Self-Regulatory Organizations; The Options Clearing Corporation; Order Granting Approval of Proposed Rule Change by The Options Clearing Corporation To Amend and Enhance the Options Clearing Corporation's Model Risk Management Policy, 41453-41455 [2023-13449]
Download as PDF
Federal Register / Vol. 88, No. 121 / Monday, June 26, 2023 / Notices
(a)(5), (a)(6), (a)(7), (a)(8), (a)(9)(ii) and
(a)(10), permit consideration of the
scheduled matters at the closed meeting.
The subject matter of the closed
meeting will consist of the following
topics:
Institution and settlement of
injunctive actions;
Institution and settlement of
administrative proceedings;
Resolution of litigation claims; and
Other matters relating to examinations
and enforcement proceedings.
At times, changes in Commission
priorities require alterations in the
scheduling of meeting agenda items that
may consist of adjudicatory,
examination, litigation, or regulatory
matters.
CONTACT PERSON FOR MORE INFORMATION:
For further information, please contact
Vanessa A. Countryman from the Office
of the Secretary at (202) 551–5400.
Authority: 5 U.S.C. 552b.
Dated: June 22, 2023.
Vanessa A. Countryman,
Secretary.
[FR Doc. 2023–13607 Filed 6–22–23; 4:15 pm]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–97770; File No. SR–
CboeEDGX–2023–030]
Self-Regulatory Organizations; Cboe
EDGX Exchange, Inc.; Notice of
Withdrawal of a Proposed Rule Change
To Amend Its Fee Schedule
ddrumheller on DSK120RN23PROD with NOTICES1
June 20, 2023.
On April 17, 2023, Cboe EDGX
Exchange, Inc. (‘‘Exchange’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder,2 a proposed rule
change to amend its fee schedule. The
proposed rule change was published for
comment in the Federal Register on
May 3, 2023.3 The Commission did not
receive any comment letters. On June 1,
2023, the Exchange withdrew the
proposed rule change (CboeEDGX–
2023–030).
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 97393
(April 27, 2023), 88 FR 27940.
4 17 CFR 200.30–3(a)(12).
2 17
VerDate Sep<11>2014
19:33 Jun 23, 2023
Jkt 259001
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.4
J. Matthew DeLesDernier,
Deputy Secretary.
[FR Doc. 2023–13456 Filed 6–23–23; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–97763; File No. SR–OCC–
2023–004]
Self-Regulatory Organizations; The
Options Clearing Corporation; Order
Granting Approval of Proposed Rule
Change by The Options Clearing
Corporation To Amend and Enhance
the Options Clearing Corporation’s
Model Risk Management Policy
June 20, 2023.
I. Introduction
On April 27, 2023, the Options
Clearing Corporation (‘‘OCC’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change SR–OCC–2023–
004 pursuant to Section 19(b) of the
Securities Exchange Act of 1934
(‘‘Exchange Act’’) 1 and Rule 19b–4 2
thereunder. The proposed rule change
would amend OCC’s Model Risk
Management Policy (the ‘‘MRM Policy’’
or ‘‘Policy’’) to, in part, broaden the
scope of OCC’s processes for managing
model risk. The proposed rule change
was published for public comment in
the Federal Register on May 17, 2023.3
The Commission has received no
comments regarding the proposed rule
change.
II. Background 4
OCC is a central counterparty
(‘‘CCP’’), which means it interposes
itself as the buyer to every seller and
seller to every buyer for financial
transactions. As the CCP for the listed
options markets in the U.S., as well as
for certain futures, OCC is exposed to
certain risks arising from its
relationships with its members. To
manage such risks, OCC uses
quantitative methods to make estimates,
forecasts, and projections in the context
of its credit risk models, margin system
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 Securities Exchange Act Release No. 97484 (May
11, 2023), 88 FR 31549 (May 17, 2023) (File No. SR–
OCC–2023–004) (‘‘Notice of Filing’’).
4 Capitalized terms used but not defined herein
have the meanings specified in OCC’s Rules and ByLaws, available at https://www.theocc.com/about/
publications/bylaws.jsp.
2 17
PO 00000
Frm 00083
Fmt 4703
Sfmt 4703
41453
and related models, and liquidity risk
models (each a ‘‘Risk Model’’).5
OCC’s use of models inherently
exposes OCC to model risk, such as the
risk of losses arising out of decisions
based on incorrect or misused model
outputs. For example, a model that is
not managed properly could potentially
cause OCC to under-collect the
collateral used to cover credit risk posed
by a Clearing Member. OCC’s MRM
Policy outlines OCC’s framework for
managing model risk and defines the
roles and responsibilities throughout the
risk model and methodology lifecycle.
Currently, the Policy applies to the
Risk Models that OCC uses to
determine, quantify, or measure actual
or potential risk exposures or risk
mitigating actions.6 The Policy also
describes and outlines the roles and
responsibilities of various groups at
OCC with regard to model risk
management.7 Further, changes to the
Policy are subject to annual review and
approval by the Risk Committee of
OCC’s Board of Directors.8 As described
in more detail below, OCC proposes to
expand the application of the Policy to
contemplate methodologies comprising
Risk Models and their related inputs
and outputs, rather than only individual
Risk Models. To accommodate the
expansion of the Policy’s scope beyond
individual Risk Models, OCC proposes
to revise the roles and responsibilities
described in the MRM Policy. To further
broaden the Policy, OCC proposes
adding a new section regarding the use
of tools with quantitative or
mathematical techniques not focused on
credit risk models, margin system and
related models, and liquidity risk
models (such tools and techniques
referred to as ‘‘Risk Applications’’).9
A. Expanding From Risk Models to Risk
Methodologies
As noted above, OCC proposes to
expand the scope of its MRM Policy to
encompass not only individual Risk
Models, but also the methodologies
such models comprise. Such ‘‘Risk
Methodologies’’ include the related
inputs and outputs of OCC’s Risk
Models, which OCC uses to estimate or
5 See Securities Exchange Act Release No. 82785
(Feb. 27, 2018), 83 FR 9345 (Mar. 5, 2018) (File No.
SR–OCC–2017–011) (approving the formalization of
the MRM Policy).
6 See id.
7 See id.
8 See Notice of Filing, 88 FR at 31552, n. 22.
9 OCC also proposes non-material verbiage
changes, such as updating references to internal
policies and removing duplicative definitions. For
example, OCC would remove standalone definitions
at the end of the Policy where either the term is
defined in the body of the Policy or is not used in
the Policy.
E:\FR\FM\26JNN1.SGM
26JNN1
41454
Federal Register / Vol. 88, No. 121 / Monday, June 26, 2023 / Notices
compute the distinct aspects of OCC’s
credit (i.e., Clearing Fund and margin)
and liquidity resources. To effectuate
this expansion, OCC proposes to replace
references to Risk Models with
references to Risk Methodologies, and to
revise the roles and responsibilities of
OCC staff as described below.
ddrumheller on DSK120RN23PROD with NOTICES1
B. OCC Internal Roles and
Responsibilities
OCC proposes changes to the roles
and responsibilities defined in its MRM
Policy to accommodate the shift in focus
from Risk Models to Risk
Methodologies. Such changes include
the expansion of the Model Risk
Management (‘‘MRM’’) department’s
responsibilities. MRM would become
responsible for validating both Risk
Models and Risk Methodologies no less
than annually.10 Further, the proposed
Policy would require MRM, in
validating OCC’s Risk Methodologies, to
review the performance of each
methodology and verify the related
software implementation.11
Additionally, certain references to a
specific department would be replaced
with references to such department’s
parent to encompass a broader set of
staff and responsibilities. For example,
discussion of OCC’s Quantitative Risk
Management (‘‘QRM’’) department’s role
in monitoring the use and performance
of individual Risk Models would be
replaced with discussion of OCC’s
Financial Risk Management (‘‘FRM’’)
department, of which QRM is a part.
Similarly, OCC proposes to expand the
responsibilities of the Model Risk
Working Group (‘‘MRWG’’) in
accordance with the expansion of the
MRM Policy.12 Currently, the MRWG
10 Such validations would be performed both
prior to implementation as well as on an ongoing
basis to evaluate the performance of individual Risk
Models. Pursuant to the MRM Policy, OCC requires
MRM to validate its Risk Models annually, which
OCC defines as every ‘‘12 months or 365 days.’’ The
head of MRM would be responsible for developing
and maintain OCC’s Annual Model Validation Plan.
OCC proposes to use the more generic ‘‘head of
MRM’’ to accommodate non-material title changes
that may occur from time to time. For example, the
head of MRM was previously the Executive Director
of MRM, but is currently the Managing Director,
Model Risk Management.
11 Such validations would be governed by two
procedures underlying the MRM Policy (the
Methodology and Model Validation Procedure and
the Methodology and Model Performance
Monitoring Procedure), which OCC provided to
staff as confidential exhibits to File No. SR–OCC–
2023–004.
12 The MRWG assists OCC’s Management
Committee in overseeing and governing OCC’s
model-related risk issues. In addition to the
expansion of responsibilities described here, OCC
proposes to describe the membership of the MRWG
more generally in the MRM Policy than is currently
the case. Based on a review of OCC’s Model Risk
Working Group Procedure, the Commission
VerDate Sep<11>2014
19:33 Jun 23, 2023
Jkt 259001
reviews risk model changes and
determines which should be sent to
OCC’s Management Committee for
further consideration. OCC proposes to
expand the MRWG’s purview to include
review of Risk Methodologies (not just
individual Risk Models).13
C. New Section on Risk Applications
Lastly, OCC proposes to add a new
section regarding the use of Risk
Applications. The current MRM Policy
focuses on OCC’s financial risk
management (i.e., credit risk models,
margin system and related models, and
liquidity risk models).14 The Risk
Applications are tools with quantitative
or mathematical techniques specifically
not focused on financial risk
management. Although the Risk
Applications do not affect OCC’s Risk
Methodologies (or the underlying Risk
Models), the processes for managing the
potential risks are similar, so OCC
proposes to encompass both Risk
Methodologies and Risk Applications in
its Model Risk Management Policy
going forward.15
III. Discussion and Commission
Findings
Section 19(b)(2)(C) of the Exchange
Act directs the Commission to approve
a proposed rule change of a selfregulatory organization if it finds that
such proposed rule change is consistent
with the requirements of the Exchange
Act and the rules and regulations
thereunder applicable to such
organization.16 After carefully
considering the proposed rule change,
the Commission finds that the proposal
understands that the MRM Policy change will not
remove any of the current departments represented
on the MRWG. OCC provided the MRWG Procedure
as a confidential exhibit to File No. SR–OCC–2023–
004.
13 OCC also proposes non-substantive changes
that touch on roles and responsibilities. For
example, OCC’s Chief Financial Risk Officer
(‘‘CFRO’’) has responsibility for reviewing and
approving Risk Model documentation. Currently,
the Policy describes review of documentation as the
responsibility of the CFRO or the CFRO’s delegate.
The proposed Policy would instead describe it as
the responsibility of the CFRO pursuant to OCC’s
Risk Methodology Documentation Procedure.
According to OCC, the change would not result in
any substantive change in the roles and
responsibilities. See Notice of Filing, 88 FR at
31550, n. 10.
14 See Securities Exchange Act Release No. 82785
(Feb. 27, 2018), 83 FR 9345 (Mar. 5, 2018) (File No.
SR–OCC–2017–011) (approving the formalization of
the MRM Policy).
15 The proposed MRM Policy would also note that
OCC uses user developed applications (‘‘UDAs’’),
which are analytical applications designed to
manipulate and analyze data that are used on a
repetitive basis and might expose OCC to Model
Risk, and that the governance for such UDAs is
outlined in OCC’s User Developed Application
Management Procedure.
16 15 U.S.C. 78s(b)(2)(C).
PO 00000
Frm 00084
Fmt 4703
Sfmt 4703
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,17 Rules 17Ad–22(e)(3),
(e)(4), (e)(6), and (e)(7) 18 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 a
clearing agency’s rules are designed to
assure the safeguarding of securities and
funds in custody or control of the
clearing agency or for which it is
responsible.19
The Commission believes that the
proposed change supports OCC’s ability
to safeguard of securities and funds
because the proposed change builds on
the foundation of OCC’s current
processes to provide a more complete
view of model risk at OCC. The MRM
Policy governs OCC’s processes for
reducing model risk. Expanding OCC’s
view of model risk to encompass Risk
Methodologies rather than focusing only
on individual Risk Models in isolation
will give OCC a more comprehensive
understanding of model risk. The
Commission continues to believe that
reducing model risk may allow OCC to
avoid taking non-defaulters’ resources to
manage a default by covering losses and
shortfalls with a defaulter’s collateral.20
Similarly, applying its model risk
management practices to OCC’s Risk
Applications will reduce the likelihood
of loss arising out of decisions based on
those applications.
The Commission believes, therefore,
that the proposal is consistent with the
requirements of Section 17A(b)(3)(F) of
the Exchange Act.
B. Consistency With Rule 17Ad–22(e)(4),
(e)(6), and (e)(7) Under the Exchange
Act
Rules 17Ad–22(e)(4)(vii), (e)(6)(vii)
and (e)(7)(vii) under the Exchange Act
require a covered clearing agency to
establish, implement, maintain, and
enforce written policies and procedures
reasonably designed to, among other
things, require the performance of a
model validation for its credit risk
models, margin system and related
models, and liquidity risk models not
17 15
U.S.C. 78q–1(b)(3)(F).
CFR 240.17Ad–22(e)(3), 17 CFR 240.17Ad–
22(e)(4), 17 CFR 240.17Ad–22(e)(6), and 17 CFR
240.17Ad–22(e)(7).
19 15 U.S.C. 78q–1(b)(3)(F).
20 See Securities Exchange Act Release No. 82785
(Feb. 27, 2018), 83 FR 9345, 9346 (Mar. 5, 2018)
(File No. SR–OCC–2017–011).
18 17
E:\FR\FM\26JNN1.SGM
26JNN1
Federal Register / Vol. 88, No. 121 / Monday, June 26, 2023 / Notices
less than annually, or more frequently
as may be contemplated by the covered
clearing agency’s risk management
framework established pursuant to Rule
17Ad–22(e)(3) under the Exchange
Act.21 The Commission has stated that
a covered clearing agency generally
should consider, in establishing and
maintaining policies and procedures for
margin, whether it regularly reviews
and validates its margin system.22
The Commission previously found the
adoption of the MRM Policy to be
consistent with Rules 17Ad–
22(e)(4)(vii), (e)(6)(vii), and (e)(7)(vii)
under the Exchange Act because the
MRM Policy requires the annual
validations of the performance,
parameters, and assumptions of OCC’s
credit risk, margin, and liquidity risk
models. As described above, OCC
proposes to broaden the scope of the
Policy to contemplate not only
individual Risk Models, but also the
Risk Methodologies such models
comprise. The proposal includes
governance changes that would
facilitate expansion of the Policy’s scope
without reducing the current validation
obligations of OCC’s MRM department.
The Commission believes that
expanding the scope of the MRM Policy
to encompass Risk Methodologies
without weakening the arrangements
governing the validation of individual
Risk Models would strengthen OCC’s
validation of its credit risk models,
margin system and related models, and
liquidity risk models.
The Commission believes, therefore,
that the proposal is consistent with the
requirements of Rules 17Ad–
22(e)(4)(vii), (e)(6)(vii) and (e)(7)(vii)
under the Exchange Act.23
ddrumheller on DSK120RN23PROD with NOTICES1
C. Consistency With Rule 17Ad–22(e)(3)
Under the Exchange Act
Rule 17Ad–22(e)(3)(i) requires, among
other things, that a covered clearing
agency establish, implement, maintain
and enforce written policies and
procedures reasonably designed to
21 17 CFR 240.17Ad–22(e)(4)(vii), (e)(6)(vii) and
(e)(7)(vii). The requirements of Rule 17Ad–22(e)(4)
pertain to the effective identification, measurement,
monitoring, and management of credit exposures.
17 CFR 240.17Ad–22(e)(4). The requirements of
Rule 17Ad–22(e)(6), which apply to a covered
clearing agency that performs central counterparty
services, pertain to the covering of a covered
clearing agency’s credit exposures to its
participants. 17 CFR 240.17Ad–22(e)(6). The
requirements of Rule 17Ad–22(e)(7) pertain to the
effective measurement, monitoring, and
management of liquidity risk. 17 CFR 240.17Ad–
22(e)(7).
22 See Standards for Covered Clearing Agencies,
Securities Exchange Act Release No. 78961 (Sept.
28, 2016), 81 FR 70786, 70819 (Oct. 13, 2016).
23 17 CFR 240.17Ad–22(e)(4)(vii), (e)(6)(vii) and
(e)(7)(vii).
VerDate Sep<11>2014
19:33 Jun 23, 2023
Jkt 259001
maintain a sound risk management
framework for comprehensively
managing legal, credit, liquidity,
operational, general business,
investment, custody, and other risks
that arise in or are borne by the covered
clearing agency, which includes risk
management policies, procedures, and
systems designed to identify, measure,
monitor, and manage the range of risks
that arise in or are borne by the covered
clearing agency, that are subject to
review on a specified periodic basis and
approved by the board of directors
annually.24
Currently, the MRM Policy (and
related risk management processes)
applies to Risk Models, which include
only credit risk models, margin system
and related models, and liquidity risk
models (i.e., financial risk management
models). As proposed, the MRM Policy
would apply to quantitative or
mathematical techniques (i.e., the Risk
Applications) that OCC uses outside of
financial risk management. As a result,
OCC is proposing to apply a consistent
risk management approach to Risk
Methodologies and Risk Applications.
The Commission believes that
broadening the application of risk
management processes to cover models
that deal with both financial risks and
non-financial risks is consistent with
the maintain a sound risk management
framework for comprehensively
managing such risks.
The Commission believes, therefore,
that the proposal is consistent with the
requirements of Rule 17Ad–22(e)(3)(i)
under the Exchange Act.25
VI. 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 26 and
the rules and regulations thereunder.
It is therefore ordered, pursuant to
Section 19(b)(2) of the Exchange Act,27
that the proposed rule change (SR–
OCC–2022–004) be, and hereby is,
approved.
24 17
CFR 240.17Ad–22(e)(3)(i).
CFR 240.17Ad–22(e)(3)(i).
26 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).
27 15 U.S.C. 78s(b)(2).
28 17 CFR 200.30–3(a)(12).
25 17
PO 00000
Frm 00085
Fmt 4703
Sfmt 4703
41455
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.28
J. Matthew DeLesDernier,
Deputy Secretary.
[FR Doc. 2023–13449 Filed 6–23–23; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–97747; File No. SR–NYSE–
2023–23]
Self-Regulatory Organizations; New
York Stock Exchange LLC; Notice of
Filing and Immediate Effectiveness of
Proposed Rule Change To Amend the
Partial Cabinet Solution Bundles
Offered as Part of Its Co-Location
Services
June 16, 2023.
Pursuant to Section 19(b)(1) 1 of the
Securities Exchange Act of 1934
(‘‘Act’’) 2 and Rule 19b–4 thereunder,3
notice is hereby given that on June 5,
2023, New York Stock Exchange LLC
(‘‘NYSE’’ or the ‘‘Exchange’’) filed with
the Securities and Exchange
Commission (the ‘‘Commission’’) the
proposed rule change as described in
Items I and II below, which Items have
been prepared by the self-regulatory
organization. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to amend the
Partial Cabinet Solution bundles offered
as part of its co-location services. The
description of the Partial Cabinet
Solution bundles in the Connectivity
Fee Schedule (‘‘Fee Schedule’’) would
be updated accordingly. The proposed
rule change is available on the
Exchange’s website at www.nyse.com, at
the principal office of the Exchange, and
at the Commission’s Public Reference
Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
self-regulatory organization included
statements concerning the purpose of,
and basis for, the proposed rule change
and discussed any comments it received
on the proposed rule change. The text
1 15
U.S.C. 78s(b)(1).
U.S.C. 78a.
3 17 CFR 240.19b–4.
2 15
E:\FR\FM\26JNN1.SGM
26JNN1
Agencies
[Federal Register Volume 88, Number 121 (Monday, June 26, 2023)]
[Notices]
[Pages 41453-41455]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2023-13449]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-97763; File No. SR-OCC-2023-004]
Self-Regulatory Organizations; The Options Clearing Corporation;
Order Granting Approval of Proposed Rule Change by The Options Clearing
Corporation To Amend and Enhance the Options Clearing Corporation's
Model Risk Management Policy
June 20, 2023.
I. Introduction
On April 27, 2023, the Options Clearing Corporation (``OCC'') filed
with the Securities and Exchange Commission (``Commission'') the
proposed rule change SR-OCC-2023-004 pursuant to Section 19(b) of the
Securities Exchange Act of 1934 (``Exchange Act'') \1\ and Rule 19b-4
\2\ thereunder. The proposed rule change would amend OCC's Model Risk
Management Policy (the ``MRM Policy'' or ``Policy'') to, in part,
broaden the scope of OCC's processes for managing model risk. The
proposed rule change was published for public comment in the Federal
Register on May 17, 2023.\3\ The Commission has received no comments
regarding the proposed rule change.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ Securities Exchange Act Release No. 97484 (May 11, 2023), 88
FR 31549 (May 17, 2023) (File No. SR-OCC-2023-004) (``Notice of
Filing'').
---------------------------------------------------------------------------
II. Background 4
---------------------------------------------------------------------------
\4\ Capitalized terms used but not defined herein have the
meanings specified in OCC's Rules and By-Laws, available at https://www.theocc.com/about/publications/bylaws.jsp.
---------------------------------------------------------------------------
OCC is a central counterparty (``CCP''), which means it interposes
itself as the buyer to every seller and seller to every buyer for
financial transactions. As the CCP for the listed options markets in
the U.S., as well as for certain futures, OCC is exposed to certain
risks arising from its relationships with its members. To manage such
risks, OCC uses quantitative methods to make estimates, forecasts, and
projections in the context of its credit risk models, margin system and
related models, and liquidity risk models (each a ``Risk Model'').\5\
---------------------------------------------------------------------------
\5\ See Securities Exchange Act Release No. 82785 (Feb. 27,
2018), 83 FR 9345 (Mar. 5, 2018) (File No. SR-OCC-2017-011)
(approving the formalization of the MRM Policy).
---------------------------------------------------------------------------
OCC's use of models inherently exposes OCC to model risk, such as
the risk of losses arising out of decisions based on incorrect or
misused model outputs. For example, a model that is not managed
properly could potentially cause OCC to under-collect the collateral
used to cover credit risk posed by a Clearing Member. OCC's MRM Policy
outlines OCC's framework for managing model risk and defines the roles
and responsibilities throughout the risk model and methodology
lifecycle.
Currently, the Policy applies to the Risk Models that OCC uses to
determine, quantify, or measure actual or potential risk exposures or
risk mitigating actions.\6\ The Policy also describes and outlines the
roles and responsibilities of various groups at OCC with regard to
model risk management.\7\ Further, changes to the Policy are subject to
annual review and approval by the Risk Committee of OCC's Board of
Directors.\8\ As described in more detail below, OCC proposes to expand
the application of the Policy to contemplate methodologies comprising
Risk Models and their related inputs and outputs, rather than only
individual Risk Models. To accommodate the expansion of the Policy's
scope beyond individual Risk Models, OCC proposes to revise the roles
and responsibilities described in the MRM Policy. To further broaden
the Policy, OCC proposes adding a new section regarding the use of
tools with quantitative or mathematical techniques not focused on
credit risk models, margin system and related models, and liquidity
risk models (such tools and techniques referred to as ``Risk
Applications'').\9\
---------------------------------------------------------------------------
\6\ See id.
\7\ See id.
\8\ See Notice of Filing, 88 FR at 31552, n. 22.
\9\ OCC also proposes non-material verbiage changes, such as
updating references to internal policies and removing duplicative
definitions. For example, OCC would remove standalone definitions at
the end of the Policy where either the term is defined in the body
of the Policy or is not used in the Policy.
---------------------------------------------------------------------------
A. Expanding From Risk Models to Risk Methodologies
As noted above, OCC proposes to expand the scope of its MRM Policy
to encompass not only individual Risk Models, but also the
methodologies such models comprise. Such ``Risk Methodologies'' include
the related inputs and outputs of OCC's Risk Models, which OCC uses to
estimate or
[[Page 41454]]
compute the distinct aspects of OCC's credit (i.e., Clearing Fund and
margin) and liquidity resources. To effectuate this expansion, OCC
proposes to replace references to Risk Models with references to Risk
Methodologies, and to revise the roles and responsibilities of OCC
staff as described below.
B. OCC Internal Roles and Responsibilities
OCC proposes changes to the roles and responsibilities defined in
its MRM Policy to accommodate the shift in focus from Risk Models to
Risk Methodologies. Such changes include the expansion of the Model
Risk Management (``MRM'') department's responsibilities. MRM would
become responsible for validating both Risk Models and Risk
Methodologies no less than annually.\10\ Further, the proposed Policy
would require MRM, in validating OCC's Risk Methodologies, to review
the performance of each methodology and verify the related software
implementation.\11\ Additionally, certain references to a specific
department would be replaced with references to such department's
parent to encompass a broader set of staff and responsibilities. For
example, discussion of OCC's Quantitative Risk Management (``QRM'')
department's role in monitoring the use and performance of individual
Risk Models would be replaced with discussion of OCC's Financial Risk
Management (``FRM'') department, of which QRM is a part. Similarly, OCC
proposes to expand the responsibilities of the Model Risk Working Group
(``MRWG'') in accordance with the expansion of the MRM Policy.\12\
Currently, the MRWG reviews risk model changes and determines which
should be sent to OCC's Management Committee for further consideration.
OCC proposes to expand the MRWG's purview to include review of Risk
Methodologies (not just individual Risk Models).\13\
---------------------------------------------------------------------------
\10\ Such validations would be performed both prior to
implementation as well as on an ongoing basis to evaluate the
performance of individual Risk Models. Pursuant to the MRM Policy,
OCC requires MRM to validate its Risk Models annually, which OCC
defines as every ``12 months or 365 days.'' The head of MRM would be
responsible for developing and maintain OCC's Annual Model
Validation Plan. OCC proposes to use the more generic ``head of
MRM'' to accommodate non-material title changes that may occur from
time to time. For example, the head of MRM was previously the
Executive Director of MRM, but is currently the Managing Director,
Model Risk Management.
\11\ Such validations would be governed by two procedures
underlying the MRM Policy (the Methodology and Model Validation
Procedure and the Methodology and Model Performance Monitoring
Procedure), which OCC provided to staff as confidential exhibits to
File No. SR-OCC-2023-004.
\12\ The MRWG assists OCC's Management Committee in overseeing
and governing OCC's model-related risk issues. In addition to the
expansion of responsibilities described here, OCC proposes to
describe the membership of the MRWG more generally in the MRM Policy
than is currently the case. Based on a review of OCC's Model Risk
Working Group Procedure, the Commission understands that the MRM
Policy change will not remove any of the current departments
represented on the MRWG. OCC provided the MRWG Procedure as a
confidential exhibit to File No. SR-OCC-2023-004.
\13\ OCC also proposes non-substantive changes that touch on
roles and responsibilities. For example, OCC's Chief Financial Risk
Officer (``CFRO'') has responsibility for reviewing and approving
Risk Model documentation. Currently, the Policy describes review of
documentation as the responsibility of the CFRO or the CFRO's
delegate. The proposed Policy would instead describe it as the
responsibility of the CFRO pursuant to OCC's Risk Methodology
Documentation Procedure. According to OCC, the change would not
result in any substantive change in the roles and responsibilities.
See Notice of Filing, 88 FR at 31550, n. 10.
---------------------------------------------------------------------------
C. New Section on Risk Applications
Lastly, OCC proposes to add a new section regarding the use of Risk
Applications. The current MRM Policy focuses on OCC's financial risk
management (i.e., credit risk models, margin system and related models,
and liquidity risk models).\14\ The Risk Applications are tools with
quantitative or mathematical techniques specifically not focused on
financial risk management. Although the Risk Applications do not affect
OCC's Risk Methodologies (or the underlying Risk Models), the processes
for managing the potential risks are similar, so OCC proposes to
encompass both Risk Methodologies and Risk Applications in its Model
Risk Management Policy going forward.\15\
---------------------------------------------------------------------------
\14\ See Securities Exchange Act Release No. 82785 (Feb. 27,
2018), 83 FR 9345 (Mar. 5, 2018) (File No. SR-OCC-2017-011)
(approving the formalization of the MRM Policy).
\15\ The proposed MRM Policy would also note that OCC uses user
developed applications (``UDAs''), which are analytical applications
designed to manipulate and analyze data that are used on a
repetitive basis and might expose OCC to Model Risk, and that the
governance for such UDAs is outlined in OCC's User Developed
Application Management Procedure.
---------------------------------------------------------------------------
III. Discussion and Commission Findings
Section 19(b)(2)(C) of the Exchange Act directs the Commission to
approve a proposed rule change of a self-regulatory organization if it
finds that such proposed rule change is consistent with the
requirements of the Exchange Act and the rules and regulations
thereunder applicable to such organization.\16\ 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,\17\ Rules 17Ad-22(e)(3),
(e)(4), (e)(6), and (e)(7) \18\ thereunder as described in detail
below.
---------------------------------------------------------------------------
\16\ 15 U.S.C. 78s(b)(2)(C).
\17\ 15 U.S.C. 78q-1(b)(3)(F).
\18\ 17 CFR 240.17Ad-22(e)(3), 17 CFR 240.17Ad-22(e)(4), 17 CFR
240.17Ad-22(e)(6), and 17 CFR 240.17Ad-22(e)(7).
---------------------------------------------------------------------------
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 a clearing agency's rules are designed to assure the
safeguarding of securities and funds in custody or control of the
clearing agency or for which it is responsible.\19\
---------------------------------------------------------------------------
\19\ 15 U.S.C. 78q-1(b)(3)(F).
---------------------------------------------------------------------------
The Commission believes that the proposed change supports OCC's
ability to safeguard of securities and funds because the proposed
change builds on the foundation of OCC's current processes to provide a
more complete view of model risk at OCC. The MRM Policy governs OCC's
processes for reducing model risk. Expanding OCC's view of model risk
to encompass Risk Methodologies rather than focusing only on individual
Risk Models in isolation will give OCC a more comprehensive
understanding of model risk. The Commission continues to believe that
reducing model risk may allow OCC to avoid taking non-defaulters'
resources to manage a default by covering losses and shortfalls with a
defaulter's collateral.\20\ Similarly, applying its model risk
management practices to OCC's Risk Applications will reduce the
likelihood of loss arising out of decisions based on those
applications.
---------------------------------------------------------------------------
\20\ See Securities Exchange Act Release No. 82785 (Feb. 27,
2018), 83 FR 9345, 9346 (Mar. 5, 2018) (File No. SR-OCC-2017-011).
---------------------------------------------------------------------------
The Commission believes, therefore, that the proposal is consistent
with the requirements of Section 17A(b)(3)(F) of the Exchange Act.
B. Consistency With Rule 17Ad-22(e)(4), (e)(6), and (e)(7) Under the
Exchange Act
Rules 17Ad-22(e)(4)(vii), (e)(6)(vii) and (e)(7)(vii) under the
Exchange Act require a covered clearing agency to establish, implement,
maintain, and enforce written policies and procedures reasonably
designed to, among other things, require the performance of a model
validation for its credit risk models, margin system and related
models, and liquidity risk models not
[[Page 41455]]
less than annually, or more frequently as may be contemplated by the
covered clearing agency's risk management framework established
pursuant to Rule 17Ad-22(e)(3) under the Exchange Act.\21\ The
Commission has stated that a covered clearing agency generally should
consider, in establishing and maintaining policies and procedures for
margin, whether it regularly reviews and validates its margin
system.\22\
---------------------------------------------------------------------------
\21\ 17 CFR 240.17Ad-22(e)(4)(vii), (e)(6)(vii) and (e)(7)(vii).
The requirements of Rule 17Ad-22(e)(4) pertain to the effective
identification, measurement, monitoring, and management of credit
exposures. 17 CFR 240.17Ad-22(e)(4). The requirements of Rule 17Ad-
22(e)(6), which apply to a covered clearing agency that performs
central counterparty services, pertain to the covering of a covered
clearing agency's credit exposures to its participants. 17 CFR
240.17Ad-22(e)(6). The requirements of Rule 17Ad-22(e)(7) pertain to
the effective measurement, monitoring, and management of liquidity
risk. 17 CFR 240.17Ad-22(e)(7).
\22\ See Standards for Covered Clearing Agencies, Securities
Exchange Act Release No. 78961 (Sept. 28, 2016), 81 FR 70786, 70819
(Oct. 13, 2016).
---------------------------------------------------------------------------
The Commission previously found the adoption of the MRM Policy to
be consistent with Rules 17Ad-22(e)(4)(vii), (e)(6)(vii), and
(e)(7)(vii) under the Exchange Act because the MRM Policy requires the
annual validations of the performance, parameters, and assumptions of
OCC's credit risk, margin, and liquidity risk models. As described
above, OCC proposes to broaden the scope of the Policy to contemplate
not only individual Risk Models, but also the Risk Methodologies such
models comprise. The proposal includes governance changes that would
facilitate expansion of the Policy's scope without reducing the current
validation obligations of OCC's MRM department. The Commission believes
that expanding the scope of the MRM Policy to encompass Risk
Methodologies without weakening the arrangements governing the
validation of individual Risk Models would strengthen OCC's validation
of its credit risk models, margin system and related models, and
liquidity risk models.
The Commission believes, therefore, that the proposal is consistent
with the requirements of Rules 17Ad-22(e)(4)(vii), (e)(6)(vii) and
(e)(7)(vii) under the Exchange Act.\23\
---------------------------------------------------------------------------
\23\ 17 CFR 240.17Ad-22(e)(4)(vii), (e)(6)(vii) and (e)(7)(vii).
---------------------------------------------------------------------------
C. Consistency With Rule 17Ad-22(e)(3) Under the Exchange Act
Rule 17Ad-22(e)(3)(i) requires, among other things, that a covered
clearing agency establish, implement, maintain and enforce written
policies and procedures reasonably designed to maintain a sound risk
management framework for comprehensively managing legal, credit,
liquidity, operational, general business, investment, custody, and
other risks that arise in or are borne by the covered clearing agency,
which includes risk management policies, procedures, and systems
designed to identify, measure, monitor, and manage the range of risks
that arise in or are borne by the covered clearing agency, that are
subject to review on a specified periodic basis and approved by the
board of directors annually.\24\
---------------------------------------------------------------------------
\24\ 17 CFR 240.17Ad-22(e)(3)(i).
---------------------------------------------------------------------------
Currently, the MRM Policy (and related risk management processes)
applies to Risk Models, which include only credit risk models, margin
system and related models, and liquidity risk models (i.e., financial
risk management models). As proposed, the MRM Policy would apply to
quantitative or mathematical techniques (i.e., the Risk Applications)
that OCC uses outside of financial risk management. As a result, OCC is
proposing to apply a consistent risk management approach to Risk
Methodologies and Risk Applications. The Commission believes that
broadening the application of risk management processes to cover models
that deal with both financial risks and non-financial risks is
consistent with the maintain a sound risk management framework for
comprehensively managing such risks.
The Commission believes, therefore, that the proposal is consistent
with the requirements of Rule 17Ad-22(e)(3)(i) under the Exchange
Act.\25\
---------------------------------------------------------------------------
\25\ 17 CFR 240.17Ad-22(e)(3)(i).
---------------------------------------------------------------------------
VI. 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 \26\ and the rules and regulations thereunder.
---------------------------------------------------------------------------
\26\ 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).
---------------------------------------------------------------------------
It is therefore ordered, pursuant to Section 19(b)(2) of the
Exchange Act,\27\ that the proposed rule change (SR-OCC-2022-004) be,
and hereby is, approved.
---------------------------------------------------------------------------
\27\ 15 U.S.C. 78s(b)(2).
\28\ 17 CFR 200.30-3(a)(12).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\28\
J. Matthew DeLesDernier,
Deputy Secretary.
[FR Doc. 2023-13449 Filed 6-23-23; 8:45 am]
BILLING CODE 8011-01-P