Self-Regulatory Organizations; Fixed Income Clearing Corporation; Order Approving Proposed Rule Change To Revise the Formula Used To Calculate the VaR Charge for Repo Interest Volatility, 53522-53526 [2022-18768]
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Federal Register / Vol. 87, No. 168 / Wednesday, August 31, 2022 / Notices
comment submissions. You should
submit only information that you wish
to make available publicly. All
submissions should refer to File
Number SR–CboeBZX–2022–045 and
should be submitted on or before
September 21, 2022.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.49
J. Matthew DeLesDernier,
Deputy Secretary.
[FR Doc. 2022–18764 Filed 8–30–22; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–95605; File No. SR–FICC–
2022–005]
Self-Regulatory Organizations; Fixed
Income Clearing Corporation; Order
Approving Proposed Rule Change To
Revise the Formula Used To Calculate
the VaR Charge for Repo Interest
Volatility
August 25, 2022.
I. Introduction
On June 29, 2022, Fixed Income
Clearing Corporation (‘‘FICC’’) filed
with the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder,2 proposed rule
change SR–FICC–2022–005. The
proposed rule change was published for
comment in the Federal Register on July
15, 2022.3 The Commission did not
receive any comment letters on the
proposed rule change. For the reasons
discussed below, the Commission is
approving the proposed rule change.
II. Description of the Proposed Rule
Change
FICC proposes to amend its
Government Securities Division
(‘‘GSD’’) 4 Quantitative Risk
Management (‘‘QRM’’) Methodology
Document—GSD Initial Market Risk
17 CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 Securities Exchange Act Release No. 95256 (July
12, 2022), 87 FR 42524 (July 15, 2022) (SR–FICC–
2022–005) (‘‘Notice’’).
4 FICC operates two divisions, GSD and the
Mortgage Backed Securities Division (‘‘MBSD’’).
GSD provides trade comparison, netting, risk
management, settlement, and central counterparty
(‘‘CCP’’) services for the U.S. Government securities
market, including repos. MBSD provides the same
services for the U.S. mortgage-backed securities
market. GSD and MBSD maintain separate sets of
rules, margin models, and clearing funds. The
proposed rule change relates solely to GSD.
49
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Margin Model (‘‘QRM Methodology
Document’’) 5 in order to (i) revise the
formula FICC uses to calculate the Value
at Risk charge (‘‘VaR Charge’’) 6 margin
component for repurchase agreement
(‘‘repo’’) interest volatility, and (ii) make
certain technical and conforming
changes.
A. Background
Repos involve a pair of transactions
between two parties. The first
transaction consists of the sale of
securities, in which one party (the ‘‘cash
borrower’’) delivers securities in
exchange for the other party’s (the ‘‘cash
lender’’) delivery of cash. The second
transaction occurs on a date after that of
the first transaction and consists of a
repurchase of the securities, in which
the obligations to deliver cash and
securities are reversed. FICC’s members
submit repos to FICC for matching,
comparison, risk management, and
ultimately, net settlement. FICC
guarantees that the cash borrower
receives its repo collateral back at the
close of a repo transaction, while the
cash lender receives the amount paid at
the repo’s start, plus interest. Interest on
a repo transaction is the difference
between the repurchase settlement
amount and the start amount paid on
the repo inception date.
A key tool that FICC uses to manage
its credit exposures to its members is
the daily collection of margin from each
member. The aggregated amount of all
members’ margin constitutes the
Clearing Fund,7 which FICC would be
able to access should a defaulted
member’s own margin be insufficient to
satisfy losses to FICC caused by the
liquidation of that member’s portfolio.
Each member’s margin consists of a
number of applicable components,
including the VaR Charge which is
designed to capture the potential market
price risk associated with the securities
in a member’s portfolio.8 The VaR
Charge is typically the largest
component of a member’s margin
requirement. FICC designed the VaR
5 FICC filed an excerpt of the QRM Methodology
Document showing the proposed changes as a
confidential exhibit to this proposed rule change,
pursuant to 17 CFR 240.24–b2. FICC originally filed
the QRM Methodology Document confidentially as
part of a previous proposed rule change and
advance notice approved by the Commission
regarding FICC’s GSD sensitivity VaR. See
Securities Exchange Act Release Nos. 83362 (June
1, 2018), 83 FR 26514 (June 7, 2018) (SR–FICC–
2018–001) and 83223 (May 11, 2018), 83 FR 23020
(May 17, 2018) (SR–FICC–2018–801).
6 Capitalized terms not defined herein are defined
in FICC’s GSD Rulebook, available at https://
www.dtcc.com/∼/media/Files/Downloads/legal/
rules/ficc_gov_rules.pdf (‘‘Rules’’).
7 See Rule 4 of the Rules, supra note 6.
8 See Rule 1 of the Rules, supra note 6.
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Charge to cover FICC’s projected
liquidation losses with respect to a
defaulted member’s portfolio at a 99
percent confidence level.
The VaR Charge includes, among
other things, a component that
addresses repo interest volatility (the
‘‘repo interest volatility charge’’).9 The
QRM Methodology Document describes
FICC’s formula for calculating the repo
interest volatility charge. The market
value of interest payments for the
duration of a repo transaction are
subject to the risk of movements of the
market repo interest rates. Since FICC
guarantees the repo interest payment to
the cash lenders, FICC must mitigate the
risk arising out of fluctuations in market
repo interest rates for a specified period
of time after a member default.10
Under the current formula, the repo
interest positions for a given member
portfolio are put into different risk
buckets based on (i) whether the
underlying repo trade is a generic repo
trade or a special repo trade,11 and (ii)
the time to settlement of the underlying
repo trade. FICC assesses the repo
interest volatility charge by applying a
haircut schedule to the different risk
buckets, with a single haircut rate
applied to each risk bucket after netting
the short and long repo interest
positions within the relevant bucket.
The total net amount of each risk bucket
equals the sum of the products of the
repo start amount and the time to
settlement of each repo interest position
in that risk bucket. If the total net
amount is positive (i.e., long), FICC
applies a long repo haircut rate to the
total net amount for that risk bucket to
calculate the repo interest volatility
charge for that risk bucket. If the total
net amount is negative (i.e., short), FICC
applies a short repo haircut rate to the
absolute value of the total net amount
for that risk bucket to calculate the repo
interest volatility charge for that risk
bucket. The total repo interest volatility
charge for a member’s portfolio is the
sum of the repo interest volatility
charges of all of the risk buckets in the
portfolio. Accordingly, the current
formula reflects a repo interest rate
9 Currently, the repo interest volatility constitutes
approximately 3 percent of the total GSD margin (at
the CCP level). See Notice, supra note 3, at 42524.
10 This time period is currently set at three days,
which represents the duration of time that FICC
would be subject to market risk after a member
default, starting from the time of the last successful
margin collection to the time the market risk
exposure is effectively mitigated. See Notice, supra
note 3, at 42524.
11 FICC designates repo trades as either generic or
special depending on how the repo rate of the
trade’s particular collateral compares to the
prevailing market rates of similar repo transactions.
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index 12 driven approach where a single
repo haircut rate is applied to the
absolute value of the total net amount of
each risk bucket of repo interest
positions.13 The QRM Methodology
Document, which was filed
confidentially, contains a detailed
description of the repo haircut rate
calculation for all risk buckets.
Based on FICC’s 2020 and 2021
annual model validation reports,14 the
rolling 12-month backtesting coverage
on members’ repo interest positions
were below the 99 percent coverage
target from June 2019 to September
2020. Additionally, FICC conducted an
impact study for the period of January
2018 to February 2022 (‘‘Impact
Study’’),15 which demonstrated a
backtesting coverage ratio of 98.7
percent for the repo interest volatility
charge during that time period. To
address these deficiencies, FICC
proposes to change the formula for
calculating the repo interest volatility
charge to improve backtesting coverage
and provide FICC with greater flexibility
than the current formula to calculate the
repo interest volatility charge in a
manner that is more responsive to
rapidly changing market conditions.
B. Proposed Rule Change
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1. New Formula for Calculating Repo
Interest Volatility Charge
The proposed formula is similar to the
current formula in certain respects. For
example, the proposed formula would
continue to rely upon repo interest rate
indices and would use a similar
mathematical calculation as the current
formula. In addition, under the
proposed formula, the repo interest
positions for a given member portfolio
would continue to be placed into risk
buckets based on the same criteria used
currently, that is, (i) whether the
underlying repo trade is a generic repo
trade or a special repo trade, and (ii) the
time to settlement of the underlying
repo trade. Finally, the total repo
interest volatility charge for the
portfolio would continue to be the sum
12 FICC has developed its repo interest rate
indices using its delivery-versus-payment repo
transactions. See Notice, supra note 3, at 42525.
13 For a detailed example of the current repo
interest volatility charge calculation, please refer to
the Notice, supra note 3, at 42525.
14 Pursuant to 17 CFR 240.24-b2, FICC filed
excerpts of (1) the GSD Initial Market Risk Margin
Models: Model Validation Report, July 2021, and (2)
the Depository Trust and Clearing Corporation
(‘‘DTCC’’) Model Validation Report/GSD Initial
Market Risk Margin Models, July 2020, in a
confidential Exhibit 3 to this proposed rule change.
15 Pursuant to 17 CFR 240.24-b2, FICC filed a
summary of the Impact Study in a confidential
Exhibit 3 to this proposed rule change. The Impact
Study
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of the repo interest volatility charges of
all of the risk buckets in the portfolio.
However, unlike the current formula,
the proposed formula provides FICC
with the flexibility to apply more than
one repo haircut rate to each risk bucket
because FICC would no longer apply the
repo haircut rate based on whether the
total net amount for a specific risk
bucket is long or short. Instead, FICC
proposes to apply a specific repo haircut
rate based on whether the individual
repo interest position in a given risk
bucket is either long or short. That is,
FICC would apply a long repo haircut
rate to all long positions and a short
repo haircut rate to all short positions,
in each risk bucket. The long positions
and the short positions could offset each
other within the same risk bucket, but
could not offset each other across
different risk buckets. The repo interest
volatility charge for a specific risk
bucket would be the absolute value 16 of
the sum of the products of repo start
amount, time to settlement, and repo
haircut rate of the individual repo
interest positions in the risk bucket.
Thus, by allowing FICC to use two
haircuts for each risk bucket, one for
long positions and the other for short
positions,17 the proposal would enable
FICC to respond to rapidly changing
market conditions more quickly and
timely.18
2. Add Bid-Ask Spread To Repo Haircut
Rates
FICC also proposes to add a repo bid/
ask spread to each repo haircut rate (one
for long positions and one for short
positions) within the same risk bucket.
FICC would calculate the repo bid/ask
spread based on the historical percentile
movements of FICC’s internally
constructed repo interest rate indices.
FICC states that this change would
account for the difference observed in
the repo market between the highest rate
a repo participant is willing to pay to
borrow money in a repo trade and the
lowest rate a repo participant is willing
to accept to lend money in a repo trade.
FICC believes that adding the repo bid/
ask spread to each of the repo haircut
rates would improve backtesting
coverage, particularly with respect to
16 The repo interest volatility charge would
always be a positive number because the
calculation is based on the absolute value of the
sum of the relevant amounts.
17 As an initial matter, FICC would set the repo
haircut rates for long positions and short positions
to be the same rate, i.e., the larger of the two rates,
so that the long and short positions in a specific risk
bucket would be subject to the same repo haircut
rate.
18 See Notice, supra note 3, at 42525.
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53523
sub-portfolios of repo interest only
positions.19
Based on the Impact Study, had the
proposed new formula and repo bid-ask
spread been in place during the period
of January 2018 to February 2022, the
CCP-level backtesting coverage ratio for
the repo interest volatility charge would
have increased from approximately 98.7
percent to 99.2 percent.20
3. Remove Description of Repo Haircut
Rate Calculations
As stated above, the QRM
Methodology Document currently
contains a detailed description of the
repo haircut rate calculation for all risk
buckets. FICC proposes to eliminate this
detailed description from the QRM
Methodology Document and replace it
with a more general description of the
repo haircut rate calculation. FICC
proposes to describe the detailed
calculations of the repo haircut rates in
an internal standalone document.
FICC believes a more general
description of the repo haircut rate
calculation would be sufficient for the
QRM Methodology Document, and
would provide FICC with greater
flexibility to respond to rapidly
changing market conditions more
quickly and timely by enabling FICC to
adjust the calculation.21 Nonetheless,
FICC acknowledges that any future
changes to the repo haircut rate
calculations would continue to follow
DTCC’s internal model governance
procedure as described in the Clearing
Agency Model Risk Management
Framework.22 Moreover, pursuant to
Section 806(e)(1) of Title VIII of the
Dodd-Frank Wall Street Reform and
19 Id.
20 See
Notice, supra note 3, at 42526.
Notice, supra note 3, at 42526. Specifically,
FICC states that the more general description would
allow it to adjust the calculation without needing
to submit a proposed rule change pursuant to Rule
19b–4, 17 CFR 240.19b–4. Id.
22 Id. The Clearing Agency Model Risk
Management Framework (‘‘Framework’’) sets forth
the model risk management practices that FICC and
its affiliates, The Depository Trust Company and
National Securities Clearing Corporation, follows to
identify, measure, monitor, and manage the risks
associated with the design, development,
implementation, use, and validation of quantitative
models. See Securities Exchange Act Release Nos.
81485 (August 25, 2017), 82 FR 41433 (August 31,
2017) (File Nos. SR–DTC–2017–008; SR–FICC–
2017–014; SR–NSCC–2017–008), 88911 (May 20,
2020), 85 FR 31828 (May 27, 2020) (File Nos. SR–
DTC–2020–008; SR–FICC–2020–004; SR–NSCC–
2020–008), 92380 (July 13, 2021), 86 FR 38140 (July
19, 2021) (File No. SR–FICC–2021–006), 92381 (July
13, 2021), 86 FR 38163 (July 19, 2021) (File No. SR–
NSCC–2021–008) and 92379 (July 13, 2021), 86 FR
38143 (July 19, 2021) (File No. SR–DTC–2021–003).
Consistent with this obligation, FICC proposes to
specifically state in the QRM Methodology
Document that any changes or adjustments to the
repo haircut rate calculation would need to go
through this model governance process.
21 See
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Consumer Protection Act (‘‘Dodd-Frank
Act’’) and Rule 19b–4(n)(1)(i) under the
Act, FICC would be required to file an
advance notice with the Commission for
any proposed change to the repo haircut
rate calculation that would materially
affect the nature or level of risks
presented by FICC.23 Additionally, FICC
tracks the repo haircut rates in a
monthly model parameter report, which
is provided to the Commission in its
supervisory capacity.24
FICC believes that enhancing its
ability to quickly adjust the repo haircut
rate calculation would better enable
FICC to manage the risks of its members’
repo interest positions.25 Specifically,
FICC believes the proposed change
would enable FICC to make appropriate
and timely adjustments to the repo
haircut rates based on an evaluation of
a number of factors, including, but not
limited to, repo interest rate volatility
outlook and backtesting coverage
results.26 Furthermore, FICC has
identified certain known data
availability limitations with respect to
the current repo interest rate index.27
Specifically, the current repo interest
rate index is missing data for a volatile
period, such that repo haircut rates
calibrated based on the current repo
interest rate index might not calculate
sufficient margin amounts during
periods of heightened repo market
volatility.28 FICC believes that the
ability to quickly adjust the repo haircut
rate calculation in response to rapidly
changing market conditions would help
mitigate the effects of such potential
data availability limitations.29
4. Technical and Conforming Changes
FICC proposes to make certain
technical and conforming changes to the
QRM Methodology Document for
clarity.30
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III. Discussion and Commission
Findings
Section 19(b)(2)(C) of the Act 31
directs the Commission to approve a
proposed rule change of a self23 12 U.S.C. 5465(e)(1) and 17 CFR 240.19b–
4(n)(1)(i).
24 See Notice, supra note 3, at 42526.
25 Id.
26 Id.
27 Id.
28 Id.
29 Id.
30 FICC’s proposed technical and conforming
changes are designed to use more precise language,
remove obsolete items, clarify and address
substantive changes discussed in the proposal, and
otherwise enhance the QRM Methodology
Document’s readability. For a detailed description
of FICC’s proposed technical and conforming
changes, please refer to the Notice, supra note 3, at
42526–27.
31 15 U.S.C. 78s(b)(2)(C).
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regulatory organization if it finds that
such proposed rule change is consistent
with the requirements of the Act and the
rules and regulations thereunder
applicable to such organization. After
careful consideration, the Commission
finds that the proposed rule change is
consistent with the requirements of the
Act and the rules and regulations
thereunder applicable to FICC. In
particular, the Commission finds that
the proposed rule change is consistent
with Section 17A(b)(3)(F) of the Act 32
and Rules 17Ad–22(e)(4) 33 and (e)(6) 34
thereunder.
A. Consistency With Section
17A(b)(3)(F) of the Act
Section 17A(b)(3)(F) of the Act
requires, among other things, that the
rules of a clearing agency, such as FICC,
be designed to promote the prompt and
accurate clearance and settlement of
securities transactions and to assure the
safeguarding of securities and funds
which are in the custody or control of
the clearing agency or for which it is
responsible.35
As described in Section II.B.1 above,
FICC proposes to change its formula for
calculating the repo interest volatility
charge. Specifically, FICC would no
longer apply the repo haircut rate based
on whether the total net amount of a
portfolio’s positions in a specific risk
bucket is long or short, as does the
currently formula. Instead, FICC
proposes to apply a specific repo haircut
rate based on whether the individual
repo interest positions in a given risk
bucket are either long or short,
specifically, enabling FICC to use two
haircuts for each risk bucket, one for
long positions and the other for short
positions. The repo interest volatility
charge for a specific risk bucket would
be the absolute value of the sum of the
products of repo start amount, time to
settlement, and repo haircut rate of the
individual repo interest positions in the
risk bucket. The total repo interest
volatility charge for the portfolio would
be the sum of the repo interest volatility
charges of all of the risk buckets in the
portfolio. By allowing FICC to use two
haircuts for each risk bucket, the
proposed formula should better
facilitate FICC’s collection of sufficient
margin by enabling FICC to respond to
rapidly changing market conditions
more quickly and effectively,
particularly when the long and short
repo interest positions exhibit very
different risk profiles.
32 15
U.S.C. 78q–1(b)(3)(F).
CFR 240.17Ad–22(e)(4)(i).
34 17 CFR 240.17Ad–22(e)(6)(i) and (v).
35 15 U.S.C. 78q–1(b)(3)(F).
33 17
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As described in Section II.B.2 above,
FICC proposes to add a repo bid/ask
spread to each repo haircut rate within
the same risk bucket, based on the
historical percentile movements of
FICC’s internally constructed repo
interest rate indices. Adding the bid/ask
spread would generate margin amounts
not currently accounted for in the
current repo interest volatility charge
formula. Specifically, the proposed bid/
ask spread component would account
for the difference observed in the repo
market between the highest rate a repo
participant is willing to pay to borrow
money in a repo trade and the lowest
rate a repo participant is willing to
accept to lend money in a repo trade.
Based on the Impact Study,36 had
FICC used the proposed formula (i.e.,
two haircuts for each risk bucket) and
the proposed bid/ask spread
component, the CCP-level backtesting
coverage ratio for the repo interest
volatility charge would have increased
from approximately 98.7 percent to 99.2
during the period of January 2018 to
February 2022. The Commission
believes that the results of the Impact
Study demonstrate that these proposed
changes would have enabled FICC to
generate margin amounts that more
effectively cover FICC’s relevant credit
exposures than the current formula.
Additionally, as described in Section
II.B.3 above, FICC proposes to move the
detailed description of the repo haircut
rate calculation for all risk buckets from
the QRM Methodology Document to an
internal standalone document, which
FICC would not consider to be a ‘‘rule’’
for purposes of Rule 19b–4 37 under the
Act. As such, the proposed change
would provide FICC with greater
flexibility to respond to rapidly
changing market conditions more
quickly, which in turn, would better
enable FICC to risk manage its members’
repo interest positions and effectively
cover FICC’s applicable credit
exposures.
Accordingly, the Commission believes
that implementing the changes set forth
in Sections II.B.1, II.B.2, and II.B.3
36 See
supra note 15.
CFR 240.19b–4. A stated policy, practice, or
interpretation of a self-regulatory organization is not
a ‘‘rule’’ that would be subject to the Rule 19b–4
filing requirements if, for example, it is reasonably
and fairly implied by an existing rule of the selfregulatory organization. See 17 CFR 240.19b–4(c).
However, any future changes to the repo haircut
rate calculations would be subject to DTCC’s
internal model governance procedure as described
in the Clearing Agency Model Risk Management
Framework. See supra note 22. Moreover, any
future changes to the repo haircut rate calculations
that would materially affect the nature or level of
risks presented by FICC would be subject to the
advance notice filing requirements of the DoddFrank Act. See supra note 23.
37 17
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should help ensure that, in the event of
a member default, FICC’s operation of
its critical clearance and settlement
services would not be disrupted because
of insufficient financial resources. The
Commission, therefore, finds that FICC’s
proposals to change the repo interest
volatility charge formula, add the bid/
ask spread component, and remove the
details of the repo haircut rate
calculations from the QRM
Methodology Document should help
FICC to continue providing prompt and
accurate clearance and settlement of
securities transactions in the event of a
member default, consistent with Section
17A(b)(3)(F) of the Act.38
Moreover, as described in Section II.A
above, FICC would access the
mutualized Clearing Fund should a
defaulted member’s own margin be
insufficient to satisfy losses to FICC
caused by the liquidation of that
member’s portfolio. Because FICC’s
proposals to change the repo interest
volatility charge formula, add the bid/
ask spread component, and remove the
details of the repo haircut rate
calculations from the QRM
Methodology Document, should help
ensure that FICC has collected sufficient
margin from members, the proposed
changes would also help minimize the
likelihood that FICC would have to
access the Clearing Fund, thereby
limiting non-defaulting members’
exposure to mutualized losses. The
Commission believes that by helping to
limit the exposure of FICC’s nondefaulting members to mutualized
losses, the proposed changes should
help FICC assure the safeguarding of
securities and funds which are in its
custody or control, consistent with
Section 17A(b)(3)(F) of the Act.39
Finally, as described in Section II.B.4
above, FICC proposes several technical
and conforming changes to the QRM
Methodology Document to improve
accuracy and clarity. The Commission
believes that greater accuracy and
clarity of the QRM Methodology
Document should better enable FICC to
effectively implement the document’s
provisions. Accordingly, the
Commission believes that FICC’s
proposed technical and conforming
changes should better enable FICC to
assess and collect sufficient margin from
its members with respect to the repo
interest volatility charge, thereby
promoting prompt and accurate
clearance and settlement, and assuring
the safeguarding of security and funds
which are in FICC’s custody or control,
consistent with Section 17A(b)(3)(F) of
the Act.40
C. Consistency With Rule 17Ad–22(e)(6)
Under the Act
B. Consistency With Rule 17Ad–22(e)(4)
Under the Act
Rule 17Ad–22(e)(6)(i) 43 under the Act
requires a clearing agency establish,
implement, maintain, and enforce
written policies and procedures
reasonably designed to cover its credit
exposures to its participants by
establishing a risk-based margin system
that, at a minimum, considers, and
produces margin levels commensurate
with, the risks and particular attributes
of each relevant product, portfolio, and
market. Rule 17Ad–22(e)(6)(v) 44 under
the Act requires a clearing agency to
establish, implement, maintain and
enforce written policies and procedures
reasonably designed to cover its credit
exposures to its participants by
establishing a risk-based margin system
that, at a minimum, uses an appropriate
method for measuring credit exposure
that accounts for relevant product risk
factors and portfolio effects across
products.
FICC’s proposal to change its formula
for calculating the repo interest
volatility charge by applying a specific
repo haircut rate based on whether
individual repo interest positions in a
given risk bucket are either long or short
would provide FICC the flexibility to
apply two separate repo haircut rates
(for long and short positions,
respectively) within the same risk
bucket. As a result, the proposed change
would enhance FICC’s ability to
respond quickly to rapidly changing
market conditions, particularly when
long and short repo interest positions
exhibit very different risk profiles.45
Additionally, FICC’s proposal to add a
bid/ask spread component to the repo
interest volatility charge would account
for the difference observed in the repo
market between the highest rate a repo
participant is willing to pay to borrow
money and the lowest rate a repo
participant is willing to accept to lend
money. Finally, based on its review of
the Proposed Rule Change, including
confidential Exhibit 3 thereto,46 the
Commission understands that the
proposed changes generate sufficient
margin amounts more effectively than
Rule 17Ad–22(e)(4)(i) 41 under the Act
requires a covered clearing agency to
establish, implement, maintain and
enforce written policies and procedures
reasonably designed to effectively
identify, measure, monitor, and manage
its credit exposures to participants and
those exposures arising from its
payment, clearing, and settlement
processes by maintaining sufficient
financial resources to cover its credit
exposure to each participant fully with
a high degree of confidence.
As described in Section III.A above,
FICC’s proposals to: (i) apply a specific
repo haircut rate based on whether
individual repo interest positions in a
given risk bucket are either long or
short; and (ii) add a bid/ask spread
component to the repo interest volatility
charge should improve FICC’s ability to
calculate and collect sufficient margin
from its members. The results of FICC’s
Impact Study demonstrate that during
the period of January 2018 to February
2022, the proposed changes would have
enabled FICC to achieve its 99 percent
coverage target more effectively than the
current formula. Additionally, FICC’s
proposal to move the detailed
description of the repo haircut rate
calculation for all risk buckets from the
QRM Methodology Document to an
internal standalone document would
enable FICC to quickly adjust the
calculation in response to rapidly
changing market conditions, which in
turn, should better enable FICC to risk
manage its members’ repo interest
positions and thereby collect sufficient
margin to effectively cover FICC’s credit
exposures.
Because the foregoing proposed
changes should better enable FICC to
collect sufficient margin in connection
with member portfolios subject to the
repo interest volatility charge, the
Commission believes that the proposed
changes should enhance FICC’s ability
to maintain sufficient financial
resources to cover its credit exposures to
applicable member portfolios fully with
a high degree of confidence, consistent
with Rule 17Ad–22(e)(4)(i) under the
Act.42
40 Id.
38 Id.
41 17
39 Id.
42 Id.
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16:59 Aug 30, 2022
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CFR 240.17Ad–22(e)(4)(i).
Frm 00085
Fmt 4703
Sfmt 4703
43 17
CFR 240.17Ad–22(e)(6)(i).
CFR 240.17Ad–22(e)(6)(v).
45 FICC’s proposal to move the detailed
description of the repo haircut rate calculation for
all risk buckets from the QRM Methodology
Document to an internal standalone document
would enable FICC to quickly adjust the calculation
in response to rapidly changing market conditions,
which in turn, should enable FICC to better risk
manage its members’ repo interest positions.
46 See supra notes 14 and 15, describing the
information submitted confidentially.
44 17
E:\FR\FM\31AUN1.SGM
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53526
Federal Register / Vol. 87, No. 168 / Wednesday, August 31, 2022 / Notices
the current repo interest volatility
charge formula.
For these reasons, the Commission
believes that the proposed changes
should help ensure that FICC produces
margin levels commensurate with the
risks and particular attributes of its
member portfolios containing repo
interest positions by (i) enabling FICC to
adjust the repo interest volatility charge
formula in response to rapidly changing
market conditions, and (ii) accounting
for the bid/ask spread, which is not
addressed in the current repo interest
volatility charge formula. Accordingly,
the Commission believes that the
proposed changes would enhance
FICC’s risk-based margin system to
better enable FICC to cover its credit
exposures to its members’ repo interest
positions because the proposed changes
consider the risks and particular
attributes of the relevant products,
portfolios, and markets, consistent with
the requirements of Rule 17Ad–
22(e)(6)(i).47 Similarly, the Commission
believes that the proposed changes are
reasonably designed to cover FICC’s
credit exposures to its members’ repo
interest positions because the proposed
changes would enhance FICC’s riskbased margin system using appropriate
methods for measuring credit exposures
that account for relevant product risk
factors and portfolio effects, consistent
with the requirements of Rule 17Ad–
22(e)(6)(v).48
IV. Conclusion
On the basis of the foregoing, the
Commission finds that the proposed
rule change is consistent with the
requirements of the Act and, in
particular, with the requirements of
Section 17A of the Act 49 and the rules
and regulations promulgated
thereunder.
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act 50 that
proposed rule change SR–FICC–2022–
005, be, and hereby is, APPROVED.51
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.52
J. Matthew DeLesDernier,
Deputy Secretary.
[FR Doc. 2022–18768 Filed 8–30–22; 8:45 am]
lotter on DSK11XQN23PROD with NOTICES1
BILLING CODE 8011–01–P
47 17
CFR 240.17Ad–22(e)(6)(i).
CFR 240.17Ad–22(e)(6)(v).
49 15 U.S.C. 78q–1.
50 15 U.S.C. 78s(b)(2).
51 In approving the proposed rule change, the
Commission considered the proposals’ impact on
efficiency, competition, and capital formation. 15
U.S.C. 78c(f).
52 17 CFR 200.30–3(a)(12).
48 17
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16:59 Aug 30, 2022
Jkt 256001
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 95602; File No. SR–MSRB–
2022–05]
Self-Regulatory Organizations;
Municipal Securities Rulemaking
Board; Order Granting Approval of a
Proposed Rule Change Consisting of
Amendments to MSRB Rule G–34 to
Better Align the CUSIP Requirements
for Underwriters and Municipal
Advisors With Current Market
Practices
August 25, 2022.
I. Introduction
On July 1, 2022, the Municipal
Securities Rulemaking Board (the
‘‘MSRB’’ or ‘‘Board’’) filed with the
Securities and Exchange Commission
(the ‘‘SEC’’ or ‘‘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 consisting of amendments to
MSRB Rule G–34, on CUSIP numbers,
New Issue, and Market Information
Requirements (the ‘‘proposed rule
change’’). The proposed rule change
would make amendments to better align
Rule G–34’s requirements for obtaining
CUSIP numbers with the process
followed by market participants and
facilitate compliance with MSRB Rule
G–34 by streamlining the rule text.
The proposed rule change was
published for comment in the Federal
Register on July 13, 2022.3 The public
comment period closed on August 3,
2022, and three comment letters were
received on the proposed rule change.4
On August 22, 2022, the MSRB
responded to those comments.5 This
order approves the proposed rule
change.
II. Description of Proposed Rule Change
As described further herein and in the
Notice of Filing, the proposed rule
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 Exchange Act Release No. 95208 (July 7, 2022)
(the ‘‘Notice of Filing’’), 87 FR 41846 (July 13,
2022).
4 See Letter to Secretary, Commission, from
Michael Decker, Senior Vice President for Public
Policy, Bond Dealers of America (‘‘BDA’’), dated
August 3, 2022 (the ‘‘BDA Letter’’); Letter to
Secretary, Commission, from Kim M. Whelan, CoPresident, and Noreen P. White, Co-President,
Acacia Financial Group Inc., dated August 3, 2022
(the ‘‘Acacia Letter’’); and Letter to Secretary,
Commission, from Susan Gaffney, Executive
Director, National Association of Municipal
Advisors (‘‘NAMA’’), dated July 6, 2022 (the
‘‘NAMA Letter’’).
5 See Letter to Secretary, Commission, from Gail
Marshall, Chief Regulatory Officer, MSRB, dated
August 22, 2022 (the ‘‘MSRB Response Letter’’).
2 17
PO 00000
Frm 00086
Fmt 4703
Sfmt 4703
change specifies that CUSIP
applications must be made to the
Board’s designee (and not the Board
itself); removes the obligation for
municipal advisors providing advice
with respect to a competitive offering to
apply for the CUSIP number by no later
than one business day after
dissemination of a notice of sale in favor
of a more flexible standard that still
obligates the application to be made
within sufficient time to ensure timely
CUSIP number assignment; removes
language dictating the precise content of
a CUSIP number application that the
MSRB believes would more
appropriately be left to the Board’s
designee for receiving and reviewing
such applications; and provides that
certain obligations set forth in the rule
do not apply when CUSIP numbers have
been preassigned.6
A. Designee of the Board
MSRB Rule G–34(a)(i)(A) currently
requires an underwriter or municipal
advisor to obtain CUSIP numbers
through an application in writing to the
Board or its designee. The proposed rule
change amends this language by
providing that underwriters and
municipal advisors must apply to the
Board’s designee and removing the
language in the rule text that makes
reference to the Board as an option with
which to submit CUSIP application.7
The MSRB states that this revised
language is designed to avoid the
potential for confusion associated with
the current rule text and to more clearly
convey the MSRB’s expectations with
respect to the process of obtaining a
CUSIP number.8 The MSRB notes that it
does not currently assign CUSIP
numbers to municipal securities;
underwriters and municipal advisors
may only obtain a CUSIP by application
to the only entity that provides these
identifiers, CUSIP Global Services,
which is currently the only entity
serving as the Board’s designee.9 This
designation would remain unchanged
by the proposed rule change and would
be reflected in new Supplementary
Material .01.10 The MSRB states that if
CUSIP numbers become available from
another source or another identifier for
municipal securities becomes market
practice at some point in the future, the
MSRB would notify the market of a
decision to modify the designee via
6 See
Notice of Filing 87 FR 41846 at 41847.
7 Id.
8 Id.
9 Id.
10 Id.
E:\FR\FM\31AUN1.SGM
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Agencies
[Federal Register Volume 87, Number 168 (Wednesday, August 31, 2022)]
[Notices]
[Pages 53522-53526]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2022-18768]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-95605; File No. SR-FICC-2022-005]
Self-Regulatory Organizations; Fixed Income Clearing Corporation;
Order Approving Proposed Rule Change To Revise the Formula Used To
Calculate the VaR Charge for Repo Interest Volatility
August 25, 2022.
I. Introduction
On June 29, 2022, Fixed Income Clearing Corporation (``FICC'')
filed with the Securities and Exchange Commission (``Commission''),
pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
(``Act'') \1\ and Rule 19b-4 thereunder,\2\ proposed rule change SR-
FICC-2022-005. The proposed rule change was published for comment in
the Federal Register on July 15, 2022.\3\ The Commission did not
receive any comment letters on the proposed rule change. For the
reasons discussed below, the Commission is approving the proposed rule
change.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ Securities Exchange Act Release No. 95256 (July 12, 2022),
87 FR 42524 (July 15, 2022) (SR-FICC-2022-005) (``Notice'').
---------------------------------------------------------------------------
II. Description of the Proposed Rule Change
FICC proposes to amend its Government Securities Division (``GSD'')
\4\ Quantitative Risk Management (``QRM'') Methodology Document--GSD
Initial Market Risk Margin Model (``QRM Methodology Document'') \5\ in
order to (i) revise the formula FICC uses to calculate the Value at
Risk charge (``VaR Charge'') \6\ margin component for repurchase
agreement (``repo'') interest volatility, and (ii) make certain
technical and conforming changes.
---------------------------------------------------------------------------
\4\ FICC operates two divisions, GSD and the Mortgage Backed
Securities Division (``MBSD''). GSD provides trade comparison,
netting, risk management, settlement, and central counterparty
(``CCP'') services for the U.S. Government securities market,
including repos. MBSD provides the same services for the U.S.
mortgage-backed securities market. GSD and MBSD maintain separate
sets of rules, margin models, and clearing funds. The proposed rule
change relates solely to GSD.
\5\ FICC filed an excerpt of the QRM Methodology Document
showing the proposed changes as a confidential exhibit to this
proposed rule change, pursuant to 17 CFR 240.24-b2. FICC originally
filed the QRM Methodology Document confidentially as part of a
previous proposed rule change and advance notice approved by the
Commission regarding FICC's GSD sensitivity VaR. See Securities
Exchange Act Release Nos. 83362 (June 1, 2018), 83 FR 26514 (June 7,
2018) (SR-FICC-2018-001) and 83223 (May 11, 2018), 83 FR 23020 (May
17, 2018) (SR-FICC-2018-801).
\6\ Capitalized terms not defined herein are defined in FICC's
GSD Rulebook, available at https://www.dtcc.com/~/media/Files/
Downloads/legal/rules/ficc_gov_rules.pdf (``Rules'').
---------------------------------------------------------------------------
A. Background
Repos involve a pair of transactions between two parties. The first
transaction consists of the sale of securities, in which one party (the
``cash borrower'') delivers securities in exchange for the other
party's (the ``cash lender'') delivery of cash. The second transaction
occurs on a date after that of the first transaction and consists of a
repurchase of the securities, in which the obligations to deliver cash
and securities are reversed. FICC's members submit repos to FICC for
matching, comparison, risk management, and ultimately, net settlement.
FICC guarantees that the cash borrower receives its repo collateral
back at the close of a repo transaction, while the cash lender receives
the amount paid at the repo's start, plus interest. Interest on a repo
transaction is the difference between the repurchase settlement amount
and the start amount paid on the repo inception date.
A key tool that FICC uses to manage its credit exposures to its
members is the daily collection of margin from each member. The
aggregated amount of all members' margin constitutes the Clearing
Fund,\7\ which FICC would be able to access should a defaulted member's
own margin be insufficient to satisfy losses to FICC caused by the
liquidation of that member's portfolio. Each member's margin consists
of a number of applicable components, including the VaR Charge which is
designed to capture the potential market price risk associated with the
securities in a member's portfolio.\8\ The VaR Charge is typically the
largest component of a member's margin requirement. FICC designed the
VaR Charge to cover FICC's projected liquidation losses with respect to
a defaulted member's portfolio at a 99 percent confidence level.
---------------------------------------------------------------------------
\7\ See Rule 4 of the Rules, supra note 6.
\8\ See Rule 1 of the Rules, supra note 6.
---------------------------------------------------------------------------
The VaR Charge includes, among other things, a component that
addresses repo interest volatility (the ``repo interest volatility
charge'').\9\ The QRM Methodology Document describes FICC's formula for
calculating the repo interest volatility charge. The market value of
interest payments for the duration of a repo transaction are subject to
the risk of movements of the market repo interest rates. Since FICC
guarantees the repo interest payment to the cash lenders, FICC must
mitigate the risk arising out of fluctuations in market repo interest
rates for a specified period of time after a member default.\10\
---------------------------------------------------------------------------
\9\ Currently, the repo interest volatility constitutes
approximately 3 percent of the total GSD margin (at the CCP level).
See Notice, supra note 3, at 42524.
\10\ This time period is currently set at three days, which
represents the duration of time that FICC would be subject to market
risk after a member default, starting from the time of the last
successful margin collection to the time the market risk exposure is
effectively mitigated. See Notice, supra note 3, at 42524.
---------------------------------------------------------------------------
Under the current formula, the repo interest positions for a given
member portfolio are put into different risk buckets based on (i)
whether the underlying repo trade is a generic repo trade or a special
repo trade,\11\ and (ii) the time to settlement of the underlying repo
trade. FICC assesses the repo interest volatility charge by applying a
haircut schedule to the different risk buckets, with a single haircut
rate applied to each risk bucket after netting the short and long repo
interest positions within the relevant bucket. The total net amount of
each risk bucket equals the sum of the products of the repo start
amount and the time to settlement of each repo interest position in
that risk bucket. If the total net amount is positive (i.e., long),
FICC applies a long repo haircut rate to the total net amount for that
risk bucket to calculate the repo interest volatility charge for that
risk bucket. If the total net amount is negative (i.e., short), FICC
applies a short repo haircut rate to the absolute value of the total
net amount for that risk bucket to calculate the repo interest
volatility charge for that risk bucket. The total repo interest
volatility charge for a member's portfolio is the sum of the repo
interest volatility charges of all of the risk buckets in the
portfolio. Accordingly, the current formula reflects a repo interest
rate
[[Page 53523]]
index \12\ driven approach where a single repo haircut rate is applied
to the absolute value of the total net amount of each risk bucket of
repo interest positions.\13\ The QRM Methodology Document, which was
filed confidentially, contains a detailed description of the repo
haircut rate calculation for all risk buckets.
---------------------------------------------------------------------------
\11\ FICC designates repo trades as either generic or special
depending on how the repo rate of the trade's particular collateral
compares to the prevailing market rates of similar repo
transactions.
\12\ FICC has developed its repo interest rate indices using its
delivery-versus-payment repo transactions. See Notice, supra note 3,
at 42525.
\13\ For a detailed example of the current repo interest
volatility charge calculation, please refer to the Notice, supra
note 3, at 42525.
---------------------------------------------------------------------------
Based on FICC's 2020 and 2021 annual model validation reports,\14\
the rolling 12-month backtesting coverage on members' repo interest
positions were below the 99 percent coverage target from June 2019 to
September 2020. Additionally, FICC conducted an impact study for the
period of January 2018 to February 2022 (``Impact Study''),\15\ which
demonstrated a backtesting coverage ratio of 98.7 percent for the repo
interest volatility charge during that time period. To address these
deficiencies, FICC proposes to change the formula for calculating the
repo interest volatility charge to improve backtesting coverage and
provide FICC with greater flexibility than the current formula to
calculate the repo interest volatility charge in a manner that is more
responsive to rapidly changing market conditions.
---------------------------------------------------------------------------
\14\ Pursuant to 17 CFR 240.24-b2, FICC filed excerpts of (1)
the GSD Initial Market Risk Margin Models: Model Validation Report,
July 2021, and (2) the Depository Trust and Clearing Corporation
(``DTCC'') Model Validation Report/GSD Initial Market Risk Margin
Models, July 2020, in a confidential Exhibit 3 to this proposed rule
change.
\15\ Pursuant to 17 CFR 240.24-b2, FICC filed a summary of the
Impact Study in a confidential Exhibit 3 to this proposed rule
change. The Impact Study
---------------------------------------------------------------------------
B. Proposed Rule Change
1. New Formula for Calculating Repo Interest Volatility Charge
The proposed formula is similar to the current formula in certain
respects. For example, the proposed formula would continue to rely upon
repo interest rate indices and would use a similar mathematical
calculation as the current formula. In addition, under the proposed
formula, the repo interest positions for a given member portfolio would
continue to be placed into risk buckets based on the same criteria used
currently, that is, (i) whether the underlying repo trade is a generic
repo trade or a special repo trade, and (ii) the time to settlement of
the underlying repo trade. Finally, the total repo interest volatility
charge for the portfolio would continue to be the sum of the repo
interest volatility charges of all of the risk buckets in the
portfolio.
However, unlike the current formula, the proposed formula provides
FICC with the flexibility to apply more than one repo haircut rate to
each risk bucket because FICC would no longer apply the repo haircut
rate based on whether the total net amount for a specific risk bucket
is long or short. Instead, FICC proposes to apply a specific repo
haircut rate based on whether the individual repo interest position in
a given risk bucket is either long or short. That is, FICC would apply
a long repo haircut rate to all long positions and a short repo haircut
rate to all short positions, in each risk bucket. The long positions
and the short positions could offset each other within the same risk
bucket, but could not offset each other across different risk buckets.
The repo interest volatility charge for a specific risk bucket would be
the absolute value \16\ of the sum of the products of repo start
amount, time to settlement, and repo haircut rate of the individual
repo interest positions in the risk bucket. Thus, by allowing FICC to
use two haircuts for each risk bucket, one for long positions and the
other for short positions,\17\ the proposal would enable FICC to
respond to rapidly changing market conditions more quickly and
timely.\18\
---------------------------------------------------------------------------
\16\ The repo interest volatility charge would always be a
positive number because the calculation is based on the absolute
value of the sum of the relevant amounts.
\17\ As an initial matter, FICC would set the repo haircut rates
for long positions and short positions to be the same rate, i.e.,
the larger of the two rates, so that the long and short positions in
a specific risk bucket would be subject to the same repo haircut
rate.
\18\ See Notice, supra note 3, at 42525.
---------------------------------------------------------------------------
2. Add Bid-Ask Spread To Repo Haircut Rates
FICC also proposes to add a repo bid/ask spread to each repo
haircut rate (one for long positions and one for short positions)
within the same risk bucket. FICC would calculate the repo bid/ask
spread based on the historical percentile movements of FICC's
internally constructed repo interest rate indices. FICC states that
this change would account for the difference observed in the repo
market between the highest rate a repo participant is willing to pay to
borrow money in a repo trade and the lowest rate a repo participant is
willing to accept to lend money in a repo trade. FICC believes that
adding the repo bid/ask spread to each of the repo haircut rates would
improve backtesting coverage, particularly with respect to sub-
portfolios of repo interest only positions.\19\
---------------------------------------------------------------------------
\19\ Id.
---------------------------------------------------------------------------
Based on the Impact Study, had the proposed new formula and repo
bid-ask spread been in place during the period of January 2018 to
February 2022, the CCP-level backtesting coverage ratio for the repo
interest volatility charge would have increased from approximately 98.7
percent to 99.2 percent.\20\
---------------------------------------------------------------------------
\20\ See Notice, supra note 3, at 42526.
---------------------------------------------------------------------------
3. Remove Description of Repo Haircut Rate Calculations
As stated above, the QRM Methodology Document currently contains a
detailed description of the repo haircut rate calculation for all risk
buckets. FICC proposes to eliminate this detailed description from the
QRM Methodology Document and replace it with a more general description
of the repo haircut rate calculation. FICC proposes to describe the
detailed calculations of the repo haircut rates in an internal
standalone document.
FICC believes a more general description of the repo haircut rate
calculation would be sufficient for the QRM Methodology Document, and
would provide FICC with greater flexibility to respond to rapidly
changing market conditions more quickly and timely by enabling FICC to
adjust the calculation.\21\ Nonetheless, FICC acknowledges that any
future changes to the repo haircut rate calculations would continue to
follow DTCC's internal model governance procedure as described in the
Clearing Agency Model Risk Management Framework.\22\ Moreover, pursuant
to Section 806(e)(1) of Title VIII of the Dodd-Frank Wall Street Reform
and
[[Page 53524]]
Consumer Protection Act (``Dodd-Frank Act'') and Rule 19b-4(n)(1)(i)
under the Act, FICC would be required to file an advance notice with
the Commission for any proposed change to the repo haircut rate
calculation that would materially affect the nature or level of risks
presented by FICC.\23\ Additionally, FICC tracks the repo haircut rates
in a monthly model parameter report, which is provided to the
Commission in its supervisory capacity.\24\
---------------------------------------------------------------------------
\21\ See Notice, supra note 3, at 42526. Specifically, FICC
states that the more general description would allow it to adjust
the calculation without needing to submit a proposed rule change
pursuant to Rule 19b-4, 17 CFR 240.19b-4. Id.
\22\ Id. The Clearing Agency Model Risk Management Framework
(``Framework'') sets forth the model risk management practices that
FICC and its affiliates, The Depository Trust Company and National
Securities Clearing Corporation, follows to identify, measure,
monitor, and manage the risks associated with the design,
development, implementation, use, and validation of quantitative
models. See Securities Exchange Act Release Nos. 81485 (August 25,
2017), 82 FR 41433 (August 31, 2017) (File Nos. SR-DTC-2017-008; SR-
FICC-2017-014; SR-NSCC-2017-008), 88911 (May 20, 2020), 85 FR 31828
(May 27, 2020) (File Nos. SR-DTC-2020-008; SR-FICC-2020-004; SR-
NSCC-2020-008), 92380 (July 13, 2021), 86 FR 38140 (July 19, 2021)
(File No. SR-FICC-2021-006), 92381 (July 13, 2021), 86 FR 38163
(July 19, 2021) (File No. SR-NSCC-2021-008) and 92379 (July 13,
2021), 86 FR 38143 (July 19, 2021) (File No. SR-DTC-2021-003).
Consistent with this obligation, FICC proposes to specifically state
in the QRM Methodology Document that any changes or adjustments to
the repo haircut rate calculation would need to go through this
model governance process.
\23\ 12 U.S.C. 5465(e)(1) and 17 CFR 240.19b-4(n)(1)(i).
\24\ See Notice, supra note 3, at 42526.
---------------------------------------------------------------------------
FICC believes that enhancing its ability to quickly adjust the repo
haircut rate calculation would better enable FICC to manage the risks
of its members' repo interest positions.\25\ Specifically, FICC
believes the proposed change would enable FICC to make appropriate and
timely adjustments to the repo haircut rates based on an evaluation of
a number of factors, including, but not limited to, repo interest rate
volatility outlook and backtesting coverage results.\26\ Furthermore,
FICC has identified certain known data availability limitations with
respect to the current repo interest rate index.\27\ Specifically, the
current repo interest rate index is missing data for a volatile period,
such that repo haircut rates calibrated based on the current repo
interest rate index might not calculate sufficient margin amounts
during periods of heightened repo market volatility.\28\ FICC believes
that the ability to quickly adjust the repo haircut rate calculation in
response to rapidly changing market conditions would help mitigate the
effects of such potential data availability limitations.\29\
---------------------------------------------------------------------------
\25\ Id.
\26\ Id.
\27\ Id.
\28\ Id.
\29\ Id.
---------------------------------------------------------------------------
4. Technical and Conforming Changes
FICC proposes to make certain technical and conforming changes to
the QRM Methodology Document for clarity.\30\
---------------------------------------------------------------------------
\30\ FICC's proposed technical and conforming changes are
designed to use more precise language, remove obsolete items,
clarify and address substantive changes discussed in the proposal,
and otherwise enhance the QRM Methodology Document's readability.
For a detailed description of FICC's proposed technical and
conforming changes, please refer to the Notice, supra note 3, at
42526-27.
---------------------------------------------------------------------------
III. Discussion and Commission Findings
Section 19(b)(2)(C) of the Act \31\ directs the Commission to
approve a proposed rule change of a self-regulatory organization if it
finds that such proposed rule change is consistent with the
requirements of the Act and the rules and regulations thereunder
applicable to such organization. After careful consideration, the
Commission finds that the proposed rule change is consistent with the
requirements of the Act and the rules and regulations thereunder
applicable to FICC. In particular, the Commission finds that the
proposed rule change is consistent with Section 17A(b)(3)(F) of the Act
\32\ and Rules 17Ad-22(e)(4) \33\ and (e)(6) \34\ thereunder.
---------------------------------------------------------------------------
\31\ 15 U.S.C. 78s(b)(2)(C).
\32\ 15 U.S.C. 78q-1(b)(3)(F).
\33\ 17 CFR 240.17Ad-22(e)(4)(i).
\34\ 17 CFR 240.17Ad-22(e)(6)(i) and (v).
---------------------------------------------------------------------------
A. Consistency With Section 17A(b)(3)(F) of the Act
Section 17A(b)(3)(F) of the Act requires, among other things, that
the rules of a clearing agency, such as FICC, be designed to promote
the prompt and accurate clearance and settlement of securities
transactions and to assure the safeguarding of securities and funds
which are in the custody or control of the clearing agency or for which
it is responsible.\35\
---------------------------------------------------------------------------
\35\ 15 U.S.C. 78q-1(b)(3)(F).
---------------------------------------------------------------------------
As described in Section II.B.1 above, FICC proposes to change its
formula for calculating the repo interest volatility charge.
Specifically, FICC would no longer apply the repo haircut rate based on
whether the total net amount of a portfolio's positions in a specific
risk bucket is long or short, as does the currently formula. Instead,
FICC proposes to apply a specific repo haircut rate based on whether
the individual repo interest positions in a given risk bucket are
either long or short, specifically, enabling FICC to use two haircuts
for each risk bucket, one for long positions and the other for short
positions. The repo interest volatility charge for a specific risk
bucket would be the absolute value of the sum of the products of repo
start amount, time to settlement, and repo haircut rate of the
individual repo interest positions in the risk bucket. The total repo
interest volatility charge for the portfolio would be the sum of the
repo interest volatility charges of all of the risk buckets in the
portfolio. By allowing FICC to use two haircuts for each risk bucket,
the proposed formula should better facilitate FICC's collection of
sufficient margin by enabling FICC to respond to rapidly changing
market conditions more quickly and effectively, particularly when the
long and short repo interest positions exhibit very different risk
profiles.
As described in Section II.B.2 above, FICC proposes to add a repo
bid/ask spread to each repo haircut rate within the same risk bucket,
based on the historical percentile movements of FICC's internally
constructed repo interest rate indices. Adding the bid/ask spread would
generate margin amounts not currently accounted for in the current repo
interest volatility charge formula. Specifically, the proposed bid/ask
spread component would account for the difference observed in the repo
market between the highest rate a repo participant is willing to pay to
borrow money in a repo trade and the lowest rate a repo participant is
willing to accept to lend money in a repo trade.
Based on the Impact Study,\36\ had FICC used the proposed formula
(i.e., two haircuts for each risk bucket) and the proposed bid/ask
spread component, the CCP-level backtesting coverage ratio for the repo
interest volatility charge would have increased from approximately 98.7
percent to 99.2 during the period of January 2018 to February 2022. The
Commission believes that the results of the Impact Study demonstrate
that these proposed changes would have enabled FICC to generate margin
amounts that more effectively cover FICC's relevant credit exposures
than the current formula.
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\36\ See supra note 15.
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Additionally, as described in Section II.B.3 above, FICC proposes
to move the detailed description of the repo haircut rate calculation
for all risk buckets from the QRM Methodology Document to an internal
standalone document, which FICC would not consider to be a ``rule'' for
purposes of Rule 19b-4 \37\ under the Act. As such, the proposed change
would provide FICC with greater flexibility to respond to rapidly
changing market conditions more quickly, which in turn, would better
enable FICC to risk manage its members' repo interest positions and
effectively cover FICC's applicable credit exposures.
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\37\ 17 CFR 240.19b-4. A stated policy, practice, or
interpretation of a self-regulatory organization is not a ``rule''
that would be subject to the Rule 19b-4 filing requirements if, for
example, it is reasonably and fairly implied by an existing rule of
the self-regulatory organization. See 17 CFR 240.19b-4(c). However,
any future changes to the repo haircut rate calculations would be
subject to DTCC's internal model governance procedure as described
in the Clearing Agency Model Risk Management Framework. See supra
note 22. Moreover, any future changes to the repo haircut rate
calculations that would materially affect the nature or level of
risks presented by FICC would be subject to the advance notice
filing requirements of the Dodd-Frank Act. See supra note 23.
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Accordingly, the Commission believes that implementing the changes
set forth in Sections II.B.1, II.B.2, and II.B.3
[[Page 53525]]
should help ensure that, in the event of a member default, FICC's
operation of its critical clearance and settlement services would not
be disrupted because of insufficient financial resources. The
Commission, therefore, finds that FICC's proposals to change the repo
interest volatility charge formula, add the bid/ask spread component,
and remove the details of the repo haircut rate calculations from the
QRM Methodology Document should help FICC to continue providing prompt
and accurate clearance and settlement of securities transactions in the
event of a member default, consistent with Section 17A(b)(3)(F) of the
Act.\38\
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\38\ Id.
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Moreover, as described in Section II.A above, FICC would access the
mutualized Clearing Fund should a defaulted member's own margin be
insufficient to satisfy losses to FICC caused by the liquidation of
that member's portfolio. Because FICC's proposals to change the repo
interest volatility charge formula, add the bid/ask spread component,
and remove the details of the repo haircut rate calculations from the
QRM Methodology Document, should help ensure that FICC has collected
sufficient margin from members, the proposed changes would also help
minimize the likelihood that FICC would have to access the Clearing
Fund, thereby limiting non-defaulting members' exposure to mutualized
losses. The Commission believes that by helping to limit the exposure
of FICC's non-defaulting members to mutualized losses, the proposed
changes should help FICC assure the safeguarding of securities and
funds which are in its custody or control, consistent with Section
17A(b)(3)(F) of the Act.\39\
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\39\ Id.
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Finally, as described in Section II.B.4 above, FICC proposes
several technical and conforming changes to the QRM Methodology
Document to improve accuracy and clarity. The Commission believes that
greater accuracy and clarity of the QRM Methodology Document should
better enable FICC to effectively implement the document's provisions.
Accordingly, the Commission believes that FICC's proposed technical and
conforming changes should better enable FICC to assess and collect
sufficient margin from its members with respect to the repo interest
volatility charge, thereby promoting prompt and accurate clearance and
settlement, and assuring the safeguarding of security and funds which
are in FICC's custody or control, consistent with Section 17A(b)(3)(F)
of the Act.\40\
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\40\ Id.
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B. Consistency With Rule 17Ad-22(e)(4) Under the Act
Rule 17Ad-22(e)(4)(i) \41\ under the Act requires a covered
clearing agency to establish, implement, maintain and enforce written
policies and procedures reasonably designed to effectively identify,
measure, monitor, and manage its credit exposures to participants and
those exposures arising from its payment, clearing, and settlement
processes by maintaining sufficient financial resources to cover its
credit exposure to each participant fully with a high degree of
confidence.
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\41\ 17 CFR 240.17Ad-22(e)(4)(i).
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As described in Section III.A above, FICC's proposals to: (i) apply
a specific repo haircut rate based on whether individual repo interest
positions in a given risk bucket are either long or short; and (ii) add
a bid/ask spread component to the repo interest volatility charge
should improve FICC's ability to calculate and collect sufficient
margin from its members. The results of FICC's Impact Study demonstrate
that during the period of January 2018 to February 2022, the proposed
changes would have enabled FICC to achieve its 99 percent coverage
target more effectively than the current formula. Additionally, FICC's
proposal to move the detailed description of the repo haircut rate
calculation for all risk buckets from the QRM Methodology Document to
an internal standalone document would enable FICC to quickly adjust the
calculation in response to rapidly changing market conditions, which in
turn, should better enable FICC to risk manage its members' repo
interest positions and thereby collect sufficient margin to effectively
cover FICC's credit exposures.
Because the foregoing proposed changes should better enable FICC to
collect sufficient margin in connection with member portfolios subject
to the repo interest volatility charge, the Commission believes that
the proposed changes should enhance FICC's ability to maintain
sufficient financial resources to cover its credit exposures to
applicable member portfolios fully with a high degree of confidence,
consistent with Rule 17Ad-22(e)(4)(i) under the Act.\42\
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\42\ Id.
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C. Consistency With Rule 17Ad-22(e)(6) Under the Act
Rule 17Ad-22(e)(6)(i) \43\ under the Act requires a clearing agency
establish, implement, maintain, and enforce written policies and
procedures reasonably designed to cover its credit exposures to its
participants by establishing a risk-based margin system that, at a
minimum, considers, and produces margin levels commensurate with, the
risks and particular attributes of each relevant product, portfolio,
and market. Rule 17Ad-22(e)(6)(v) \44\ under the Act requires a
clearing agency to establish, implement, maintain and enforce written
policies and procedures reasonably designed to cover its credit
exposures to its participants by establishing a risk-based margin
system that, at a minimum, uses an appropriate method for measuring
credit exposure that accounts for relevant product risk factors and
portfolio effects across products.
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\43\ 17 CFR 240.17Ad-22(e)(6)(i).
\44\ 17 CFR 240.17Ad-22(e)(6)(v).
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FICC's proposal to change its formula for calculating the repo
interest volatility charge by applying a specific repo haircut rate
based on whether individual repo interest positions in a given risk
bucket are either long or short would provide FICC the flexibility to
apply two separate repo haircut rates (for long and short positions,
respectively) within the same risk bucket. As a result, the proposed
change would enhance FICC's ability to respond quickly to rapidly
changing market conditions, particularly when long and short repo
interest positions exhibit very different risk profiles.\45\
Additionally, FICC's proposal to add a bid/ask spread component to the
repo interest volatility charge would account for the difference
observed in the repo market between the highest rate a repo participant
is willing to pay to borrow money and the lowest rate a repo
participant is willing to accept to lend money. Finally, based on its
review of the Proposed Rule Change, including confidential Exhibit 3
thereto,\46\ the Commission understands that the proposed changes
generate sufficient margin amounts more effectively than
[[Page 53526]]
the current repo interest volatility charge formula.
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\45\ FICC's proposal to move the detailed description of the
repo haircut rate calculation for all risk buckets from the QRM
Methodology Document to an internal standalone document would enable
FICC to quickly adjust the calculation in response to rapidly
changing market conditions, which in turn, should enable FICC to
better risk manage its members' repo interest positions.
\46\ See supra notes 14 and 15, describing the information
submitted confidentially.
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For these reasons, the Commission believes that the proposed
changes should help ensure that FICC produces margin levels
commensurate with the risks and particular attributes of its member
portfolios containing repo interest positions by (i) enabling FICC to
adjust the repo interest volatility charge formula in response to
rapidly changing market conditions, and (ii) accounting for the bid/ask
spread, which is not addressed in the current repo interest volatility
charge formula. Accordingly, the Commission believes that the proposed
changes would enhance FICC's risk-based margin system to better enable
FICC to cover its credit exposures to its members' repo interest
positions because the proposed changes consider the risks and
particular attributes of the relevant products, portfolios, and
markets, consistent with the requirements of Rule 17Ad-22(e)(6)(i).\47\
Similarly, the Commission believes that the proposed changes are
reasonably designed to cover FICC's credit exposures to its members'
repo interest positions because the proposed changes would enhance
FICC's risk-based margin system using appropriate methods for measuring
credit exposures that account for relevant product risk factors and
portfolio effects, consistent with the requirements of Rule 17Ad-
22(e)(6)(v).\48\
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\47\ 17 CFR 240.17Ad-22(e)(6)(i).
\48\ 17 CFR 240.17Ad-22(e)(6)(v).
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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 Act
and, in particular, with the requirements of Section 17A of the Act
\49\ and the rules and regulations promulgated thereunder.
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\49\ 15 U.S.C. 78q-1.
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It is therefore ordered, pursuant to Section 19(b)(2) of the Act
\50\ that proposed rule change SR-FICC-2022-005, be, and hereby is,
APPROVED.\51\
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\50\ 15 U.S.C. 78s(b)(2).
\51\ In approving the proposed rule change, the Commission
considered the proposals' impact on efficiency, competition, and
capital formation. 15 U.S.C. 78c(f).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\52\
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\52\ 17 CFR 200.30-3(a)(12).
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J. Matthew DeLesDernier,
Deputy Secretary.
[FR Doc. 2022-18768 Filed 8-30-22; 8:45 am]
BILLING CODE 8011-01-P