCC's Margins
Methodology as rules in the past.\7\ OCC has not, however, filed the
Margins Methodology in its entirety. Additionally, OCC has requested
confidential treatment for those sections of the Margins Methodology
that it has filed with the Commission.\8\
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\5\ See Securities Exchange Act Release No. 82473 (Jan. 9,
2018), 83 FR 2271 (Jan. 16, 2018) (File No. SR-OCC-2017-011), which
describes how OCC periodically reviews the parameters and
assumptions used by STANS pursuant to its Model Risk Management
Policy and in accordance with 17 CFR 240.17Ad-22(e)(6).
\6\ 15 U.S.C. 78s(b)(1) and 17 CFR 240.19b-4.
\7\ See Securities Exchange Act Release No. 74966 (May 14,
2015), 80 FR 29784 (May 22, 2015) (File No. SR-OCC-2015-010);
Securities Exchange Act Release No. 76128 (Dec. 28, 2015), 81 FR 135
(Jan. 4, 2016) (File No. SR-OCC-2015-016); Securities Exchange Act
Release No. 79818 (Jan. 18, 2017), 82 FR 8455 (Jan. 25, 2017) (File
No. SR-OCC-2017-001); Securities Exchange Act Release No. 82161
(Nov. 28, 2017), 82 FR 57306 (Dec. 4, 2017) (File No. SR-OCC-2017-
022); Securities Exchange Act Release No. 84524 (Nov. 2, 2018), 83
FR 55918 (Nov. 8, 2018) (File No. SR-OCC-2018-014); Securities
Exchange Act Release No. 85440 (Mar. 28, 2019), 84 FR 13082 (Apr. 3,
2019) (File No. SR-OCC-2019-002); Securities Exchange Act Release
No. 85755 (Apr. 30, 2019), 87 FR 19815 (May 6, 2019) (File No. SR-
OCC-2019-004); Securities Exchange Act Release No. 86296 (Jul. 3,
2019), 84 FR 32816 (Jul. 9, 2019) (File No. SR-OCC-2019-005);
Securities Exchange Act Release No. 87387 (Oct. 23, 2019), 84 FR
57890 (Oct. 29, 2019) (File No. SR-OCC-2019-010); Securities
Exchange Act Release No. 89392 (Jul. 24, 2020), 85 FR 45938 (Jul.
30,2020) (File No. SR-OCC-2020-007); Securities Exchange Act Release
No. 90139 (Oct. 8, 2020), 85 FR 65886 (Oct. 16, 2020) (File No. SR-
OCC-2020-012).
\8\ See id.
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OCC now proposes to replace the Margins Methodology in its entirety
(both sections that have and have not been filed as rules) with a
description of OCC's system for calculating daily and intra-day margin
requirements for its Clearing Members (the ``STANS Methodology
Description'').\9\ OCC stated that the proposed STANS Methodology
Description includes the material aspects of OCC's risk-based margin
system.\10\ OCC intends to make the proposed STANS Methodology
[[Page 9411]]
Description available to Clearing Members.\11\
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\9\ OCC also proposes conforming changes to its Margin Policy.
\10\ See Notice of Filing, 85 FR at 85789.
\11\ See Notice of Filing, 85 FR at 85790.
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The proposed STANS Methodology Description would include
substantially the same information as the Margins Methodology with the
exception of various details, described below, that OCC does not
believe would be appropriately included in the STANS Methodology
Description.\12\ OCC stated that the purpose of the STANS Methodology
Description would be to enable an informed reader to understand OCC's
modeling choices and the interconnectedness of STANS model components
in producing OCC margin requirements, and that the portions of the
Margins Methodology not carried forward in the STANS Methodology
Description are extraneous to this purpose.\13\
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\12\ OCC does not propose to change its margin methodology as
part of the Proposed Rule Change.
\13\ See Notice of Filing, 85 FR at 85790.
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Proposed STANS Methodology Description
As noted above, the proposed STANS Methodology Description covers
OCC's system for calculating daily and intra-day margin requirements
for its Clearing Members. The proposed document includes three sections
with various subsections as described below and in greater detail in
the Notice of Filing. The STANS Methodology Description begins with an
executive summary. The executive summary would state that the purpose
of STANS is to determine margin requirements for OCC's Clearing
Members, and would describe the types of positions and collateral
modeled through STANS. The executive summary would also briefly
describe OCC's procedures related to both model monitoring and price
editing.
Model components. The bulk of the STANS Methodology Description
covers the model components in STANS, including model and econometric
calibration, copula construction, implied volatility smoothing and
options pricing, and the application of the theoretical derivatives
prices to actual positions in Clearing Members' accounts to calculate
margin requirements through the aggregation of various component
charges. The sub-sections related to model and econometric calibration
cover the use of (i) returns on equity securities that are based on
current market prices to create econometric parameters and for pricing;
(ii) implied volatility risk factors to measure the expected future
volatility of an option's underlying security at expiration; (iii)
Nelson-Siegel framework to price treasury securities; (iv) a generic
futures model to price linear derivatives with limited term structures;
(v) a specialized factor model to price variance futures; (vi) a
synthetic futures model to price specified products such as volatility
index-based futures (e.g., VIX futures); and (vii) econometric
parameters related to volatility forecasts and marginal distributions,
and calibrates these parameters using ten-year histories of the
foregoing data inputs.
The sub-sections related to copula construction describes the use
of a copula to quantify the joint behavior and dependence structure of
the risk factors used by STANS.\14\ The STANS Methodology Description
covers OCC's process for estimating the copula as well as simulating
price movements based on random draws from the multivariate Student's
t-distribution described by the copula. The document also describes
OCC's process for identifying and separately processing risk factors
with incomplete data sets that lack sufficient data to estimate the
copula. Specifically, the STANS Methodology Description addresses the
application of conditional and default simulations to estimate
correlations for risk factors excluded from the copula simulation in
STANS due to a lack of data.
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\14\ A copula is a mathematical construct used in probability
theory to calculate the cumulative distribution of a set of random
variables.
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The sub-sections related to implied volatility smoothing and
options pricing describe how OCC uses the inputs and outputs described
in the subsections on model and econometric calibration and copula
construction. Specifically, the STANS Methodology Description discusses
OCC's processing for performing implied volatility smoothing as well as
pricing European-style options, American-style options, Asian FLEX
options,\15\ and Cliquet options.\16\ The document also discusses how
STANS can also be used to price forward start options.\17\
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\15\ Asian options are European-style options for which the
settlement price is determined based on the difference between the
aggregate exercise price and the aggregate current underlying
interest value, which is based on the average of twelve monthly
price observations. See Securities Exchange Release No. 74966 (May
14, 2015), 80 FR 29784 (May 22, 2015) (File No. SR-OCC-2015-010).
\16\ Cliquet options are European-style options for which the
settlement price is determined based on the (positive) sum of capped
returns of an index on pre-determined dates over a specified period
of time. See id., n. 9.
\17\ Forward start options are options for which the strike
price in dollars is unknown prior to the determination date of the
strike shortly before expiration. See Notice of Filing, 85 FR at
85796.
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The sub-sections related to the aggregation of various component
charges discuss a based margin charge, error compensation charge,
liquidation cost charge, and positive risk reversal charge. The base
margin charge consists of an ES calculation with the addition of
Extreme Value Theory loss modeling and a stress test component. The
error compensation charge is designed to compensate for the estimation
error inherent in ES calculations. The liquidation cost charge is
designed to cover the costs of selling long positions at the current
bid price and covering short positions at the current ask price
following the default of a Clearing Member. The positive risk reversal
charge ensures that total calculated margin requirement is at least
equal to the estimated liquidation cost, even in the event a position
is liquidated at the current market price.
Model utilities. The final substantive section of the STANS
Methodology Description addresses several model utilities that OCC
applies at various points in the STANS methodology, to incorporate
various market and operational factors that affect options pricing and
thereby produce model results which more accurately reflect current and
potential market conditions. Such utilities include the incorporation
of expected cash dividends on a stock into options pricing in STANS.
The STANS Methodology Description also addresses OCC's processes for
obtaining relevant risk factors for both the most recent opening price
and the most recent closing price to include a joint distribution of
both overnight and daily returns on relevant risk factors within the
copula described above. Further, the STANS Methodology Description
discusses OCC's process for addressing option expirations occurring
during the period in which OCC closes out a defaulted Clearing Member's
portfolio. Finally, the document describes the portfolio specific
haircut model that OCC uses to haircut values for withdrawals or
deposits of collateral made throughout the day.
Additional Details
As noted above, STANS Methodology Description would not include
details from the Margins Methodology that OCC believes are extraneous
to the purpose of enabling an informed reader to understand OCC's
modeling choices and the interconnectedness of STANS model components
in producing OCC margin requirements. As described below, and in
greater detail in the Notice of Filing, the details in the Margins
Methodology that would not be included in the
[[Page 9412]]
STANS Methodology Description fall thematically into eight
categories.\18\
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\18\ See Notice of Filing, 85 FR at 85790.
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First, the STANS Methodology Description would not describe
historical modeling practices and potential future enhancements that do
not describe how a model currently functions. For example, the STANS
Methodology Description would not include background on OCC's decision
to incorporate implied volatility modeling into STANS. Similarly, the
STANS Methodology Description would not summarize historical changes
OCC has made to the manner in which STANS calculates a total margin
charge.
Second, the STANS Methodology Description would not describe the
set of current products to which each STANS component applies. For
example, the STANS Methodology Description would list products eligible
for implied volatility scenarios modeling in STANS.
Third, the STANS Methodology Description would not describe OCC's
model configuration choices. Such configuration choices include a list
of control parameters of the Newton-Raphson method OCC uses to
calculate implied volatilities for vanilla options. Similarly, the
STANS Methodology Description would not describe the parameters that
OCC uses to calibrate liquidation grids when calculating its
liquidation cost charge.
Fourth, the STANS Methodology Description would not describe model
testing results and supporting rationale. Such testing results would
include model testing and validation results for OCC's implied
volatility model. Similarly, the STANS Methodology Description would
not describe the mathematical rationale for the cumulative distribution
function, inverse cumulative distribution function, and degrees of
freedom for the Student's t-distribution used by the GARCH model for
implied volatility risk factors.
Fifth, the STANS Methodology Description would not describe
standard mathematical and economic theories and techniques that are
well-known in quantitative finance, readily found in public sources,
and do not include OCC-specific modifications or applications. For
example, the STANS Methodology Description would not describe the
standard Glosten-Jagannathan-Runkle GARCH model and the use of a
Student's t-distribution. Similarly, the STANS Methodology Description
would not describe the Vega-weighted least squares calculation
performed during the first round of optimization to produce arbitrage-
free options prices for European options.
Sixth, the STANS Methodology Description would not include
redundant descriptions of a model component appearing in multiple
chapters. For example, the Executive Summary of the STANS Methodology
Description would not include details of the STANS methodology also
found in the main body of the document. Similarly, the section of the
proposed STANS Methodology Description discussing conditional and
default simulations would not include introductory text restating the
use of time series in STANS, which is described elsewhere in the
document.
Seventh, the STANS Methodology Description would not describe OCC's
implementation of a model in its internal technology systems. Such
details include detailed steps for a linear interpolation/extrapolation
used to construct a volatility surface from smoothed volatilities.
Similarly, the STANS Methodology Description would not include
discussion of the processes OCC uses to operationalize the STANS
methodology in its systems.
Finally, the STANS Methodology Description would not describe
manual margin adjustments and add-ons that OCC employs pursuant to OCC
rules, policies, or procedures outside of STANS. Such adjustments
include additional margin charges related to cross-margin accounts
established under OCC's Rule 704. Similarly, the STANS Methodology
Description would not describe ``derived scenarios,'' which are a
special case of conditional simulations related to exchange rate risk
factors addressed elsewhere in OCC's procedures.
Changes to Margin Policy
OCC also proposes conforming changes to its Margin Policy to
reflect the adoption of the STANS Methodology Description and the
retirement of the Margins Methodology. Additionally, OCC proposes to
make other non-substantive changes to the Margin Policy to correct
typographical errors, update references to other related internal OCC
policies and procedures, and conform the policy to OCC's current
internal policy template.
III. Discussion and Commission's Findings
Section 19(b)(2)(C) of the Exchange Act directs the Commission to
approve a proposed rule change of a self-regulatory organization if it
finds that such proposed rule change is consistent with the
requirements of the Exchange Act and the rules and regulations
thereunder applicable to such organization.\19\ After carefully
considering the Proposed Rule Change, the Commission finds that the
proposal is consistent with the requirements of the Exchange Act and
the rules and regulations thereunder applicable to OCC. More
specifically, the Commission finds that the proposal is consistent with
Section 17A(b)(3)(F) of the Exchange Act,\20\ Rule 17Ad-22(e)(6) \21\
thereunder, as described in detail below.
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\19\ 15 U.S.C. 78s(b)(2)(C).
\20\ 15 U.S.C. 78q-1(b)(3)(F).
\21\ 17 CFR 240.17Ad-22(e)(6).
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A. Consistency With Section 17A(b)(3)(F) of the Exchange Act
Section 17A(b)(3)(F) of the Exchange Act requires, among other
things, that the rules of a clearing agency be designed to assure the
safeguarding of securities and funds which are in its custody or
control or for which it is responsible.\22\ OCC uses STANS to set risk-
based margin requirements for its Clearing Members. OCC proposes to
describe its modeling choices and the interconnectedness of STANS model
components in producing such margin requirements within its rules by
adopting the STANS Methodology Description. The aspects of STANS
described in the STANS Methodology Description directly relate to OCC's
ability to accurately risk manage Clearing Member portfolios by
calculating and collecting an appropriate amount of collateral. The
Commission notes that only some of the aspects of STANS addressed in
the STANS Methodology Description are currently addressed in the
portions of the Margins Methodology that OCC has filed with the
Commission.
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\22\ 15 U.S.C. 78q-1(b)(3)(F).
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The Commission believes that, even with the removal of the
additional details from the Margins Methodology described above, the
proposed STANS Methodology Description is designed to help ensure that
OCC's margin methodology calculates and collects margin sufficient to
mitigate OCC's credit exposure to a Clearing Member default. The
Commission also believes that accurate calculation of margin is
necessary to help ensure that OCC is able to risk manage the default of
a Clearing Member without recourse to the assets of non-defaulting
Clearing Members, which supports the safeguarding of securities and
funds in OCC's custody. Accordingly, the Commission believes that the
replacement of the Margins Methodology with the STANS Margin
[[Page 9413]]
Description is consistent with the requirements of Section 17A(b)(3)(F)
of the Exchange Act.\23\
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\23\ 15 U.S.C. 78q-1(b)(3)(F).
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B. Consistency With Rule 17Ad-22(e)(6) Under the Exchange Act
Rules 17Ad-22(e)(6) generally requires each covered clearing agency
that provides central counterparty services to establish, implement,
maintain, and enforce written policies and procedures reasonably
designed to cover its credit exposure to its participants by
establishing a risk-based margin system that meets certain
standards.\24\ As described above, the STANS Methodology Description
addresses OCC's modeling choices and the interconnectedness of STANS
model components in producing risk-based margin requirements.
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\24\ 17 CFR 240.17Ad-22(e)(6).
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Section (i) under Rule 17Ad-22(e)(6) requires that the policies and
procedures required pursuant to Rule 17Ad-22(e)(6) describe a risk-
based margin system that considers and produces margin levels
commensurate with the risks and particular attributes of each relevant
product, portfolio, and market.\25\ As described above, the STANS
Methodology Description covers various components of STANS designed to
address the particular attributes of the products that OCC clears
(e.g., American-style options, European-style options, Asian FLEX
options, Cliquet options) as well as the risks presented by a specific
portfolio (e.g., liquidation cost charges). Further, the STANS
Methodology Description also describes OCC's process addressing the
entrance of new products into the markets for which it clears
(identifying and separately processing risk factors with incomplete
data sets that lack sufficient data to estimate the copula).
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\25\ 17 CFR 240.17Ad-22(e)(6)(i).
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Section (iii) under Rule 17Ad-22(e)(6) requires that the policies
and procedures required pursuant to Rule 17Ad-22(e)(6) describe a risk-
based margin system that calculates margin sufficient to cover its
potential future exposure to participants in the interval between the
last margin collection and the close out of positions following a
participant default.\26\ As described above, the STANS Methodology
Description discusses various model utilities that pertain to events
occurring between the collection of margin and closing out of a
defaulted Clearing Member's portfolio (e.g., cash dividend payments,
option expiration, and changes to portfolio specific haircuts due to
the withdrawal or deposit of collateral).
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\26\ 17 CFR 240.17Ad-22(e)(6)(iii).
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Section (v) under Rule 17Ad-22(e)(6) requires that the policies and
procedures required pursuant to Rule 17Ad-22(e)(6) describe a risk-
based margin system that uses an appropriate method for measuring
credit exposure to accounts for relevant product risk factors and
portfolio effects across products.\27\ As discussed above, the STANS
Methodology Description covers the various STANS components that
provide the inputs and outputs necessary for OCC to conduct implied
volatility smoothing and options pricing (e.g., model components
addressing derivatives based on equities and treasuries as well as
generic futures, variance futures, and volatility index-based futures)
as well as the implied volatility smoothing and options pricing
themselves.
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\27\ 17 CFR 240.17Ad-22(e)(6)(v).
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Based on the foregoing, the Commission believes that the
replacement of the Margins Methodology with the STANS Margin
Description is consistent with the requirements of Rule 17Ad-22(e)(6)
under the Exchange Act.\28\
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\28\ 17 CFR 240.17Ad-22(e)(6).
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IV. Conclusion
On the basis of the foregoing, the Commission finds that the
Proposed Rule Change is consistent with the requirements of the
Exchange Act, and in particular, the requirements of Section 17A of the
Exchange Act \29\ and the rules and regulations thereunder.
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\29\ In approving this Proposed Rule Change, the Commission has
considered the proposed rules' impact on efficiency, competition,
and capital formation. See 15 U.S.C. 78c(f).
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It is therefore ordered, pursuant to Section 19(b)(2) of the
Exchange Act,\30\ that the Proposed Rule Change (SR-OCC-2020-016) be,
and hereby is, approved.
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\30\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\31\
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\31\ 17 CFR 200.30-3(a)(12).
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J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2021-02859 Filed 2-11-21; 8:45 am]
BILLING CODE 8011-01-P