Self-Regulatory Organizations; The Options Clearing Corporation; Order Granting Approval of Proposed Rule Change, as Modified by Partial Amendment No. 1, by The Options Clearing Corporation Concerning Its Process for Adjusting Certain Parameters in Its Proprietary System for Calculating Margin Requirements During Periods When the Products It Clears and the Markets It Serves Experience High Volatility, 710-714 [2024-31610]
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Federal Register / Vol. 90, No. 3 / Monday, January 6, 2025 / Notices
Electronic Comments
• Use the Commission’s internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include file number SR–
ISE–2024–62 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE,
Washington, DC 20549–1090.
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All submissions should refer to file
number SR–ISE–2024–62. This file
number should be included on the
subject line if email is used. To help the
Commission process and review your
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only one method. The Commission will
post all comments on the Commission’s
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rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
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provisions of 5 U.S.C. 552, will be
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For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.58
Stephanie J. Fouse,
Assistant Secretary.
[FR Doc. 2024–31771 Filed 1–3–25; 8:45 am]
BILLING CODE 8011–01–P
58 17
CFR 200.30–3(a)(12).
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SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–102057; File No. SR–OCC–
2024–014]
Self-Regulatory Organizations; The
Options Clearing Corporation; Order
Granting Approval of Proposed Rule
Change, as Modified by Partial
Amendment No. 1, by The Options
Clearing Corporation Concerning Its
Process for Adjusting Certain
Parameters in Its Proprietary System
for Calculating Margin Requirements
During Periods When the Products It
Clears and the Markets It Serves
Experience High Volatility
December 30, 2024.
I. Introduction
On October 1, 2024, the Options
Clearing Corporation (‘‘OCC’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change SR–OCC–2024–
014, pursuant to Section 19(b) of the
Securities Exchange Act of 1934
(‘‘Exchange Act’’) 1 and Rule 19b–4 2
thereunder, to codify OCC’s process for
adjusting certain parameters in its
proprietary system for calculating
margin requirements during periods
when the products OCC clears and the
markets it serves experience high
volatility.3 The proposed rule change, as
modified by Partial Amendment No. 1
(hereinafter, the ‘‘Proposed Rule
Change’’) was published for public
comment in the Federal Register on
October 9, 2024.4 The Commission has
received no comments regarding the
Proposed Rule Change.
On November 21, 2024, pursuant to
Section 19(b)(2) of the Exchange Act,5
the Commission designated a longer
period within which to approve,
disapprove, or institute proceedings to
determine whether to disapprove the
Proposed Rule Change.6 For the reasons
discussed below, the Commission is
approving the Proposed Rule Change.
II. Background 7
OCC is a central counterparty
(‘‘CCP’’), which means that as part of its
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Notice of Filing infra note 4, at 89 FR 81958.
4 See Securities Exchange Act Release No. 101246
(Oct. 3, 2024), 89 FR 81958 (Oct. 9, 2024) (File No.
SR–OCC–2024–014) (‘‘Notice of Filing’’).
5 15 U.S.C. 78s(b)(2).
6 See Securities Exchange Act Release No. 101684
(Nov. 21, 2024), 89 FR 93693 (Nov. 27, 2024) (File
No. SR–OCC–2024–014).
7 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
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function as a clearing agency, it
interposes itself as the buyer to every
seller and the seller to every buyer for
financial transactions. As the CCP for
the listed options markets and for
certain futures in the United States,
OCC is exposed to the risk that one or
more of its Clearing Members may fail
to make a payment or to deliver
securities. OCC addresses such risk
exposure, in part, by requiring its
Clearing Members to provide collateral,
including margin collateral. Margin is
the collateral that CCPs collect to cover
potential changes in a member’s
positions over a set period of time.
Typically, margin is designed to cover
such exposures during normal market
conditions, which means that margin
collateral should be sufficient to cover
exposures at least 99 out of 100 days.8
OCC’s methodology for calculating
margin collateral—including daily and
intra-day margin requirements for
Clearing Members—is a collection of
margin models collectively called the
System for Theoretical Analysis and
Numerical Simulations (‘‘STANS’’). The
STANS Methodology Description is a
document that comprehensively
describes the material aspects of OCC’s
risk-based margin system, including its
approach for calculating daily and intraday margin requirements for its Clearing
Members.9
As a collection of models, STANS is
subject to assumptions and limitations
that are incorporated into STANS as
margin model parameters. For example,
OCC has a price return model that
employs bounds, or ‘‘control sets’’ that
are implemented under either regular or
high volatility settings, for certain
parameters that are calculated daily
based on current market data.10 OCC
maintains authority under its rules to
adjust member margin requirements to
protect the respective interests of OCC,
its Clearing Members, and the public.
OCC has established an exception
process for implementing, changing,
and terminating certain of these margin
model parameters in STANS to control
margin requirements where such
parameters cause STANS to produce
inappropriate margin requirements
8 See Securities Exchange Act Release No. 78961
(Sep. 28, 2016), 81 FR 70786, 70819 (Oct. 13, 2016)
(‘‘Standards for Covered Clearing Agencies’’)
(stating that a covered clearing agency generally
should consider, among other things, ‘‘whether
initial margin meets an established single-tailed
confidence level of at least 99 percent with respect
to the estimated distribution of future exposure[.]’’).
9 See Securities Exchange Act Release No. 91079
(Feb. 8, 2021), 86 FR 9410 (Feb. 12, 2021) (File No.
SR–OCC–2020–016) (‘‘STANS Methodology
Approval’’).
10 See Notice of Filing, notes 25–28 (describing
the parameters to which bounds are applied).
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during periods of heightened volatility
(the ‘‘high-volatility parameter
controls’’). While the STANS
Methodology Description currently
includes a brief discussion of the highvolatility parameter controls that OCC
uses,11 it does not provide a detailed
description of OCC’s actual process and
governance for implementing, changing,
and terminating the high-volatility
parameter controls. As such, OCC is
filing the Proposed Rule Change to
codify and describe more fully in the
STANS Methodology Description its
process and governance surrounding the
high-volatility parameter controls.
More specifically, OCC proposes to
amend its existing Margin Policy to
include material details regarding its
high-volatility parameter control setting
process.12 Although the Proposed Rule
Change would amend OCC’s Margin
Policy, OCC states that the proposal
does not significantly change OCC’s
existing high-volatility parameter
control setting practices,13 which OCC
indicates have been in use since at least
2020.14
Proposed additions to the Margin
Policy describing OCC’s exception
process for setting high-volatility
parameter controls include the
following: (1) setting and reviewing
regular and high-volatility parameter
control settings; (2) monitoring the
volatility of products being cleared and
markets served, and establishing
thresholds to escalate the results of such
monitoring to senior decisionmakers;
and (3) internal governance for
implementing and terminating highvolatility parameter control settings.
11 In the initial rule filing to introduce the STANS
Methodology Description, OCC included a brief
description of the high-volatility parameter controls
discussion. See Securities Exchange Act Release
No. 90763 (Dec. 21, 2020), 85 FR 85788, 85793 (Dec.
29, 2020) (File No. SR–OCC–2020–016) (‘‘The
STANS Methodology Description would also
describe the controls that may be placed on the
GJR–GARCH parameters after their initial
calibration. GARCH volatility forecasting models
can be very reactive in certain market
environments. As a result, OCC may implement
parameter controls for risk factors and classes of
risk factors, which are subject to periodic review
and approval by the [Model Risk Working
Group].’’).
12 OCC also intends to update its internal Margin
Setting and Maintenance procedure (Exhibit 3F to
the Proposed Rule Change) to provide greater detail
about its high-volatility parameter control process.
13 See Notice of Filing, 89 FR 81959.
14 See id. at 81961–62 (describing an instance
when OCC applied the idiosyncratic control
settings in 2021). Additionally, various exhibits to
File No. SR–OCC–2024–014 indicate OCC’s use of
high-volatility parameter control settings since
2020. For example, confidential Exhibit B to that
filing, which is an internal OCC memorandum
addressing high-volatility parameter control
settings, describes an instance on March 9, 2020
when OCC implemented the global control settings.
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The three sets of changes to OCC’s
Margin Policy are described in further
detail below.
A. Setting and Reviewing Regular and
High-Volatility Parameter Control
Settings
STANS uses large-scale Monte Carlo
simulations to calculate the margin
requirements of OCC’s Clearing
Members. The methodology includes
econometric models that incorporate a
number of risk factors.15 One of these
econometric models, GARCH, is used to
estimate the volatility of equity
securities based on historical data. Over
time, OCC has observed that the margin
requirements produced by its GARCH
model are strongly reactive to market
movements and are considered to be
‘‘procyclical’’—meaning that changes in
margin requirements produced by the
GARCH model may be positively
correlated with the overall state of the
market. OCC states that such
procyclicality could inflate the margin
requirements of OCC’s Clearing
Members beyond the related risk posed
by Clearing Members’ positions if it is
not addressed during high-volatility
periods in the market, and would
potentially threaten the operational
stability of those Clearing Members.16
As part of its current practice, OCC
applies high-volatility parameter control
settings to constrain the GARCH
parameters temporarily during periods
of high market volatility. OCC’s price
return model uses upper and lower
bounds for parameters calculated daily
based on market data. OCC’s highvolatility parameter control settings
consist of parameters that are bounded
differently than regular control settings.
These high-volatility parameter control
settings, when applied to GARCH
parameters after their initial calibration,
mitigate the reactivity of the model
15 OCC defines a risk factor in STANS as a
product or attribute whose historical data is used
to estimate and simulate the risk for an associated
product. The majority of risk factors utilized in
STANS are the returns on individual equity
securities.
16 See Notice of Filing, 89 FR 81960. For example,
OCC states that its GARCH model produced
forecasts for particular S&P 500 Index (‘‘SPX’’)
options that were four-fold larger than the
comparable market index, leading to margin
requirement increasing by 80% overnight, with
some margin requirements increasing ten-fold. Id.
OCC has attempted a number of approaches to
mitigate the impact of procyclicality, including
changes to its GARCH model. See Securities
Exchange Act Release No. 84879 (Dec. 20, 2018), 83
FR 67392, 67393 (Dec. 28, 2018) (File No. SR–OCC–
2018–014). OCC has also developed a new model
to replace GARCH for simulating implied volatility
for SPX-based options and volatility index futures.
See Securities Exchange Act Release No. 95319
(July 19, 2022), 87 FR 44167 (July 25, 2022) (File
No. SR–OCC–2022–001).
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711
volatility forecast and, in turn, generally
prevent significant overestimation of
Clearing Members’ margin
requirements.17 Depending on the
circumstances, OCC may apply control
settings to individual risk factors (i.e.,
‘‘idiosyncratic control settings’’), or to
all or a class of risk factors (i.e., ‘‘global
control settings’’).18
As part of the Proposed Rule Change,
OCC proposes to amend its Margin
Policy to describe the current exception
process for setting and reviewing both
regular and high-volatility parameter
control settings. Specifically, the
proposed addition to the Margin Policy
would state that GARCH parameters
may be temporarily constrained through
the application of idiosyncratic or global
control settings. The added language
would state that OCC’s Financial Risk
Management team (‘‘FRM’’) maintains
both regular and high-volatility
parameter control sets, which it reviews
on an at-least annual basis. FRM’s
review of the high-volatility parameter
control sets assesses whether they
effectively mitigate procyclicality while
remaining appropriately risk-based. The
new Margin Policy language would
further state that OCC’s Model Risk
Working Group (‘‘MRWG’’) must
approve any changes to the regular or
high-volatility sets. The Proposed Rule
Change would also provide further
detail on the review of both regular and
high-volatility parameter control sets.19
These proposed changes to the Margin
Policy describe current OCC processes
that will remain unchanged.
17 See Notice of Filing, 89 FR 81959. OCC also
provides detailed examples in which high-volatility
parameter control settings were implemented. Id. at
81962, notes 41–42.
18 When OCC implements global control settings
for a class or sector of risk factors, it is OCC’s
practice to blend the high volatility and regular
control settings based on a weighted percentage
between them. See Notice of Filing, 89 FR 81961.
Such a ‘‘blended’’ or ‘‘weighted’’ approach allows
OCC’s risk managers, when appropriate, to select
bounds that provide more conservative margin
coverage when applying high volatility control
settings globally across multiple risk factors. See id.
19 The proposed language states that in the case
of the regular control set, the review assesses
whether the GARCH parameter bounds are
appropriately risk-based, including but not limited
to assessing whether they align with the 95th
percentile of the parameter calibrations over the
prior review period; and, in the case of the highvolatility parameter control sets, the review assesses
whether they effectively mitigate procyclicality
while remaining appropriately risk-based, including
but not limited to whether the bounds keep the dayover-day change in 2-day expected shortfall
coverage within a factor of approximately 1.5,
assuming price shocks based on observed returns
for top risk factors.
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B. Monitoring Volatility of Products and
Markets Served
As part of the Proposed Rule Change,
OCC proposes to amend the Margin
Calls and Adjustments section of the
Margin Policy to include details about
how OCC currently sets volatility
controls. Specifically, the new Control
Setting details would include
information about OCC’s current use of
certain monitoring thresholds related to
high market volatility, low market
liquidity, and significant increases in
position size or concentration (‘‘CCA
Monitoring Thresholds’’).20 The new
details would state that the Quantitative
Risk Management (‘‘QRM’’) team,21 in
collaboration with Stress Testing and
Liquidity Risk Management, will
perform a review of the CCA Monitoring
Thresholds to ensure that they remain
adequate to identify periods of high
market volatility, low market liquidity,
and significant increases in position size
or concentration. Moreover, the new
language would state that any changes
to the CCA Monitoring Thresholds must
be approved by the MRWG and the
Stress Testing Working Group.
OCC also proposes to amend the
Margin Calls and Adjustments section to
state that QRM shall perform a monthly
sensitivity analysis of the margin model,
but may review more frequently when
CCA Monitoring Thresholds are
breached.
These proposed changes to the Margin
Policy describe current OCC processes
that will remain unchanged.
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C. Internal Governance for
Implementing and Terminating HighVolatility Parameter Controls
As part of the Proposed Rule Change,
OCC proposes to amend its Margin
Policy to include details about its
current internal governance process for
implementing and terminating highvolatility parameter control settings.
The new Margin Policy details would
include descriptions of both
idiosyncratic and global control settings,
and the circumstances under which
these settings may be used.
For example, for global control
settings, FRM monitors market volatility
on a daily basis, and escalates to the
MRWG if a market volatility threshold
20 The establishment of these CCA Monitoring
Thresholds is described in OCC’s internal Clearing
Fund Methodology Policy and its internal Stress
Test Reporting Procedure.
21 FRM is the parent department of QRM, which
is responsible for, among other things, monitoring
the use and performance of risk models according
to relevant procedures, maintaining risk tolerances
and associated key risk indicators to measure and
monitor risk models. See Securities Exchange Act
Release No. 97484 (May 11, 2023), 88 FR 31549,
31550 (May 17, 2023) (File No. SR–OCC–2023–004).
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is exceeded. As part of the escalation to
the MRWG, FRM recommends whether
global control settings should be applied
to all risk factors or to a class of risk
factors. MRWG approval is required for
OCC to implement global control
settings, and for OCC to revert back to
regular control settings.22
Meanwhile, for idiosyncratic control
settings, FRM monitors securities
against thresholds for idiosyncratic
price moves.23 These thresholds may be
a tiered structure that takes into account
the type and magnitude of OCC’s risk
exposure to the security, the value of the
security, the magnitude of the price
move, and the coverage rates. When an
idiosyncratic threshold is breached,
FRM Officer approval is required for
any implementation of idiosyncratic
control settings for an individual risk
factor. An FRM Officer may also
approve idiosyncratic control settings
based on additional considerations,
including market moves, expected
shortfall risk contribution, and changes
in Clearing Member positions.
Generally, the FRM Officer will approve
the reversion back to regular control
settings once market volatility lessens,
but in exceptional circumstances, the
FRM Officer has the discretion to apply
the idiosyncratic control settings for a
longer or shorter period of time.
The new language in the Margin
Policy would also state that changes to
the idiosyncratic thresholds require
MRWG approval.
These proposed changes to the Margin
Policy describe current OCC processes
that will remain unchanged.
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.24 Under the Commission’s
22 When OCC implements global control settings,
MRWG evaluates and selects a control setting with
different weightings between the regular control set
and high-volatility parameter control set based on
an assessment of which blended approach generates
a coverage level that converges with the implied
volatility of the SPX. Factors that the MRWG
considers when determining whether to revert to
regular control settings include, but are not limited
to, whether SPX coverage rates produced under
regular control settings have converged with the
initial coverage rates when the global control
settings were first implemented. See Notice of
Filing, 89 FR 81961.
23 These ‘‘idiosyncratic thresholds’’ are defined in
OCC’s internal Margin Setting and Maintenance
Procedure. OCC included a copy of this procedure
as Exhibit 3F for the Proposed Rule Change.
24 15 U.S.C. 78s(b)(2)(C).
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Rules of Practice, the ‘‘burden to
demonstrate that a proposed rule change
is consistent with the Exchange Act and
the rules and regulations issued
thereunder . . . is on the self-regulatory
organization [‘SRO’] that proposed the
rule change.’’ 25
The description of a proposed rule
change, its purpose and operation, its
effect, and a legal analysis of its
consistency with applicable
requirements must all be sufficiently
detailed and specific to support an
affirmative Commission finding,26 and
any failure of an SRO to provide this
information may result in the
Commission not having a sufficient
basis to make an affirmative finding that
a proposed rule change is consistent
with the Exchange Act and the
applicable rules and regulations.27
Moreover, ‘‘unquestioning reliance’’ on
an SRO’s representations in a proposed
rule change is not sufficient to justify
Commission approval of a proposed rule
change.28
After carefully considering the
Proposed Rule Change, the Commission
finds that the Proposed Rule Change 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 Proposed Rule Change is
consistent with Section 17A(b)(3)(F) of
the Exchange Act 29 and Rules 17Ad–
22(e)(2) 30 and 17Ad–22(e)(6) 31
thereunder, as described in detail
below.
A. Consistency With Section
17A(b)(3)(F) of the Exchange Act
Section 17A(b)(3)(F) of the Exchange
Act requires, among other things, that
the rules of a clearing agency be
designed to assure the safeguarding of
securities and funds which are in the
custody or control of the clearing agency
or for which it is responsible.32 Based
on the review of the record, and for the
reasons described below, OCC’s
proposed update to its Margin Policy in
the manner described above is
consistent with the safeguarding of
securities and funds which are in OCC’s
custody or control or for which it is
responsible.
25 Rule 700(b)(3), Commission Rules of Practice,
17 CFR 201.700(b)(3).
26 Id.
27 Id.
28 Susquehanna Int’l Group, LLP v. Securities and
Exchange Commission, 866 F.3d 442, 447 (D.C. Cir.
2017).
29 15 U.S.C. 78q-1(b)(3)(F).
30 17 CFR 240.17Ad–22(e)(2).
31 17 CFR 240.17Ad–22(e)(6).
32 15 U.S.C. 78q–1(b)(3)(F).
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OCC’s high-volatility parameter
control settings provide an exception
handling process for OCC to correct for
procyclicality effects on the GARCH
model calculation that may
unreasonably inflate Clearing Members’
margin requirements during periods of
high market volatility.33 The
idiosyncratic control settings allow OCC
to adjust Clearing Member margin
requirements to be commensurate with
the risk of the products, portfolios, or
markets when an individual risk factor
becomes volatile (e.g., reflecting genuine
changes in the risk of the Clearing
Member’s products or portfolio, or the
markets), rather than allowing the
Clearing Member’s margin requirement
to diverge from observed market
dynamics based on the reactivity of
OCC’s GARCH model. The global
control settings offer the same benefit
for periods during which all or a class
of risk factors becomes volatile.
Therefore, by setting and reviewing
high-volatility parameter control
settings, OCC is able to reduce the
likelihood that Clearing Members would
become operationally unstable or,
potentially, default as the result of
unreasonably high margin calls. This in
turn further assures the safeguarding of
Clearing Members’ collateral by
reducing the likelihood that OCC would
be forced to charge losses from a
defaulting Clearing Member to the
Clearing Fund.
OCC’s use of CCA Monitoring
Thresholds to monitor for market
volatility is also consistent with the
safeguarding of securities and funds
which are in OCC’s custody or control
or for which it is responsible. The CCA
Monitoring Thresholds are set and used
for FRM to detect both high market
volatility generally and high volatility of
individual risk factors. When FRM
observes that any of these thresholds are
exceeded, FRM determines whether or
not to recommend that OCC’s highvolatility parameter control settings be
implemented—either to MRWG that
global controls should be implemented
for market-wide volatility, or to the FRM
Officer that idiosyncratic controls
should be implemented for
idiosyncratic volatility. OCC’s
monitoring and proper setting of these
thresholds helps to lower the chances of
a Clearing Member default resulting
from margin calls that are significantly
higher than necessary to account for the
risk presented by the Clearing Member’s
33 Examples of unreasonably inflated margin
requirements were included in backtesting data and
analysis provided as part of OCC’s confidential
Exhibit 3C to File No. SR–OCC–2024–014. See
Notice of Filing, 89 FR 81962, note 43.
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products, portfolio, or the market, and
thus assures the safeguarding of
Clearing Members’ collateral from any
loss charges to OCC’s Clearing Fund.
The high-volatility parameter control
setting practices described in the
Proposed Rule Change are designed to
ensure that Clearing Member margin
requirements remain commensurate
with market risk in circumstances when
the margin model reacts unreasonably to
high market volatility. Indeed, the
confidential backtesting data that OCC
provided to the Commission 34 shows
that no account level exceedance has
been attributed to OCC’s
implementation of high-volatility
parameter control settings. Thus, the
application of the high-volatility
parameter control settings does not
appear to have reduced OCC’s ability to
cover the risk posed by Clearing
Members’ positions. Additionally, the
confidential information regarding
model backtesting provided by OCC and
reviewed by the Commission
demonstrates that, overall, the use of
high-volatility parameter control
settings has not prevented OCC from
maintaining a 2-day expected shortfall
coverage level of 99%.35 This
demonstrates that, even with the use of
the high-volatility parameter control
settings, OCC’s margin collateral
remains sufficient to cover exposures at
least 99 out of 100 days, as discussed
above.36
For the foregoing reasons, the
Proposed Rule Change is consistent
with the requirements of Section
17A(b)(3)(F) of the Exchange Act.37
B. Consistency with Rule 17Ad–22(e)(2)
under the Exchange Act
Rule 17Ad-22(e)(2) under the
Exchange Act requires that a covered
clearing agency establish, implement,
maintain and enforce written policies
and procedures reasonably designed to,
as applicable, provide for governance
arrangements that, among other things,
specify clear and direct lines of
responsibility.38 Based on the review of
the record, and for the reasons described
below, OCC’s proposed update to its
Margin Policy in the manner described
34 As stated in the Margin Policy, OCC monitors
margin sufficiency by using its ‘‘business
backtesting’’ process for monitoring account
exceedances. OCC has provided responses to
Commission requests for backtesting data and
analysis as part of its confidential Exhibit 3C to File
No. SR–OCC–2024–014. See Notice of Filing, 89 FR
81962, note 43.
35 Notice of Filing, 89 FR 81962.
36 See supra note 8.
37 15 U.S.C. 78q–1(b)(3)(F).
38 17 CFR 240.17Ad–22(e)(2)(v).
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Sfmt 4703
713
above is consistent with Rule 17Ad–
22(e)(2)(v).
OCC’s amendments to its Margin
Policy describe the the arrangements
governing the implemention,
modification, and termination of highvolatility parameter controls. Defining
the MRWG, QRM, FRM, and FRM
Officer’s roles and responsibilities in
these processes specifies clear and
direct lines of responsibility.
Specifically, the added language to the
Margin Policy describes the role of FRM
in monitoring for both market and
idiosyncratic volatility. It also describes
the FRM’s direct line of responsibility to
either the MRWG for global control
settings or the FRM Officer for
idiosyncratic control settings, as well as
the roles of MRWG and the FRM Officer
in approving the eventual reversion
back to regular control settings.
For the foregoing reasons, the
Proposed Rule Change is consistent
with Rule 17Ad–22(e)(2) under the
Exchange Act.39
C. Consistency With Rule 17Ad–22(e)(6)
Under the Exchange Act
Rule 17Ad–22(e)(6) under the
Exchange Act requires that a covered
clearing agency establish, implement,
maintain, and enforce written policies
and procedures reasonably designed to
cover, if the covered clearing agency
provides central counterparty services,
its credit exposures to its participants by
establishing a risk-based margin system
that, among other things, (1) considers,
and produces margin levels
commensurate with, the risks and
particular attributes of each relevant
product, portfolio, and market 40 and (2)
calculates sufficient margin to cover its
potential future exposure to participants
in the interval between the last margin
collection and the close out of positions
following a participant default.41 Based
on the review of the record, and for the
reasons described below, OCC’s
proposed update to its Margin Policy in
the manner described above is
consistent with Rule 17Ad–22(e)(6).
As described above, the highvolatility parameter control settings
provide a necessary exception process
allowing OCC to mitigate a limitation of
its GARCH models that have
demonstrated extreme sensitivity to
sudden spikes in volatility. Such
reactivity can produce instability, and
in certain instances, over- or
underestimation of margin
39 17
CFR 240.17Ad–22(e)(2).
CFR 240.17Ad–22(e)(6)(i).
41 17 CFR 240.17Ad–22(e)(6)(iii).
40 17
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Federal Register / Vol. 90, No. 3 / Monday, January 6, 2025 / Notices
requirements.42 The confidential
backtesting data that OCC provided to
the Commission has shown that during
instances of market volatility where
OCC has employed either the
idiosyncratic control settings or the
global control settings, the control
settings have limited Clearing Member
margin requirements to be
commensurate with market risk by
countering procyclicality effects, while
still ensuring that OCC is collecting
appropriate margin to cover its exposure
to relevant products, portfolios, and
markets.43 Ensuring that OCC maintains
processes to counter procyclicality, in
turn, allows for reduced margin
requirements that, as described above,
do not degrade backtesting coverage.
Therefore, OCC is still able to calculate
sufficient margin, while limiting the
need for ‘‘destabilizing, procyclical
changes.’’ 44 Further, including such
high-volatility parameter control
settings reduces the likelihood that
Clearing Members would be required to
provide additional financial resources
unnecessarily, which, in turn, could
reduce the strain on such Clearing
Members during stressed market
conditions.
Accordingly, the Proposed Rule
Change is consistent with Rule 17Ad–
22(e)(6) under the Exchange Act.45
IV. Conclusion
On the basis of the foregoing, the
Commission finds that the Proposed
Rule Change is consistent with the
requirements of the Exchange Act, and
in particular, the requirements of
Section 17A of the Exchange Act 46 and
the rules and regulations thereunder.
It is therefore ordered, pursuant to
Section 19(b)(2) of the Exchange Act,47
that the proposed rule change, as
modified by Partial Amendment No. 1
(SR–OCC–2024–014), be, and hereby is,
approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.48
Stephanie J. Fouse,
Assistant Secretary.
[FR Doc. 2024–31610 Filed 1–3–25; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–102054; File No. SR–LTSE–
2024–11]
Self-Regulatory Organizations; LongTerm Stock Exchange, Inc.; Notice of
Filing and Immediate Effectiveness of
Proposed Rule Change To Establish
Fees for Industry Members Related to
Reasonably Budgeted CAT Costs of
the National Market System Plan
Governing the Consolidated Audit Trail
for 2025
December 30, 2024.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that on December
20, 2024, Long-Term Stock Exchange,
Inc. (‘‘Exchange’’) filed with the
Securities and Exchange Commission
(‘‘Commission’’) the proposed rule
change as described in Item I below,
which Item has been substantially
prepared by the Exchange. The
Exchange has designated this proposal
for immediate effectiveness pursuant to
Section 19(b)(3)(A) of the Act 3 and Rule
19b–4(f) thereunder.4 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 a rule change
to establish fees for Industry Members 5
48 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 15 U.S.C. 78s(b)(3)(A).
4 17 CFR 240.19b–4(f). At any time within 60 days
of the filing of the proposed rule change, the
Commission summarily may temporarily suspend
such rule change if it appears to the Commission
that such action is necessary or appropriate in the
public interest, for the protection of investors, or
otherwise in furtherance of the purposes of the Act.
If the Commission takes such action, the
Commission will institute proceedings to determine
whether the proposed rule change should be
approved or disapproved.
5 An ‘‘Industry Member’’ is defined as ‘‘a member
of a national securities exchange or a member of a
national securities association.’’ See LTSE Rule
11.610(u). See also Section 1.1 of the CAT NMS
Plan. Unless otherwise specified, capitalized terms
used in this rule filing are defined as set forth in
the CAT NMS Plan and/or the CAT Compliance
Rule. See Exchange Rule Series 11.600.
khammond on DSK9W7S144PROD with NOTICES
1 15
42 For example, OCC’s 2018 model would have
increased aggregate margin requirements by 80
percent overnight in response to increased volatility
observed on February 5, 2018. OCC stated that it
believed that these margin requirements were
unreasonable and procyclical. See Notice of Filing,
89 FR 81960; Securities Exchange Act Release No.
84879, at 83 FR 67392, 67393.
43 OCC has provided responses to Commission
requests for backtesting data and analysis as part of
its confidential Exhibit 3C to File No. SR–OCC–
2024–014. See Notice of Filing, 89 FR 81962, note
43.
44 See Standards for Covered Clearing Agencies,
81 FR 70819.
45 17 CFR 240.17Ad–22(e)(6).
46 In approving the Proposed Rule Change, the
Commission has considered the proposed rule’s
impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
47 15 U.S.C. 78s(b)(2).
VerDate Sep<11>2014
19:04 Jan 03, 2025
Jkt 265001
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Frm 00132
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related to reasonably budgeted CAT
costs of the National Market System
Plan Governing the Consolidated Audit
Trail for 2025.
The proposed rule change, including
the Exchange’s statement of the purpose
of, and statutory basis for, the proposed
rule change, is available on the
Exchange’s website at https://longterm
stockexchange.com/, at the principal
office of the Exchange, and on the
Commission’s website at https://
www.sec.gov/rules-regulations/selfregulatory-organization-rulemaking/
national-securities-exchanges?file_
number=SR-LTSE-2024-11.
II. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.6
Comments may be submitted
electronically by using the
Commission’s internet comment form
(https://www.sec.gov/rules-regulations/
self-regulatory-organizationrulemaking/national-securitiesexchanges?file_number=SR-LTSE-202411) or by sending an email to rulecomments@sec.gov. Please include file
number SR–LTSE–2024–11 on the
subject line. Alternatively, paper
comments may be sent to Secretary,
Securities and Exchange Commission,
100 F Street NE, Washington, DC
20549–1090. All submissions should
refer to file number SR–LTSE–2024–11.
To help the Commission process and
review your comments more efficiently,
please use only one method. The
Commission will post all comments on
the Commission’s internet website
(https://www.sec.gov/rules-regulations/
self-regulatory-organizationrulemaking/national-securitiesexchanges?file_number=SR-LTSE-202411). Do not include personal identifiable
information in submissions; you should
submit only information that you wish
to make available publicly. We may
redact in part or withhold entirely from
publication submitted material that is
obscene or subject to copyright
protection. All submissions should refer
6 Copies of the submission, all subsequent
amendments, all written statements with respect to
the proposed rule change that are filed with the
Commission, and all written communications
relating to the proposed rule change between the
Commission and any person, other than those that
may be withheld from the public in accordance
with the provisions of 5 U.S.C. 552, will be
available for website viewing and printing in the
Commission’s Public Reference Room, 100 F Street
NE, Washington, DC 20549, on official business
days between the hours of 10 a.m. and 3 p.m.
Copies of the filing also will be available for
inspection and copying at the principal office of
SRO.
E:\FR\FM\06JAN1.SGM
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Agencies
[Federal Register Volume 90, Number 3 (Monday, January 6, 2025)]
[Notices]
[Pages 710-714]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2024-31610]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-102057; File No. SR-OCC-2024-014]
Self-Regulatory Organizations; The Options Clearing Corporation;
Order Granting Approval of Proposed Rule Change, as Modified by Partial
Amendment No. 1, by The Options Clearing Corporation Concerning Its
Process for Adjusting Certain Parameters in Its Proprietary System for
Calculating Margin Requirements During Periods When the Products It
Clears and the Markets It Serves Experience High Volatility
December 30, 2024.
I. Introduction
On October 1, 2024, the Options Clearing Corporation (``OCC'')
filed with the Securities and Exchange Commission (``Commission'') the
proposed rule change SR-OCC-2024-014, pursuant to Section 19(b) of the
Securities Exchange Act of 1934 (``Exchange Act'') \1\ and Rule 19b-4
\2\ thereunder, to codify OCC's process for adjusting certain
parameters in its proprietary system for calculating margin
requirements during periods when the products OCC clears and the
markets it serves experience high volatility.\3\ The proposed rule
change, as modified by Partial Amendment No. 1 (hereinafter, the
``Proposed Rule Change'') was published for public comment in the
Federal Register on October 9, 2024.\4\ 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\ See Notice of Filing infra note 4, at 89 FR 81958.
\4\ See Securities Exchange Act Release No. 101246 (Oct. 3,
2024), 89 FR 81958 (Oct. 9, 2024) (File No. SR-OCC-2024-014)
(``Notice of Filing'').
---------------------------------------------------------------------------
On November 21, 2024, pursuant to Section 19(b)(2) of the Exchange
Act,\5\ the Commission designated a longer period within which to
approve, disapprove, or institute proceedings to determine whether to
disapprove the Proposed Rule Change.\6\ For the reasons discussed
below, the Commission is approving the Proposed Rule Change.
---------------------------------------------------------------------------
\5\ 15 U.S.C. 78s(b)(2).
\6\ See Securities Exchange Act Release No. 101684 (Nov. 21,
2024), 89 FR 93693 (Nov. 27, 2024) (File No. SR-OCC-2024-014).
---------------------------------------------------------------------------
II. Background \7\
---------------------------------------------------------------------------
\7\ 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 that as part
of its function as a clearing agency, it interposes itself as the buyer
to every seller and the seller to every buyer for financial
transactions. As the CCP for the listed options markets and for certain
futures in the United States, OCC is exposed to the risk that one or
more of its Clearing Members may fail to make a payment or to deliver
securities. OCC addresses such risk exposure, in part, by requiring its
Clearing Members to provide collateral, including margin collateral.
Margin is the collateral that CCPs collect to cover potential changes
in a member's positions over a set period of time. Typically, margin is
designed to cover such exposures during normal market conditions, which
means that margin collateral should be sufficient to cover exposures at
least 99 out of 100 days.\8\ OCC's methodology for calculating margin
collateral--including daily and intra-day margin requirements for
Clearing Members--is a collection of margin models collectively called
the System for Theoretical Analysis and Numerical Simulations
(``STANS''). The STANS Methodology Description is a document that
comprehensively describes the material aspects of OCC's risk-based
margin system, including its approach for calculating daily and intra-
day margin requirements for its Clearing Members.\9\
---------------------------------------------------------------------------
\8\ See Securities Exchange Act Release No. 78961 (Sep. 28,
2016), 81 FR 70786, 70819 (Oct. 13, 2016) (``Standards for Covered
Clearing Agencies'') (stating that a covered clearing agency
generally should consider, among other things, ``whether initial
margin meets an established single-tailed confidence level of at
least 99 percent with respect to the estimated distribution of
future exposure[.]'').
\9\ See Securities Exchange Act Release No. 91079 (Feb. 8,
2021), 86 FR 9410 (Feb. 12, 2021) (File No. SR-OCC-2020-016)
(``STANS Methodology Approval'').
---------------------------------------------------------------------------
As a collection of models, STANS is subject to assumptions and
limitations that are incorporated into STANS as margin model
parameters. For example, OCC has a price return model that employs
bounds, or ``control sets'' that are implemented under either regular
or high volatility settings, for certain parameters that are calculated
daily based on current market data.\10\ OCC maintains authority under
its rules to adjust member margin requirements to protect the
respective interests of OCC, its Clearing Members, and the public. OCC
has established an exception process for implementing, changing, and
terminating certain of these margin model parameters in STANS to
control margin requirements where such parameters cause STANS to
produce inappropriate margin requirements
[[Page 711]]
during periods of heightened volatility (the ``high-volatility
parameter controls''). While the STANS Methodology Description
currently includes a brief discussion of the high-volatility parameter
controls that OCC uses,\11\ it does not provide a detailed description
of OCC's actual process and governance for implementing, changing, and
terminating the high-volatility parameter controls. As such, OCC is
filing the Proposed Rule Change to codify and describe more fully in
the STANS Methodology Description its process and governance
surrounding the high-volatility parameter controls.
---------------------------------------------------------------------------
\10\ See Notice of Filing, notes 25-28 (describing the
parameters to which bounds are applied).
\11\ In the initial rule filing to introduce the STANS
Methodology Description, OCC included a brief description of the
high-volatility parameter controls discussion. See Securities
Exchange Act Release No. 90763 (Dec. 21, 2020), 85 FR 85788, 85793
(Dec. 29, 2020) (File No. SR-OCC-2020-016) (``The STANS Methodology
Description would also describe the controls that may be placed on
the GJR-GARCH parameters after their initial calibration. GARCH
volatility forecasting models can be very reactive in certain market
environments. As a result, OCC may implement parameter controls for
risk factors and classes of risk factors, which are subject to
periodic review and approval by the [Model Risk Working Group].'').
---------------------------------------------------------------------------
More specifically, OCC proposes to amend its existing Margin Policy
to include material details regarding its high-volatility parameter
control setting process.\12\ Although the Proposed Rule Change would
amend OCC's Margin Policy, OCC states that the proposal does not
significantly change OCC's existing high-volatility parameter control
setting practices,\13\ which OCC indicates have been in use since at
least 2020.\14\
---------------------------------------------------------------------------
\12\ OCC also intends to update its internal Margin Setting and
Maintenance procedure (Exhibit 3F to the Proposed Rule Change) to
provide greater detail about its high-volatility parameter control
process.
\13\ See Notice of Filing, 89 FR 81959.
\14\ See id. at 81961-62 (describing an instance when OCC
applied the idiosyncratic control settings in 2021). Additionally,
various exhibits to File No. SR-OCC-2024-014 indicate OCC's use of
high-volatility parameter control settings since 2020. For example,
confidential Exhibit B to that filing, which is an internal OCC
memorandum addressing high-volatility parameter control settings,
describes an instance on March 9, 2020 when OCC implemented the
global control settings.
---------------------------------------------------------------------------
Proposed additions to the Margin Policy describing OCC's exception
process for setting high-volatility parameter controls include the
following: (1) setting and reviewing regular and high-volatility
parameter control settings; (2) monitoring the volatility of products
being cleared and markets served, and establishing thresholds to
escalate the results of such monitoring to senior decisionmakers; and
(3) internal governance for implementing and terminating high-
volatility parameter control settings. The three sets of changes to
OCC's Margin Policy are described in further detail below.
A. Setting and Reviewing Regular and High-Volatility Parameter Control
Settings
STANS uses large-scale Monte Carlo simulations to calculate the
margin requirements of OCC's Clearing Members. The methodology includes
econometric models that incorporate a number of risk factors.\15\ One
of these econometric models, GARCH, is used to estimate the volatility
of equity securities based on historical data. Over time, OCC has
observed that the margin requirements produced by its GARCH model are
strongly reactive to market movements and are considered to be
``procyclical''--meaning that changes in margin requirements produced
by the GARCH model may be positively correlated with the overall state
of the market. OCC states that such procyclicality could inflate the
margin requirements of OCC's Clearing Members beyond the related risk
posed by Clearing Members' positions if it is not addressed during
high-volatility periods in the market, and would potentially threaten
the operational stability of those Clearing Members.\16\
---------------------------------------------------------------------------
\15\ OCC defines a risk factor in STANS as a product or
attribute whose historical data is used to estimate and simulate the
risk for an associated product. The majority of risk factors
utilized in STANS are the returns on individual equity securities.
\16\ See Notice of Filing, 89 FR 81960. For example, OCC states
that its GARCH model produced forecasts for particular S&P 500 Index
(``SPX'') options that were four-fold larger than the comparable
market index, leading to margin requirement increasing by 80%
overnight, with some margin requirements increasing ten-fold. Id.
OCC has attempted a number of approaches to mitigate the impact of
procyclicality, including changes to its GARCH model. See Securities
Exchange Act Release No. 84879 (Dec. 20, 2018), 83 FR 67392, 67393
(Dec. 28, 2018) (File No. SR-OCC-2018-014). OCC has also developed a
new model to replace GARCH for simulating implied volatility for
SPX-based options and volatility index futures. See Securities
Exchange Act Release No. 95319 (July 19, 2022), 87 FR 44167 (July
25, 2022) (File No. SR-OCC-2022-001).
---------------------------------------------------------------------------
As part of its current practice, OCC applies high-volatility
parameter control settings to constrain the GARCH parameters
temporarily during periods of high market volatility. OCC's price
return model uses upper and lower bounds for parameters calculated
daily based on market data. OCC's high-volatility parameter control
settings consist of parameters that are bounded differently than
regular control settings. These high-volatility parameter control
settings, when applied to GARCH parameters after their initial
calibration, mitigate the reactivity of the model volatility forecast
and, in turn, generally prevent significant overestimation of Clearing
Members' margin requirements.\17\ Depending on the circumstances, OCC
may apply control settings to individual risk factors (i.e.,
``idiosyncratic control settings''), or to all or a class of risk
factors (i.e., ``global control settings'').\18\
---------------------------------------------------------------------------
\17\ See Notice of Filing, 89 FR 81959. OCC also provides
detailed examples in which high-volatility parameter control
settings were implemented. Id. at 81962, notes 41-42.
\18\ When OCC implements global control settings for a class or
sector of risk factors, it is OCC's practice to blend the high
volatility and regular control settings based on a weighted
percentage between them. See Notice of Filing, 89 FR 81961. Such a
``blended'' or ``weighted'' approach allows OCC's risk managers,
when appropriate, to select bounds that provide more conservative
margin coverage when applying high volatility control settings
globally across multiple risk factors. See id.
---------------------------------------------------------------------------
As part of the Proposed Rule Change, OCC proposes to amend its
Margin Policy to describe the current exception process for setting and
reviewing both regular and high-volatility parameter control settings.
Specifically, the proposed addition to the Margin Policy would state
that GARCH parameters may be temporarily constrained through the
application of idiosyncratic or global control settings. The added
language would state that OCC's Financial Risk Management team
(``FRM'') maintains both regular and high-volatility parameter control
sets, which it reviews on an at-least annual basis. FRM's review of the
high-volatility parameter control sets assesses whether they
effectively mitigate procyclicality while remaining appropriately risk-
based. The new Margin Policy language would further state that OCC's
Model Risk Working Group (``MRWG'') must approve any changes to the
regular or high-volatility sets. The Proposed Rule Change would also
provide further detail on the review of both regular and high-
volatility parameter control sets.\19\ These proposed changes to the
Margin Policy describe current OCC processes that will remain
unchanged.
---------------------------------------------------------------------------
\19\ The proposed language states that in the case of the
regular control set, the review assesses whether the GARCH parameter
bounds are appropriately risk-based, including but not limited to
assessing whether they align with the 95th percentile of the
parameter calibrations over the prior review period; and, in the
case of the high-volatility parameter control sets, the review
assesses whether they effectively mitigate procyclicality while
remaining appropriately risk-based, including but not limited to
whether the bounds keep the day-over-day change in 2-day expected
shortfall coverage within a factor of approximately 1.5, assuming
price shocks based on observed returns for top risk factors.
---------------------------------------------------------------------------
[[Page 712]]
B. Monitoring Volatility of Products and Markets Served
As part of the Proposed Rule Change, OCC proposes to amend the
Margin Calls and Adjustments section of the Margin Policy to include
details about how OCC currently sets volatility controls. Specifically,
the new Control Setting details would include information about OCC's
current use of certain monitoring thresholds related to high market
volatility, low market liquidity, and significant increases in position
size or concentration (``CCA Monitoring Thresholds'').\20\ The new
details would state that the Quantitative Risk Management (``QRM'')
team,\21\ in collaboration with Stress Testing and Liquidity Risk
Management, will perform a review of the CCA Monitoring Thresholds to
ensure that they remain adequate to identify periods of high market
volatility, low market liquidity, and significant increases in position
size or concentration. Moreover, the new language would state that any
changes to the CCA Monitoring Thresholds must be approved by the MRWG
and the Stress Testing Working Group.
---------------------------------------------------------------------------
\20\ The establishment of these CCA Monitoring Thresholds is
described in OCC's internal Clearing Fund Methodology Policy and its
internal Stress Test Reporting Procedure.
\21\ FRM is the parent department of QRM, which is responsible
for, among other things, monitoring the use and performance of risk
models according to relevant procedures, maintaining risk tolerances
and associated key risk indicators to measure and monitor risk
models. See Securities Exchange Act Release No. 97484 (May 11,
2023), 88 FR 31549, 31550 (May 17, 2023) (File No. SR-OCC-2023-004).
---------------------------------------------------------------------------
OCC also proposes to amend the Margin Calls and Adjustments section
to state that QRM shall perform a monthly sensitivity analysis of the
margin model, but may review more frequently when CCA Monitoring
Thresholds are breached.
These proposed changes to the Margin Policy describe current OCC
processes that will remain unchanged.
C. Internal Governance for Implementing and Terminating High-Volatility
Parameter Controls
As part of the Proposed Rule Change, OCC proposes to amend its
Margin Policy to include details about its current internal governance
process for implementing and terminating high-volatility parameter
control settings. The new Margin Policy details would include
descriptions of both idiosyncratic and global control settings, and the
circumstances under which these settings may be used.
For example, for global control settings, FRM monitors market
volatility on a daily basis, and escalates to the MRWG if a market
volatility threshold is exceeded. As part of the escalation to the
MRWG, FRM recommends whether global control settings should be applied
to all risk factors or to a class of risk factors. MRWG approval is
required for OCC to implement global control settings, and for OCC to
revert back to regular control settings.\22\
---------------------------------------------------------------------------
\22\ When OCC implements global control settings, MRWG evaluates
and selects a control setting with different weightings between the
regular control set and high-volatility parameter control set based
on an assessment of which blended approach generates a coverage
level that converges with the implied volatility of the SPX. Factors
that the MRWG considers when determining whether to revert to
regular control settings include, but are not limited to, whether
SPX coverage rates produced under regular control settings have
converged with the initial coverage rates when the global control
settings were first implemented. See Notice of Filing, 89 FR 81961.
---------------------------------------------------------------------------
Meanwhile, for idiosyncratic control settings, FRM monitors
securities against thresholds for idiosyncratic price moves.\23\ These
thresholds may be a tiered structure that takes into account the type
and magnitude of OCC's risk exposure to the security, the value of the
security, the magnitude of the price move, and the coverage rates. When
an idiosyncratic threshold is breached, FRM Officer approval is
required for any implementation of idiosyncratic control settings for
an individual risk factor. An FRM Officer may also approve
idiosyncratic control settings based on additional considerations,
including market moves, expected shortfall risk contribution, and
changes in Clearing Member positions. Generally, the FRM Officer will
approve the reversion back to regular control settings once market
volatility lessens, but in exceptional circumstances, the FRM Officer
has the discretion to apply the idiosyncratic control settings for a
longer or shorter period of time.
---------------------------------------------------------------------------
\23\ These ``idiosyncratic thresholds'' are defined in OCC's
internal Margin Setting and Maintenance Procedure. OCC included a
copy of this procedure as Exhibit 3F for the Proposed Rule Change.
---------------------------------------------------------------------------
The new language in the Margin Policy would also state that changes
to the idiosyncratic thresholds require MRWG approval.
These proposed changes to the Margin Policy describe current OCC
processes that will remain unchanged.
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.\24\ Under the Commission's
Rules of Practice, the ``burden to demonstrate that a proposed rule
change is consistent with the Exchange Act and the rules and
regulations issued thereunder . . . is on the self-regulatory
organization [`SRO'] that proposed the rule change.'' \25\
---------------------------------------------------------------------------
\24\ 15 U.S.C. 78s(b)(2)(C).
\25\ Rule 700(b)(3), Commission Rules of Practice, 17 CFR
201.700(b)(3).
---------------------------------------------------------------------------
The description of a proposed rule change, its purpose and
operation, its effect, and a legal analysis of its consistency with
applicable requirements must all be sufficiently detailed and specific
to support an affirmative Commission finding,\26\ and any failure of an
SRO to provide this information may result in the Commission not having
a sufficient basis to make an affirmative finding that a proposed rule
change is consistent with the Exchange Act and the applicable rules and
regulations.\27\ Moreover, ``unquestioning reliance'' on an SRO's
representations in a proposed rule change is not sufficient to justify
Commission approval of a proposed rule change.\28\
---------------------------------------------------------------------------
\26\ Id.
\27\ Id.
\28\ Susquehanna Int'l Group, LLP v. Securities and Exchange
Commission, 866 F.3d 442, 447 (D.C. Cir. 2017).
---------------------------------------------------------------------------
After carefully considering the Proposed Rule Change, the
Commission finds that the Proposed Rule Change 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 Proposed Rule Change is consistent with Section 17A(b)(3)(F)
of the Exchange Act \29\ and Rules 17Ad-22(e)(2) \30\ and 17Ad-22(e)(6)
\31\ thereunder, as described in detail below.
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\29\ 15 U.S.C. 78q-1(b)(3)(F).
\30\ 17 CFR 240.17Ad-22(e)(2).
\31\ 17 CFR 240.17Ad-22(e)(6).
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A. Consistency With Section 17A(b)(3)(F) of the Exchange Act
Section 17A(b)(3)(F) of the Exchange Act requires, among other
things, that the rules of a clearing agency be designed to assure the
safeguarding of securities and funds which are in the custody or
control of the clearing agency or for which it is responsible.\32\
Based on the review of the record, and for the reasons described below,
OCC's proposed update to its Margin Policy in the manner described
above is consistent with the safeguarding of securities and funds which
are in OCC's custody or control or for which it is responsible.
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\32\ 15 U.S.C. 78q-1(b)(3)(F).
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[[Page 713]]
OCC's high-volatility parameter control settings provide an
exception handling process for OCC to correct for procyclicality
effects on the GARCH model calculation that may unreasonably inflate
Clearing Members' margin requirements during periods of high market
volatility.\33\ The idiosyncratic control settings allow OCC to adjust
Clearing Member margin requirements to be commensurate with the risk of
the products, portfolios, or markets when an individual risk factor
becomes volatile (e.g., reflecting genuine changes in the risk of the
Clearing Member's products or portfolio, or the markets), rather than
allowing the Clearing Member's margin requirement to diverge from
observed market dynamics based on the reactivity of OCC's GARCH model.
The global control settings offer the same benefit for periods during
which all or a class of risk factors becomes volatile. Therefore, by
setting and reviewing high-volatility parameter control settings, OCC
is able to reduce the likelihood that Clearing Members would become
operationally unstable or, potentially, default as the result of
unreasonably high margin calls. This in turn further assures the
safeguarding of Clearing Members' collateral by reducing the likelihood
that OCC would be forced to charge losses from a defaulting Clearing
Member to the Clearing Fund.
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\33\ Examples of unreasonably inflated margin requirements were
included in backtesting data and analysis provided as part of OCC's
confidential Exhibit 3C to File No. SR-OCC-2024-014. See Notice of
Filing, 89 FR 81962, note 43.
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OCC's use of CCA Monitoring Thresholds to monitor for market
volatility is also consistent with the safeguarding of securities and
funds which are in OCC's custody or control or for which it is
responsible. The CCA Monitoring Thresholds are set and used for FRM to
detect both high market volatility generally and high volatility of
individual risk factors. When FRM observes that any of these thresholds
are exceeded, FRM determines whether or not to recommend that OCC's
high-volatility parameter control settings be implemented--either to
MRWG that global controls should be implemented for market-wide
volatility, or to the FRM Officer that idiosyncratic controls should be
implemented for idiosyncratic volatility. OCC's monitoring and proper
setting of these thresholds helps to lower the chances of a Clearing
Member default resulting from margin calls that are significantly
higher than necessary to account for the risk presented by the Clearing
Member's products, portfolio, or the market, and thus assures the
safeguarding of Clearing Members' collateral from any loss charges to
OCC's Clearing Fund.
The high-volatility parameter control setting practices described
in the Proposed Rule Change are designed to ensure that Clearing Member
margin requirements remain commensurate with market risk in
circumstances when the margin model reacts unreasonably to high market
volatility. Indeed, the confidential backtesting data that OCC provided
to the Commission \34\ shows that no account level exceedance has been
attributed to OCC's implementation of high-volatility parameter control
settings. Thus, the application of the high-volatility parameter
control settings does not appear to have reduced OCC's ability to cover
the risk posed by Clearing Members' positions. Additionally, the
confidential information regarding model backtesting provided by OCC
and reviewed by the Commission demonstrates that, overall, the use of
high-volatility parameter control settings has not prevented OCC from
maintaining a 2-day expected shortfall coverage level of 99%.\35\ This
demonstrates that, even with the use of the high-volatility parameter
control settings, OCC's margin collateral remains sufficient to cover
exposures at least 99 out of 100 days, as discussed above.\36\
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\34\ As stated in the Margin Policy, OCC monitors margin
sufficiency by using its ``business backtesting'' process for
monitoring account exceedances. OCC has provided responses to
Commission requests for backtesting data and analysis as part of its
confidential Exhibit 3C to File No. SR-OCC-2024-014. See Notice of
Filing, 89 FR 81962, note 43.
\35\ Notice of Filing, 89 FR 81962.
\36\ See supra note 8.
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For the foregoing reasons, the Proposed Rule Change is consistent
with the requirements of Section 17A(b)(3)(F) of the Exchange Act.\37\
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\37\ 15 U.S.C. 78q-1(b)(3)(F).
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B. Consistency with Rule 17Ad-22(e)(2) under the Exchange Act
Rule 17Ad-22(e)(2) under the Exchange Act requires that a covered
clearing agency establish, implement, maintain and enforce written
policies and procedures reasonably designed to, as applicable, provide
for governance arrangements that, among other things, specify clear and
direct lines of responsibility.\38\ Based on the review of the record,
and for the reasons described below, OCC's proposed update to its
Margin Policy in the manner described above is consistent with Rule
17Ad-22(e)(2)(v).
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\38\ 17 CFR 240.17Ad-22(e)(2)(v).
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OCC's amendments to its Margin Policy describe the the arrangements
governing the implemention, modification, and termination of high-
volatility parameter controls. Defining the MRWG, QRM, FRM, and FRM
Officer's roles and responsibilities in these processes specifies clear
and direct lines of responsibility. Specifically, the added language to
the Margin Policy describes the role of FRM in monitoring for both
market and idiosyncratic volatility. It also describes the FRM's direct
line of responsibility to either the MRWG for global control settings
or the FRM Officer for idiosyncratic control settings, as well as the
roles of MRWG and the FRM Officer in approving the eventual reversion
back to regular control settings.
For the foregoing reasons, the Proposed Rule Change is consistent
with Rule 17Ad-22(e)(2) under the Exchange Act.\39\
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\39\ 17 CFR 240.17Ad-22(e)(2).
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C. Consistency With Rule 17Ad-22(e)(6) Under the Exchange Act
Rule 17Ad-22(e)(6) under the Exchange Act requires that a covered
clearing agency establish, implement, maintain, and enforce written
policies and procedures reasonably designed to cover, if the covered
clearing agency provides central counterparty services, its credit
exposures to its participants by establishing a risk-based margin
system that, among other things, (1) considers, and produces margin
levels commensurate with, the risks and particular attributes of each
relevant product, portfolio, and market \40\ and (2) calculates
sufficient margin to cover its potential future exposure to
participants in the interval between the last margin collection and the
close out of positions following a participant default.\41\ Based on
the review of the record, and for the reasons described below, OCC's
proposed update to its Margin Policy in the manner described above is
consistent with Rule 17Ad-22(e)(6).
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\40\ 17 CFR 240.17Ad-22(e)(6)(i).
\41\ 17 CFR 240.17Ad-22(e)(6)(iii).
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As described above, the high-volatility parameter control settings
provide a necessary exception process allowing OCC to mitigate a
limitation of its GARCH models that have demonstrated extreme
sensitivity to sudden spikes in volatility. Such reactivity can produce
instability, and in certain instances, over- or underestimation of
margin
[[Page 714]]
requirements.\42\ The confidential backtesting data that OCC provided
to the Commission has shown that during instances of market volatility
where OCC has employed either the idiosyncratic control settings or the
global control settings, the control settings have limited Clearing
Member margin requirements to be commensurate with market risk by
countering procyclicality effects, while still ensuring that OCC is
collecting appropriate margin to cover its exposure to relevant
products, portfolios, and markets.\43\ Ensuring that OCC maintains
processes to counter procyclicality, in turn, allows for reduced margin
requirements that, as described above, do not degrade backtesting
coverage. Therefore, OCC is still able to calculate sufficient margin,
while limiting the need for ``destabilizing, procyclical changes.''
\44\ Further, including such high-volatility parameter control settings
reduces the likelihood that Clearing Members would be required to
provide additional financial resources unnecessarily, which, in turn,
could reduce the strain on such Clearing Members during stressed market
conditions.
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\42\ For example, OCC's 2018 model would have increased
aggregate margin requirements by 80 percent overnight in response to
increased volatility observed on February 5, 2018. OCC stated that
it believed that these margin requirements were unreasonable and
procyclical. See Notice of Filing, 89 FR 81960; Securities Exchange
Act Release No. 84879, at 83 FR 67392, 67393.
\43\ OCC has provided responses to Commission requests for
backtesting data and analysis as part of its confidential Exhibit 3C
to File No. SR-OCC-2024-014. See Notice of Filing, 89 FR 81962, note
43.
\44\ See Standards for Covered Clearing Agencies, 81 FR 70819.
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Accordingly, the Proposed Rule Change is consistent with Rule 17Ad-
22(e)(6) under the Exchange Act.\45\
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\45\ 17 CFR 240.17Ad-22(e)(6).
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IV. Conclusion
On the basis of the foregoing, the Commission finds that the
Proposed Rule Change is consistent with the requirements of the
Exchange Act, and in particular, the requirements of Section 17A of the
Exchange Act \46\ and the rules and regulations thereunder.
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\46\ In approving the Proposed Rule Change, the Commission has
considered the proposed rule's impact on efficiency, competition,
and capital formation. See 15 U.S.C. 78c(f).
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It is therefore ordered, pursuant to Section 19(b)(2) of the
Exchange Act,\47\ that the proposed rule change, as modified by Partial
Amendment No. 1 (SR-OCC-2024-014), be, and hereby is, approved.
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\47\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\48\
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\48\ 17 CFR 200.30-3(a)(12).
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Stephanie J. Fouse,
Assistant Secretary.
[FR Doc. 2024-31610 Filed 1-3-25; 8:45 am]
BILLING CODE 8011-01-P