[Federal Register Volume 82, Number 64 (Wednesday, April 5, 2017)]
[Notices]
[Pages 16644-16647]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-06682]


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SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-80341; File No. SR-FICC-2017-801]


Self-Regulatory Organizations; Fixed Income Clearing Corporation; 
Notice of No Objection to Advance Notice Filing To (1) Implement the 
Margin Proxy and (2) Modify the Calculation of the Coverage Charge in 
Circumstances Where the Margin Proxy Applies

March 30, 2017.
    Fixed Income Clearing Corporation (``FICC'') filed with the U.S. 
Securities and Exchange Commission (``Commission'') on February 2, 2017 
the advance notice SR-FICC-2017-801 (``Advance Notice'') pursuant to 
Section 806(e)(1) of the Payment, Clearing, and Settlement Supervision 
Act of 2010 (``Clearing Supervision Act'') \1\ and Rule 19b-4(n)(1)(i) 
\2\ under the Securities Exchange Act of 1934 (``Exchange Act''). The 
Advance Notice was published for comment in the Federal Register on 
March 8, 2017.\3\ Although the Commission received no comments to the 
Advance Notice, it received three comment letters \4\ to the Proposed 
Rule Change, of which parts pertinent to the Advance Notice are 
discussed below.\5\ This publication serves as notice of no objection 
to the Advance Notice.
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    \1\ 12 U.S.C. 5465(e)(1). The Financial Stability Oversight 
Council designated FICC a systemically important financial market 
utility on July 18, 2012. See Financial Stability Oversight Council 
2012 Annual Report, Appendix A, http://www.treasury.gov/initiatives/fsoc/Documents/2012%20Annual%20Report.pdf. Therefore, FICC is 
required to comply with the Payment, Clearing and Settlement 
Supervision Act and file advance notices with the Commission. See 12 
U.S.C. 5465(e).
    \2\ 17 CFR 240.19b-4(n)(1)(i).
    \3\ Securities Exchange Act Release No. 80139 (March 2, 2017), 
82 FR 13026 (March 8, 2017) (SR-FICC-2017-801) (``Notice''). FICC 
also filed a related proposed rule change (SR-FICC-2017-001) 
(``Proposed Rule Change'') with the Commission pursuant to Section 
19(b)(1) of the Exchange Act and Rule 19b-4 thereunder, seeking 
approval of changes to its rules necessary to implement the Advance 
Notice. 15 U.S.C. 78s(b)(1) and 17 CFR 240.19b-4, respectively. The 
Proposed Rule Change was published in the Federal Register on 
February 9, 2017. Securities Exchange Act Release No. 79958 
(February 3, 2017), 82 FR 10117 (February 9, 2017) (SR-FICC-2017-
001).
    \4\ See letter from Robert E. Pooler, Chief Financial Officer, 
Ronin Capital LLC (``Ronin''), dated February 24, 2017, to Eduardo 
A. Aleman, Assistant Secretary, Commission (``Ronin Letter''); 
letter from Alan Levy, Managing Director, Industrial and Commercial 
Bank of China Financial Services LLC (``ICBCFS''), dated February 
24, 2017, to Commission (``ICBCFS Letter''); and Timothy J. Cuddihy, 
Managing Director, FICC, dated March 8, 2017, to Eduardo A. Aleman, 
Assistant Secretary, Commission (``FICC Letter'') available at 
https://www.sec.gov/comments/sr-ficc-2017-001/ficc2017001.htm.
    \5\ Because the proposal contained in the Advance Notice was 
also filed as the Proposed Rule Change, see supra note 3, the 
Commission is considering any comment received on the Proposed Rule 
Change also to be a comment on the Advance Notice.
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I. Description of the Advance Notice

    The Advance Notice proposes several amendments to the FICC 
Government Securities Division (``GSD'') Rulebook (``GSD Rules'') 
designed to provide FICC with a supplemental means to calculate the VaR 
Charge component of its GSD Netting Members' (``Netting Members'') 
daily margin requirement, known as the ``Required Fund Deposit.'' 
Specifically, under the proposal, FICC would include a minimum 
volatility calculation for a Netting Member's VaR Charge called the 
``Margin Proxy.'' FICC represents that the Margin Proxy would enhance 
the risk-based model and parameters that FICC uses to establish Netting 
Members' Required Fund Deposits by enabling FICC to better identify the 
risk posed by a Netting Member's unsettled portfolio.

A. Overview of the Required Fund Deposit

    According to FICC, a key tool it uses to manage market risk is the 
daily calculation and collection of Required Fund Deposits from its 
Netting Members. The Required Fund Deposit is intended to mitigate 
potential losses to FICC associated with liquidation of such Netting 
Member's accounts at GSD that are used for margining purposes (``Margin 
Portfolio'') in the event that FICC ceases to act for such Netting 
Member (referred to as a Netting Member ``Default'').
    A Netting Member's Required Fund Deposit consists of several 
components, including the VaR Charge and the Coverage Charge. The VaR 
Charge comprises the largest portion of a Netting Member's Required 
Fund Deposit amount and is calculated using a risk-based margin 
methodology model that is intended to cover the market price risk 
associated with the securities in a Netting Member's Margin Portfolio. 
That risk-based margin methodology model, which FICC refers to as the 
``Current Volatility Calculation,'' uses historical market moves to 
project the potential gains or losses that could occur in connection 
with the liquidation of a defaulting Netting Member's Margin Portfolio.
    The Coverage Charge is calculated based on the Netting Member's 
daily backtesting results conducted by FICC. Backtesting is used to 
determine the adequacy of each Netting Member's Required Fund Deposit 
and involves comparing the Required Fund Deposit for each Netting 
Member with actual price changes in the Netting Member's Margin 
Portfolio. The Coverage Charge is incorporated in the Required Fund 
Deposit for each Netting Member, and is equal to the amount necessary 
to increase that Netting Member's Required Fund Deposit so that the 
Netting Member's backtesting coverage may achieve the 99 percent 
confidence level required by FICC (i.e., two or fewer backtesting 
deficiency days in a rolling twelve-month period).

B. Proposed Change to the Existing VaR Charge Calculation

    Under the proposal, FICC would create the Margin Proxy, a new, 
benchmarked volatility calculation of the VaR Charge. The Margin Proxy 
would act as alternative to the Current Volatility Calculation of the 
VaR Charge to provide a minimum volatility calculation for each Netting 
Member's VaR Charge. FICC proposes to use the Margin Proxy as the VaR 
Charge if doing so would result in a higher Required Fund Deposit for a 
Netting Member than using the Current Volatility Calculation as the VaR 
Charge. In addition, as described in more detail below, because FICC's 
testing shows that the Margin Proxy would, by itself, achieve a 99 
percent confidence level for Netting Members' backtesting coverage when 
used in lieu of the Current Volatility Charge, in the event that FICC 
uses the Margin Proxy as the VaR Charge for a Netting Member, it would 
reduce the Coverage Charge for that Netting Member by a commensurate 
amount, as long as the Coverage Charge does not go below zero.
    According to FICC, during the fourth quarter of 2016, its Current 
Volatility Calculation did not respond effectively to the level of 
market volatility at that time, and its VaR Charge amounts (calculated 
using the profit and loss scenarios generated by the Current Volatility 
Calculation) did not achieve backtesting coverage at a 99 percent

[[Page 16645]]

confidence level,\6\ which resulted in backtesting deficiencies for the 
Required Fund Deposit beyond FICC's risk tolerance.\7\ FICC's 
calculation of the Margin Proxy is designed to avoid such deficiencies. 
The Margin Proxy provides FICC with an alternative calculation of the 
VaR Charge to the Current Volatility Calculation of the VaR Charge. In 
particular, the Margin Proxy is likely to be used when the Current 
Volatility Calculation is lower than volatility from certain benchmarks 
(i.e., market price volatility from corresponding U.S. Treasury and to-
be-announced (``TBA'') \8\ securities benchmarks.\9\ The Margin Proxy 
separately calculates U.S. Treasury securities and agency pass-through 
mortgage backed securities (``MBS''). According to FICC, the historical 
price changes of these two asset classes are different due to market 
factors such as credit spreads and prepayment risk.\10\ This would 
allow FICC to monitor the performance of each of those asset classes 
individually.\11\ By using separate calculations for the two asset 
classes, the Margin Proxy would cover the historical market prices of 
each of those asset classes, on a standalone basis, to a 99 percent 
confidence level.
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    \6\ Notice, 82 FR at 13029.
    \7\ Id.
    \8\ FICC states that specified pool trades are mapped to the 
corresponding positions in TBA securities for determining the VaR 
Charge.
    \9\ Notice, 82 FR at 13029.
    \10\ Id.
    \11\ Id.
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    The Margin Proxy would be calculated per Netting Member, and each 
security in a Netting Member's Margin Portfolio would be mapped to a 
respective benchmark based on the security's asset class and 
maturity.\12\ All securities within each benchmark would be aggregated 
into a net exposure.\13\ Once the net exposure is determined, FICC 
would apply an applicable haircut \14\ to each benchmark's net exposure 
to determine the net price risk for each benchmark (``Net Price 
Risk''). Finally, FICC would separately determine the asset class price 
risk (``Asset Class Price Risk'') for U.S. Treasury and MBS benchmarks 
by aggregating the respective Net Price Risk for each benchmark. To 
provide risk diversification across tenor buckets for the U.S. Treasury 
benchmarks, the Asset Class Price Risk calculation includes a 
correlation adjustment that has been historically observed across the 
U.S. Treasury benchmarks. According to FICC, the Margin Proxy would 
thereby represent the sum of the U.S. Treasury and MBS Asset Class 
Price Risk.\15\ FICC would compare the Margin Proxy to the Current 
Volatility Calculation for each asset class and then apply whichever is 
greater as the VaR Charge for each Netting Member's Margin Portfolio.
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    \12\ According to FICC, U.S. Treasury and agency securities 
would be mapped to a U.S. Treasury benchmark security/index, while 
MBS would be mapped to a TBA security/index.
    \13\ Net exposure is the aggregate market value of securities to 
be purchased by the Netting Member minus the aggregate market value 
of securities to be sold by the Netting Member.
    \14\ The haircut is calculated using historical market price 
changes of the respective benchmark to cover the expected market 
price volatility at 99 percent confidence level.
    \15\ Notice, 82 FR 13029.
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    FICC expresses confidence that this proposal would provide the 
adequate VaR Charge for each Netting Member because its calculations 
show that including the Margin Proxy results in backtesting coverage 
above the 99 percent confidence level for the past four years.\16\ 
Additionally, FICC asserts that, by using industry-standard benchmarks 
that can be observed by Netting Members, the Margin Proxy would be 
transparent to Netting Members.\17\
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    \16\ Id.
    \17\ Id.
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    FICC further asserts that the Margin Proxy methodology would be 
subject to performance reviews by FICC. Specifically, FICC would 
monitor each Netting Member's Required Fund Deposit and the aggregate 
FICC GSD clearing fund (``Clearing Fund'') requirements and compare 
them to the requirements calculated by the Margin Proxy. Consistent 
with the current GSD Rules,\18\ FICC would review the robustness of the 
Margin Proxy by comparing the results versus the three-day profit and 
loss of each Netting Member's Margin Portfolio based on actual market 
price moves. If the Margin Proxy's backtesting results do not meet 
FICC's 99 percent confidence level, FICC states that it would consider 
adjustments to the Margin Proxy, including increasing the look-back 
period and/or applying a historical stressed period to the Margin Proxy 
calibration, as appropriate.\19\
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    \18\ See definition of VaR Charge in GSD Rule 1, Definitions, 
supra note 4.
    \19\ Notice, 82 FR at 13029.
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C. Proposed Modification to the Coverage Charge When the Margin Proxy 
Is Applied

    FICC also proposes to modify the calculation of the Coverage Charge 
when the Margin Proxy is applied as the VaR Charge. Specifically, FICC 
would reduce the Coverage Charge by the amount that the Margin Proxy 
exceeds the sum of the Current Volatility Calculation and Coverage 
Charge, but not by an amount greater than the total Coverage Charge. 
FICC states that its backtesting analysis demonstrates that the Margin 
Proxy, on its own, achieves the 99 percent confidence level without the 
inclusion of the Coverage Charge \20\ FICC would not modify the 
Coverage Charge if the Margin Proxy is not applied as the VaR Charge.
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    \20\ Id. at 13029. Future adjustments to the Margin Proxy could 
require the filing of a new proposed rule change.
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II. Summary of Comments Received

    The Commission received three comment letters in response to the 
proposal.\21\ Two comment letters--the Ronin Letter and the ICBCFS 
Letter--raise concerns with respect to the proposal's design,\22\ while 
the third comment letter is FICC's response to those concerns. The 
Commission has reviewed and taken into consideration each of the 
comments received and addresses the comments below insofar as they 
relate to the standard of review for an advance notice.
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    \21\ As noted above, all three comment letters were submitted to 
the file for the related Proposed Rule Change, not the Advance 
Notice; however, because the Proposed Rule Change and Advance Notice 
are substantially the same proposal, this notice addresses the 
relevant comments. See supra note 4.
    \22\ See Ronin Letter at 1-10; ICBCFS Letter at 1-3. Ronin and 
ICBCFS also raised concerns with respect to transparency and 
implementation period. Specifically, Ronin and ICBCFS (i) argue that 
there is a lack of transparency with respect to the development of 
the Margin Proxy; and (ii) disapprove of FICC's request for an 
accelerated regulatory review process. In addition, Ronin argues 
that the proposal imposes a burden on competition because it may 
cause Ronin to pay more margin. These issues are relevant to the 
Commission's review and evaluation of the Proposed Rule Change, 
which is conducted under the Exchange Act, but not to the 
Commission's evaluation of the Advance Notice, which, as discussed 
below in Section III, is conducted under the Clearing Supervision 
Act and generally considers whether the proposal will mitigate 
systemic risk and promote financial stability. Accordingly, these 
concerns will be addressed in the Commission's review of the related 
Proposed Rule Change, as applicable under the Exchange Act.
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    Specifically, Ronin questions the justification for imposing the 
Margin Proxy, particularly (i) the need for the VaR Charge to address 
idiosyncratic risk (referencing the 2016 U.S. presidential election), 
and (ii) if the volatility around the 2016 U.S. presidential election 
was sufficiently extreme to warrant the creation of the Margin 
Proxy.\23\ In response, FICC reiterates that the Margin Proxy's primary 
goal is to achieve a 99 percent backtesting confidence level for all 
members.\24\ FICC observes that, while recent dates from the fourth 
quarter of 2016 (including the 2016 U.S. Presidential

[[Page 16646]]

election) indicate that the VaR Charge, on its own, is not always 
sufficient to ensure that the 99 percent coverage threshold is met,\25\ 
inclusion of the Margin Proxy results in a backtesting confidence level 
above 99 percent for the past four years, demonstrating that the Margin 
Proxy accomplishes its primary goal.\26\
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    \23\ Ronin Letter at 1, 6.
    \24\ See FICC Letter at 4.
    \25\ See id. at 2.
    \26\ Id. at 4.
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    ICBCFS disagrees with certain technical aspects of the proposal. In 
particular, it: (i) Questions the inclusion of ten years of pricing 
data in the proposed Margin Proxy calculation, including the 2007-2009 
period; (ii) disagrees with the Margin Proxy's netting of both sides of 
a repurchase transaction; and (iii) raises concerns on how the proposed 
Margin Proxy groups securities in a Netting Member's Margin Portfolio 
in a way that could increase its margin.\27\ In response to the 
questions regarding the inclusion of ten years of pricing data, FICC 
states that using the proposed look-back period would help to ensure 
that the Margin Proxy, and as a result, the VaR Charge, does not either 
(i) decrease as quickly during intervals of low volatility, or (ii) 
increase as sharply in crisis periods, resulting in more stable VaR 
estimates that adequately reflect extreme market moves.\28\ With 
respect to ICBCFS's concerns with offsetting positions in transaction, 
FICC notes that the Margin Proxy uses a similar approach for offsetting 
positions as in the Current Volatility Calculation.\29\ In response to 
ICBCFS' concerns about increased margin due to the Margin Proxy's 
benchmarking, FICC responds that the circumstance that ICBCFS cited 
would not result in a higher margin, as the Margin Proxy would 
benchmark securities within the same asset class and maturity (and long 
and short positions within such benchmarks would be offset).\30\
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    \27\ ICBCFS Letter at 2.
    \28\ FICC Letter at 4.
    \29\ Id.
    \30\ Id.
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III. Discussion and Commission Findings

    Although the Clearing Supervision Act does not specify a standard 
of review for an advance notice, its stated purpose is instructive: To 
mitigate systemic risk in the financial system and promote financial 
stability by, among other things, promoting uniform risk management 
standards for systemically important financial market utilities and 
strengthening the liquidity of systemically important financial market 
utilities.\31\ Section 805(a)(2) of the Clearing Supervision Act 
authorizes the Commission to prescribe risk management standards for 
the payment, clearing, and settlement activities of designated clearing 
entities and financial institutions engaged in designated activities 
for which it is the supervisory agency or the appropriate financial 
regulator. Section 805(b) of the Clearing Supervision Act \32\ states 
that the objectives and principles for the risk management standards 
prescribed under Section 805(a) shall be to:
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    \31\ 12 U.S.C. 5461(b).
    \32\ 12 U.S.C. 5464(b).
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     Promote robust risk management;
     promote safety and soundness;
     reduce systemic risks; and
     support the stability of the broader financial system.\33\
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    \33\ 12 U.S.C. 5464(b).
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    The Commission has adopted risk management standards under Section 
805(a)(2) of the Clearing Supervision Act \34\ and Section 17A of the 
Exchange Act (``Clearing Agency Standards'').\35\ The Clearing Agency 
Standards require registered clearing agencies to establish, implement, 
maintain, and enforce written policies and procedures that are 
reasonably designed to meet certain minimum requirements for their 
operations and risk management practices on an ongoing basis.\36\ 
Therefore, it is appropriate for the Commission to review changes 
proposed in advance notices against these Clearing Agency Standards and 
the objectives and principles of these risk management standards as 
described in Section 805(b) of the Clearing Supervision Act.\37\
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    \34\ 12 U.S.C. 5464(a)(2).
    \35\ See 17 CFR 240.17Ad-22; Securities Exchange Act Release No. 
68080 (October 22, 2012), 77 FR 66220 (November 2, 2012) (S7-08-11).
    \36\ Id.
    \37\ 12 U.S.C. 5464(b).
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A. Consistency With Section 805(b) of the Clearing Supervision Act

    The Commission believes that the changes proposed in the Advance 
Notice are consistent with the objectives and principles described in 
Section 805(b) of the Clearing Supervision Act.\38\
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    \38\ Id.
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    First, the Commission believes that the proposed changes promote 
robust risk management by giving FICC the ability to better cover the 
exposure to potential default presented by GSD Netting Members' 
portfolios. In light of the VaR model deficiencies revealed through 
backtesting, FICC has taken appropriate steps to improve its ability to 
assess a sufficient VaR Charge for each Netting Member, and thereby 
help ensure that it has sufficient financial resources in its Clearing 
Fund. More specifically, the Margin Proxy would serve as a minimum 
volatility calculation, enabling FICC to adjust the GSD VaR Charge when 
the Margin Proxy calculation is greater than the current VaR model 
calculation. Such an adjustment would enable FICC to more effectively 
assess for the overall market risks associated with a possible default 
of a GSD Member.
    Second, the Commission believes that each of the Margin Proxy 
mechanisms discussed above--the longer look back period, use of 
position offsets, and treatment of when-issued Treasury securities--are 
designed to help FICC to better manage market risk. The Commission 
agrees that a longer look-back period typically produces more stable 
VaR estimates.\39\ By using the proposed look back period, including 
the 2007-2009 period, FICC will help ensure that the VaR Charge does 
not either decrease as quickly during intervals of low volatility or 
increase as sharply in crisis periods. This should allow FICC to manage 
market risk more effectively by having a more stable VaR Charge, as 
well as by incorporating periods of recent market volatility. The 
Commission also agrees that, by using position offsets within and 
across tenor buckets, the Margin Proxy will reflect historical 
observations across the U.S. Treasury benchmarks, and therefore help 
FICC monitor market risk. Finally, the Commission also believes that 
the Margin Proxy's proposed treatment of when-issued Treasury 
securities is appropriate. As FICC notes, the Margin Proxy ensures that 
when-issued Treasury securities correspond to the same maturity bucket 
as the new issue, therefore the VaR Charge will not be impacted by 
grouping of similar ``when-issued'' securities in different maturity 
buckets. In sum, the Commission believes that these mechanisms are 
designed to enable FICC to reduce its exposure to Netting Members, the 
Commission believes it is consistent with promoting robust risk 
management as contemplated in Section 805(a) of the Act.
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    \39\ FICC Letter at 4.
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    Third, the Commission believes that the proposed changes promote 
safety and soundness at FICC, which, in turn, should reduce systemic 
risk and support the stability of the broader financial system. By 
providing for a supplemental means to calculate a Netting Member's VaR 
Charge, especially in light of known deficiencies with the current 
calculation, the proposal would help

[[Page 16647]]

ensure that FICC collects a VaR Charge that better addresses the risk 
exposure presented by the portfolio of the Netting Member. By better 
limiting exposure to Netting Members, the proposal is designed to help 
ensure that, in the event of a member default, GSD's operations would 
not be disrupted and non-defaulting Netting Members would limit their 
exposure to losses that they cannot anticipate or control. Accordingly, 
the Commission believes that the proposal will help to promote safety 
and soundness at FICC, which in turn will help to reduce systemic risk 
and support the stability of the broader financial system, consistent 
with Section 805(b) of the Act.\40\
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    \40\ Id.
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B. Consistency With Rule 17Ad-22(b)(1) and (b)(2) Under the Exchange 
Act

    The Commission believes that the proposed changes associated with 
the Margin Proxy are consistent with the requirements of Rules 17Ad-
22(b)(1) and (b)(2) under the Exchange Act.\41\
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    \41\ 17 CFR 240.17Ad-22(b)(1) and (b)(2).
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    Rule 17Ad-22(b)(1) under the Exchange Act requires a registered 
clearing agency that performs central counterparty services to 
establish, implement, maintain, and enforce written policies and 
procedures reasonably designed to measure its credit exposures to its 
participants at least once a day and limit its exposures to potential 
losses from defaults by its participants under normal market conditions 
so that the operations of the clearing agency would not be disrupted 
and non-defaulting participants would not be exposed to losses that 
they cannot anticipate or control.\42\ The proposed Margin Proxy would 
be used daily to help measure FICC's credit exposure to Netting 
Members. While ICBCFS raises concerns about including the 2007-2009 
period, as noted above, the Commission agrees that this look back 
period should help FICC better monitor the credit exposures presented 
by its Netting Members by including volatile periods. It should also 
enhance FICC's overall risk-based margining framework by helping to 
ensure that the calculation of each GSD Netting Member's Required Fund 
Deposit would be sufficient to allow FICC to use the defaulting 
member's own Required Fund Deposit to limit its exposures to potential 
losses associated with the liquidation of such member's portfolio in 
the event of a GSD Netting Member default under normal market 
conditions. Therefore, the Commission believes that the proposal is 
consistent with the requirements of Rule 17Ad-22(b)(1).\43\
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    \42\ 17 CFR 240.17Ad-22(b)(1).
    \43\ Id.
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    Rule 17Ad-22(b)(2) under the Exchange Act requires a registered 
clearing agency that performs central counterparty services to 
establish, implement, maintain, and enforce written policies and 
procedures reasonably designed to use margin requirements to limit its 
credit exposures to participants under normal market conditions and use 
risk-based models and parameters to set margin requirements and review 
such margin requirements and the related risk-based models and 
parameters at least monthly.\44\ The proposed changes would enhance the 
risk-based model and parameters that establish daily margin 
requirements for Netting Members by enabling FICC to better identify 
the risk posed by a Netting Member's unsettled portfolio and to quickly 
adjust and collect additional deposits as needed to cover those risks. 
Because the proposed changes are designed to calculate each Netting 
Member's Required Fund Deposit at a 99 percent confidence level, the 
proposal also should help mitigate losses to FICC and its members, in 
the event that such Netting Member defaults under normal market 
conditions. Therefore, the Commission believes that the proposal is 
consistent with the requirements of Rule 17Ad-22(b)(2).\45\
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    \44\ 17 CFR 240.17Ad-22(b)(2).
    \45\ Id.
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IV. Conclusion

    It is therefore noticed, pursuant to Section 806(e)(1)(I) of the 
Clearing Supervision Act,\46\ that the Commission does not object to 
the Advance Notice (SR-FICC-2017-801) and that FICC be hereby is 
authorized to implement the change as of the date of this notice or the 
date of an order by the Commission approving the Proposed Rule Change 
(SR-FICC-2017-001) that reflects the changes that are consistent with 
this Advance Notice, whichever is later.
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    \46\ 12 U.S.C. 5465(e)(1)(I).

    By the Commission.
Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2017-06682 Filed 4-4-17; 8:45 am]
 BILLING CODE 8011-01-P