[Federal Register Volume 89, Number 8 (Thursday, January 11, 2024)]
[Notices]
[Pages 1952-1963]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2024-00383]


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SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-99277; File No. SR-LCH SA-2023-007]


Self-Regulatory Organizations; LCH SA; Notice of Filing of 
Proposed Rule Change Relating to Liquidity Risk Modelling Framework

January 5, 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 22, 2023, Banque Centrale de Compensation, which conducts 
business under the name LCH SA (``LCH SA''), filed with the Securities 
and Exchange Commission (``Commission'') the proposed rule change 
described in Items I, II and III below, which Items have been primarily 
prepared by LCH SA. The Commission is publishing this notice to solicit 
comments on the Proposed Rule Change from interested persons.
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    \1\ 15 U.S.C. 78s(b)(1).
    \2\ 17 CFR 240.19b-4.
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I. Clearing Agency's Statement of the Terms of Substance of the 
Proposed Rule Change

    LCH SA is proposing to amend its Liquidity Risk Modelling Framework 
(the ``Framework''), which describes the Liquidity Stress Testing 
framework by which the Collateral and Liquidity Risk Management 
department (``CaLRM'') of LCH SA assures that LCH SA has enough cash 
available to meet any financial obligations, both expected and 
unexpected, that may arise over the liquidation period for each of the 
clearing services that LCH SA offers (the ``Proposed Rule Change'').\3\
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    \3\ LCH SA, a subsidiary of LCH Group and an indirect subsidiary 
of the London Stock Exchange Group plc (``LSEG''), manages its 
liquidity risk pursuant to, among other policies and procedures, the 
Group Liquidity Risk Policy and the Group Liquidity Plan applicable 
to each entity within LCH Group. In addition to its CDSClear 
service, LCH SA provides clearing services in connection with cash 
equities and derivatives listed for trading on Euronext 
(EquityClear), commodity derivatives listed for trading on Euronext 
(CommodityClear), and tri-party Repo transactions (RepoClear). LCH 
SA also maintains an interoperability link with Euronext Clearing, 
formerly Cassa di Compensazione e Garanzia, in Milan, Italy.
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II. Clearing Agency's Statement of the Purpose of, and Statutory Basis 
for, the Proposed Rule Change

    In its filing with the Commission, LCH SA included statements 
concerning the purpose of and basis for the Proposed Rule Change and 
discussed any comments it received on the Proposed Rule Change. The 
text of these statements may be examined at the places specified in 
Item IV below. LCH SA has prepared summaries, set forth in sections A, 
B, and C below, of the most significant aspects of such statements.

A. Clearing Agency's Statement of the Purpose of, and Statutory Basis 
for, the Proposed Rule Change

1. Purpose
    The Proposed Rule Change is being adopted primarily to enhance the 
manner in which the Liquidity Coverage Ratio (``LCR'') is calculated, 
thereby increasing the robustness of LCH SA's liquidity profile.\4\ The 
changes implement recommendations made by LCH SA's Model Validation 
Team following validation exercises in 2020 and 2021.
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    \4\ LCH SA uses a Cover 2 approach for conducting stress tests 
and assessing its liquidity resources on a daily basis. This 
approach assumes that the two Clearing Member groups with the 
largest liquidity exposure will default on the same day. Cover 2 is 
computed by taking into account the liquidity risks related to 
clearing members within the same group across all services of the 
CCP that are then aggregated.
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    In particular, the Proposed Rule Change will: (a) revise the manner 
in which the settlement obligation liquidity requirements are 
calculated by aligning it to the actual process used by the Operations 
Team during a default management event and ensuring that no netting is 
allowed between Members of the same Group; (b) revise the manner in 
which securities pledged to the Banque de France (``BdF'') are 
calculated by providing that such securities be valued at the stressed 
mark-to-market price rather than the contract price; \5\ (c) extend 
from five (5) days to seven (7) days the length of time for which LCH 
SA must maintain liquidity resources sufficient to meet its liquidity 
requirements; \6\ (d) include the liquidity needs generated by the 
expiration of physically settled stock futures in the liquidity 
monitoring; and (e) require LCH SA, in calculating its required 
liquidity resources, to take into account that Clearing Members may 
switch from depositing non-cash collateral in a Full Title Transfer 
Account, which may be pledged at the BdF to obtain a liquidity line of 
credit, to depositing non-cash collateral instead in a Pledge Account, 
which permits no re-hypothecation rights.\7\
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    \5\ See, Framework, Sec.  4.2.5.
    \6\ See, e.g., Framework, Sec. Sec.  4.2.1, 5.1, 5.3.
    \7\ See, Framework, Sec.  4.2.5.2.4.
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    The proposed revisions to the Framework are set out in four of the 
Framework's six sections: Section 1, Model Scope, Purpose and Use; 
Section 4, Model Specifications; Section 5, Model Performance Testing 
and Ongoing Monitoring and Section 6, Appendix.\8\
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    \8\ No revisions are being proposed to Section 2, Limitations 
and Compensating Controls, or Section 3, Justification of Modeling 
Approach. The Framework also has a number of appendices, set out in 
Section 6, that supplement the matters discussed elsewhere in the 
Framework.
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    Section 1 of the Framework will be amended as follows:
    Section 1.1, Model Objective, Business Scope and Intended Use, will 
be revised to specify that the review of the Framework will be 
performed at least on an annual basis rather than quarterly to align 
the frequency of the review with the frequency defined for the regular 
update of the Liquidity Risk Policy.
    Section 1.1.1, Reminder of SA's activities, will be revised to 
specify that the Default Funds are calibrated on the assumption of 
default of the two most exposed Member Groups (Cover 2). In particular, 
LCH SA's Framework ensures that the liquid resources are sufficient to 
cover the simultaneous default of the two most exposed Member Groups in 
term of liquidity that are identified by taking into consideration all 
of the possible liquidity needs, including the settlement obligation. 
This is approach incorporates the Cover 1 Clearing Member Group plus 
the next most exposed Clearing Member Group.\9\
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    \9\ Per SEC Rule 17Ad-22(e)(7)(i), LCH SA is required to 
maintain sufficient liquid resources at the minimum in all relevant 
currencies to effect same-day and, where appropriate, intraday and 
multiday settlement of payment obligations with a high degree of 
confidence under a wide range of foreseeable stress scenarios that 
includes, but is not limited to, the default of the participant 
family that would generate the largest aggregate payment obligation 
for the covered clearing agency in extreme but plausible market 
conditions.
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    Section 1.1.2, Investment activities, will be revised to clarify 
the responsibilities of the Collateral and Liquidity Management 
(``CaLM'') Front Office team. Specifically, the sentence: ``Three main 
tasks have been assigned to the team: liquidity management, non-cash 
collateral settlement in case of a clearing member's default and 
investment management'' has been revised to read: ``Three main tasks 
have been assigned to the team: liquidity management, non-cash 
collateral liquidation \10\ in case of a clearing

[[Page 1953]]

member's default and investment management''. The purpose of this 
change is to provide a more accurate description on the actual 
responsibilities of the CaLM Front Office team which is in charge of 
performing all the relevant activities necessary to liquidate a 
member's non-cash collateral in case of defaults.
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    \10\ Such liquidation includes the possible liquidation of 
securities underlying reverse repurchase activities of a defaulting 
clearing member.
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    Section 1.3, Model dependency and interconnectivity, will be 
revised to describe more fully the purpose of the various policies and 
procedures that LCH SA employs to manage its liquidity risk in a manner 
that is consistent with defined risk appetites, as well as with 
regulatory and internal requirements. These policies and procedures 
include:
     LCH SA Liquidity Plan, which sets out the principles and 
procedures for liquidity management within LCH SA. Its main objectives 
are to:
    [cir] Ensure that LCH SA maintains sufficient liquidity at all 
times in accordance with policies set by the appropriate governance 
authority and monitored and reported by Risk Management;
    [cir] Ensure that liquidity management and resources are aligned 
with LCH SA's operational requirements to meet payment obligations as 
they fall due under business as usual and stressed liquidity 
conditions; and
    [cir] Ensure effective liquidity risk identification and escalation 
within CaLM service and other relevant LCH SA departments.
     Group Liquidity Risk Policy, which ensures that each 
central counterparty (``CCP'') of LCH Group has enough liquid resources 
on hand to meet all the expected and unexpected financial obligations 
that arise during the course of the day. The policy lays out how a CCP 
will measure whether there are enough available liquid resources.
     Group Financial Resource Adequacy Policy, which describes 
the standards by which financial resources should be assessed against 
Clearing Member exposures, including variation margins, initial 
margins, margin add-ons for liquidity risk, concentration risk, wrong-
way risk, where appropriate, as well as the sizing and re-sizing of the 
default funds across the LCH Group CCPs.
     Group Collateral Risk Policy, which sets out the standards 
for managing collateral risk across the LCH Group CCPs and ensures that 
CCPs must have a robust mechanism in place to process and control the 
collateral posted by Members.
     Group Investment Risk Policy, which sets out the standards 
for the management of investment risk across the LCH Group CCPs.
     LCH SA Collateral Control Framework, which describes the 
actions undertaken by the CaLRM team to implement the collateral limits 
laid out in the Group Collateral Risk Policy and to ensure that the 
prices integrated on a daily basis by the Margin Team are accurate and 
fairly priced.
     Group Risk Policy: Default Management, which describes the 
minimum standards that each CCP within the LCH Group must meet in 
dealing with the default of a Member.\11\
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    \11\ The CaLM Risk Procedures: Investment Risk Monitoring, and 
Default Management Guidelines, which currently are included among 
these policies and procedures, have been removed.
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     Section 1.4, Model Governance, will be revised by adding a 
footnote specifying that core liquidity reverse stress tests \12\ are 
performed monthly in line with that stated in the Liquidity Risk 
Policy. In particular LCH SA performs two set of reverse stress test:
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    \12\ See, Framework, Sec.  5.3.
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    [cir] On a monthly basis, in line with the methodology applied to 
perform any reverse stress tests in LCH SA, risk factors (defined in 
section 5.3.1) are independently stressed (one single factor at time) 
to assess extreme market conditions necessary to observe a breach of 
the LCR limit.
    [cir] In addition, combined reverse stress test scenarios (defined 
in section 5.3.2) are also performed on at least a quarterly basis. 
These combined scenarios are considered as ``non-core reverse stress 
tests'' with combined stress shocks applied on risks factors to 
determine the joint market conditions necessary to breach the LCR limit 
and assess their plausibility. This change to the Framework is being 
proposed to align it with the updated Liquidity Risk Policy text 
approved during the 2022 review and in compliance with the SEC rule 
17Ad-22(e)(7)(vi)(B).\13\
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    \13\ 17 CFR 240.17Ad-22(e)(7)(vi)(B).
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    [cir] Finally, Section 1.6.1, Liquidity Sources, will be revised to 
expand the tools available to CaLM to meet LCH SA's non-Euro liquidity 
requirements in the event of a default. This proposed change aims to 
align the Framework with the updated Liquidity Plan text approved 
during the 2022 review.
    Specifically, these tools include:
     Non-Euro cash deposited as collateral in accordance with 
SEC Rule 17Ad-22(a)(14)(i) \14\ as being cash held at creditworthy 
commercial banks;
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    \14\ 17 CFR 240.17Ad-22(a)(14)(i).
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     Sale of non-Euro securities of the defaulting member in 
accordance with SEC Rule 17Ad-22(a)(14)(ii) \15\:
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    \15\ 17 CFR 240.17Ad-22(a)(14)(ii).
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    [cir] These highly liquid and available securities would be 
converted into cash via an outright sale in the open market; or
    [cir] in the intermediary period between the default of the member 
and the auction settlement, these securities might be converted into 
cash via the repo arrangement in place at CaLM Front Office.
     Repo transactions, including: (a) bilateral repo 
transactions (non-Euro cash taker and non-Euro collateral giver); (b) 
cross-currency bilateral repo (non-Euro cash taker and Euro collateral 
giver); (c) cross-currency triparty repo (non-Euro cash taker and Euro 
collateral giver). LCH SA considers these transactions to be classified 
as prearranged funding arrangements determined to be highly reliable 
even in extreme but plausible market conditions due to (a) their 
contractual nature; and (b) the highly liquid and overall resilience of 
the repo markets for the major currencies cleared by LCH SA.
     Use of the multicurrency overdraft facility. In accordance 
with SEC Rule 17Ad-22(a)(14),\16\ LCH SA considers this facility to be 
classified as a prearranged funding arrangement determined to be highly 
reliable even in extreme but plausible market conditions due to (a) its 
contractual nature; and (b) the high credit quality, based on the 
conservative internal credit score required of the bank providing the 
facility.
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    \16\ 17 CFR 240.17Ad-22(a)(14).
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     Use of the FX spot market transactions. In accordance with 
SEC Rule 17Ad-22(a)(14),\17\ LCH SA considers this facility to be 
classified as a prearranged funding arrangement determined to be highly 
reliable even in extreme but plausible market conditions as (a) 
numerous counterparties are already onboarded on the FX platform; and 
(b) the highly liquid and overall resilience of the FX markets observed 
for the major currencies cleared by LCH SA.
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    \17\ Id.
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     ECB weekly tender in U.S. Dollars (``USD'').\18\ In 
accordance with SEC Rule 17Ad-22(a)(14) \19\ LCH SA considers this 
facility to be a prearranged funding arrangement determined to be 
highly reliable even in extreme but plausible market conditions given 
LCA SA's banking license and the central bank

[[Page 1954]]

status of the institution providing such resource.
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    \18\ As a credit institution, LCH SA has access to the ECB Open 
Market Operations in USD. LCH SA considers this resource as a last 
resort.
    \19\ 17 CFR 240.17Ad-22(a)(14).
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     Replace LCH SA's liabilities in non-Euro by Euro, as 
permitted by LCH SA's Rule Book (Article 4.2.3.2 of CDSClear 
Rulebook).\20\ In accordance with SEC Rule 17Ad-22(a)(14) \21\ Euros 
used to cover liabilities would be cash held at central bank.
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    \20\ See Article 4.2.3.2., https://www.lch.com/system/files/media_root/Supplementary%20Materials%20-%20LCH%20SA%20-%20CDSClear%20SA%20Rule%20Book_1.pdf.
    \21\ 17 CFR 240.17Ad-22(a)(14).
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    Furthermore, the committed liquidity line previously noted is being 
removed as LCH SA has replaced the committed liquidity line with a 
multicurrency overdraft facility at a major international bank.
    In summary, LCH SA classifies the different liquidity tools 
pursuant to SEC Rule 17Ad-22(a)(14),\22\ as follows:
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    \22\ Id.
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     Cash--Euros cash held at central bank/non euros cash held 
at creditworthy commercial banks; replacement of LCH SA's liabilities 
in non euros by euros
     Uncommitted prearranged--readily available assets 
convertible to cash through prearranged funding arrangements, that are 
determined to be highly reliable even in extreme but plausible market 
conditions by the BoD following a review to be conducted not less than 
annually:
    a. Sale of non-Euro securities of the defaulting members;
    b. Repo transactions (bilateral repo, cross currency bilateral 
repo, and cross currency triparty repo);
    c. Multicurrency overdraft facility;
    d. FX spot market transactions; and
    e. ECB weekly tender in U.S. dollars
    Additionally, a footnote (8) has been removed as the relevant 
report has been taken out from the appendix in the context of the 
reorganisation of the appendix 5 as described below in the relevant 
section in the present 19b4.
    Section 1.6.1.1, Collateral transfer, will be revised to recognize 
that a Clearing Member may deposit non-cash collateral either (a) by 
Full Title Transfer Accounts that LCH SA maintains at various central 
securities depositories or (b) by a Single Pledged Account, without the 
right of re-hypothecation, that LCH SA maintains at Euroclear Bank.\23\ 
This section will be further revised to clarify that non-cash 
collateral deposited in Full Title Transfer Accounts may be pledged at 
the BdF to obtain a liquidity line of credit that can be drawn on 
intraday or overnight, if needed. Additionnaly, precisions have been 
added regarding:
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    \23\ Currently, non-cash collateral may be pledged without 
limits only with regard to the CDSClear service. Moreover, there are 
limits on the amount of pledge collateral that may be deposited for 
RepoClear, [euro]GC (Tri-Party Repo) and EquityClear. The majority 
of the collateral that LCH SA currently collects is by Full Title 
Transfer.

--the existing limits applied on Repoclear SA/[euro]GC Plus and 
EquityClear SA for pledge
--the fact that FFTA is used in majority by Clearing Members

Finally, to enhance the wording, a precision has been added to precise 
that only resources received in FFTA can be pledged to 3G pool.
    The change aims to improve the clarity of the document as there is 
no change applied on the actual offer of collateral account.
    Section 1.6.1.2, Assessment of assets' liquidity, will be revised 
to provide that Tier 1 assets, i.e., securities that are deemed to be 
of sufficient quality and demand to generate liquidity in the event of 
a default or a major market stress at little or no loss, will include, 
in addition to all European Central Bank (``ECB'') eligible collateral, 
UK Gilts and U.S. Treasury Bills, along with Dutch and Belgian central 
bank guarantees (but only for the defaulting Clearing Member). In 
addition, recognized Tier 3 assets, i.e., assets that are deemed to 
have little or no liquidity value in the event of a default or major 
market stress, or are deemed to be too illiquid to be converted in the 
timeframe that LCH SA would need the liquidity, will be revised to 
include non-cash collateral denominated Danish Krone, Norwegian Krone, 
Swedish Krona, Japanese Yen, Swiss Francs, Canadian Dollars and 
Australian Dollars.
    Section 1.6.1.3, Synthesis, will be revised to clarify that LCH SA 
does not retain the right of collateral re-hypothecation for collateral 
deposited under the pledge regime unless the Clearing Member is in 
default. The reference specific to CDS has been removed as now the 
pledge is offered for all LCH SA services. It will confirm that CaLM 
demonstrated in 2021 and 2022 the ability to raise Euro liquidity from 
non-Euro non cash collateral in USD and GBP. Moreover, it will clarify 
that when considering non-Euro non cash collateral as a liquidity 
source, a conservative buffer of ten percent (10%) is applied to absorb 
market stress that may occur beyond the volatility already captured by 
the all-in haircut. In addition, it will confirm that Central Bank 
guarantees can be considered for liquidity purposes only if the 
relevant Member posting them is in default because only in that 
situation the CCP would acquire full ownership of the guarantee 
provided by the Central Bank.
    Section 1.6.2.1, Liquidity needs arising from members' defaults, 
will be revised to clarify the description of the liquidity needs that 
may arise from settlement. The following sentence: ``Cash outflows are 
generated when SA has to step in on behalf of the defaulted member to 
post cash to non-defaulting member(s) and take in the underlying 
collateral'' has been revised to read: ``Cash outflows are generated 
when SA has to step in on behalf of the defaulted member to post cash 
to non-defaulting member(s) and take in the underlying securities''. 
This change is being made to increase the accuracy of the document and 
does not represent a change in the methodology or procedure of LCH SA.
    Moreover, LCH SA will also specify that the value of the bonds 
pledged at the ECB to raise liquidity takes into account stress market 
conditions.\24\ The addition of the ``stress market conditions'' is 
thus performed for clarity in line with adjustments performed in the 
LCR model assumptions.
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    \24\ A detailed presentation of the model enhancement is 
reflected in Section 4.2.5.1.1.2 of the Framework.
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    Section 4 of the Framework, which explains the modelling Framework 
in detail, will be amended, as noted above, to enhance the manner in 
which the LCR is calculated, thereby increasing the robustness of LCH 
SA's liquidity profile. This section discusses first, the calculation 
of the Operational Target, i.e., the amount of liquidity required to be 
held to satisfy LCH SA's liquidity needs related to the operational 
management of LCH SA in a stressed environment, but one that does not 
lead to a Clearing Member's default. The Operational Target ensures 
that LCH SA's liquidity resources are always greater than its 
operational liquidity requirements.
    Section 4.1.2, Model inputs and Variable selection, will be revised 
to clarify that the repayment of excess cash as well as excess ECB 
eligible securities deposited to cover margin requirements are 
considered in the liquidity requirement of the Operational Target. Two 
footnotes will be updated to specify that Portuguese and Finnish 
government bonds posted via the triparty solution are excluded from the 
liquid assets (repayment of excess cash and stressed margin reduction) 
because these securities are not transferrable to the BdF due to 
operational constraints. These changes will increase the accuracy of 
the document and does not represent a change in the methodology or 
procedure of LCH SA. Finally, the change of branding from CC&G to

[[Page 1955]]

Euronext Clearing has been performed in line with the change of 
branding performed in the whole documentation and described below in 
the present 19b4.
    Section 4.1.4, Mathematical formula, derivation and algorithm, and 
numerical approximation, will be revised to clarify that the 
Operational Target is calculated as the sum of the liquidity 
requirements described in Section 4.1.2 and that the liquidity 
requirements must always be lower than the resources available. This 
change will increase the accuracy of the Framework and does not 
represent a change in the methodology or procedure of LCH SA.
    Section 4.1.5, Model assumptions, will be revised to provide that 
liquidity resources must be sufficient to meet LCH SA's liquidity 
requirements for the next seven (7) days in stressed situations. This 
section currently provides that liquidity resources must be sufficient 
to meet LCH SA's liquidity requirements for the next five (5) days.\25\ 
The change incorporates a model validation recommendation to extend the 
LCR and consequently also the Operational Target to a 7 day period in 
order to align the liquidity monitoring time horizon to the RepoClear 
service new maximum holding period to manage a default (changed from a 
3-day to 5-day holding period since the end of June 2022, to which LCH 
SA added 2 days of settlement convention). Additionally, to enhance the 
clarity, details related to the management of the former horizon have 
been removed in order to clearly state that the horizon is 7 days and 
results will be displayed without any aggregation.
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    \25\ Consistent with this change, LCH SA will take into account 
the maximum daily switches from cash and ECB eligible cash 
securities to non-Euro denominated securities observed over seven 
(7) days rather than five (5) days, as currently provided.
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    In addition (4.1.5.d), the provisions of this section describing 
the liquidity requirements drivers, which assume, in part, that 100 
percent (100%) of the excess cash and excess ECB eligible securities 
will be withdrawn over the 3-day period will be revised. Specifically, 
the assumptions that the two largest individual Clearing Members will 
withdraw their excess on day one (T) and that the third and fourth 
largest Clearing Members will withdraw their excess on day two (T+1) 
will be revised to provide instead that (a) the two Clearing Member 
Groups that have the largest amount of excess collateral will withdraw 
their excess on T, and (b) the third and fourth Clearing Member Groups 
that have the next largest amount of excess collateral will withdraw 
their excess on T+1. In each case, the remaining Clearing Members will 
withdraw their excess on the third day (T+2). Precision on the footnote 
to specify that Portuguese and Finnish government bonds posted via the 
triparty solution are excluded from the liquid assets as these 
securities are not transferrable to the BdF due to operational 
constraints.
    For the liquidity requirement that aims to quantify the potential 
substitution of cash collateral/ECB eligible securities (4.1.5.e), LCH 
SA will take into account the maximum daily switches from cash and ECB 
eligible cash securities to non-Euro denominated securities observed 
over seven (7) days rather than five (5) days as currently provided to 
incoroporate the model valitation recommendation. In order to be 
consistent with this change from five to seven days in the time 
horizon, two additional definition of amount of switch corresponding to 
T+5 and T+6 have been added. Moreover, it will be clarified that on Q3 
2022 CaLM Front Office demonstrated the ability to transfer ECB 
eligible securities to BdF within 30 minutes for all eligible 
countries. The list of specific countries will be removed from the 
Framework as it is dynamic and depends on the collateral eligible at 
the CCP that can be found on the LCH SA website (a footnote will be 
added to point towards website). With respect to the amount of equity 
lodged, as LCH SA takes the maximum amount of switched observed, the 
reference to 100 million will be removed as the amount is a dynamic 
figure. It will also be precised that the amount of equity deposited 
over the past 3 years which is also a dynamic figure remains 
negligible. These changes will improve the accuracy of the Framework 
and do not represent a change in the methodology or procedure of LCH 
SA.
    For Section 4.1.5.f which describes the potential intraday 
additional liquidity injection that may generate securities carried 
overnight it will be specified that the amount is calibrated as the 
maximum EOD securities carried over night over the whole time series 
available. This change will increase the accuracy and clarity of the 
Framework and does not represent a change in the methodology or 
procedure of LCH SA.
    Moreover, Section 4.1.5.g will be revised to modify the targeted 
estimated margin reduction of non-defaulting Clearing Members. 
Currently, estimated margin reduction is calculated over a three-day 
period. As revised, targeted estimated margin reduction will be 
calculated over seven (7) consecutive days to address model validation 
recommendation.\26\ To reflect this change, a detailed table has been 
added describing the margin reduction rate per day of the horizon 
period in line with the above In order to enhance the wording, two 
bullet points have been revised to state that (a) margin reduction 
applied is greater than the biggest one observed in the historical 
window considered for the calibration (b) for each day, the reduction 
is over the 99,7% percentile on the available set of data. In order to 
precise the size of the lookback period of observation, a footnote will 
be added detailing the current start date and end date. One footnote 
will be also updated to provide that Portuguese and Finnish government 
bonds posted via the triparty solution are excluded from the liquid 
assets because such securities are not transferrable to the BdF due to 
operational constraints.
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    \26\ The overall compounded margin reduction will be above the 
maximum historical 7-day margin reduction observed.
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    These additional changes will increase the accuracy and clarity of 
the document and does not represent a change in the methodology or 
procedure of LCH SA.
    Finally, Section 4.1.5.h will be reworded to specify that the 
liquidity requirements stemming from estimated Variation Margin payment 
to be processed towards the interoperable CCP is calculated on the 
basis of the Initial Margin actually posted at LCH SA to cover a 5-days 
holding period to be spread out over a 5-days period according to a 
simulated market stress based on historical yield shifts (third bullet 
point). The rewording of the introduction of 4.1.5.h aims to clarify 
the computation of the theoretical allocation of IM (leading to the 
removal of one footnote that was duplicated) as well as to reflect the 
change of branding. These changes will increase the accuracy and 
clarity of the document and does not represent a change in the 
methodology or procedure of the LCH SA.
    As mentioned, Please also note that reference to the depth of time 
series (4.1.5.e and 4.1.5.f) are proposed to be removed as available 
set of data are wider and every points are considered. This would avoid 
LCH to periodically review the depth in the wording.
    Finally, the notion ``DF'' has been added in 4.1.5.i to reflect the 
usual acronym of the default fund. The review was the opportunity also 
to correct a typo in the third bullet point of this section.
    Section 4.2 of the Framework, LCR, which describes the manner in 
which

[[Page 1956]]

the LCR is calculated, will be revised as follows:
    Section 4.2.1, Model overview, will be revised to provide that the 
purpose of the LCR Cover 2 scenario is to allow LCH SA to ensure that 
it has enough liquidity in the case of default of the two largest 
Members Groups during the seven (7) days following the default, rather 
than five (5) days, as is currently provided. Moreover the sentence: 
``3 days holding period of margin collateral, i.e., SA ensures it has 
sufficient liquidity to meet non-defaulting member's cash requests even 
if SA is waiting for the defaulter's margin collateral to be 
liquidated'' will be revised to read: ``5 days holding period of margin 
requirement, i.e., SA ensures it has sufficient liquidity to meet non-
defaulting member's cash requests even if SA is waiting for the 
defaulter's position to be liquidated''. These changes will enhance the 
accuracy and clarity of the document and do not represent a change in 
the methodology or procedure of LCH SA (i.e., ``requirement'' is an 
enhanced wording as the objective is to cover the clean risk 
(collateral might include excess). Similarly, ``positions'' better 
clarifies the liquidity needs that are present until the final 
liquidation of the complete position of the Defaulted Members.
    Further, the sentence: ``The ERCO has approved the 5 days liquidity 
horizon as per the article 22 of the Group liquidity risk policy'' will 
be revised to read: ``The ERCO has approved the 7 days liquidity 
horizon as per the Group liquidity risk policy''. The change will 
remove a dependency between the two documents as the number of articles 
may change when the Group Liquidity Policy is updated on an annual 
basis, while ensuring that the policy content is referred in the 
Framework.
    Finally, the sentence: ``The cover 2 is computed by taking into 
account the liquidity risks related to clearing members within the same 
group across all services within the CCP that are aggregated'' will be 
revised to read: ``The cover 2 is computed by taking into account the 
liquidity risks related to clearing members within the same group 
across all services of the CCP that are then aggregated''. These last 
changes do not trigger any methodology changes but have been amended to 
enhance the clarity. The reference to footnote (24) is proposed to be 
removed as it refers to a non existing footnote (typo).
    Section 4.2.2, Model inputs and Variable selection, and Section 
4.2.4, Mathematical formula derivation and algorithm and numerical 
approximation, will be revised to provide that securities pledged at 
the BdF and included among Total Available Assets will be valued at 
stressed market prices and include the ECB haircut effect on the 
resulting figures. The notion of ``for each market'' is proposed to be 
removed to preserve clarity. At the same time for the computation of VM 
erosion, the market risk impact arising from the contractual settlement 
of RepoClear will be excluded from the computation of the component as 
treated on the asset side as previously described (i.e., the component 
that was previously considered in liabilities will be incorporated in 
the assets as a reduction of the amount of liquidity sourced from the 
clearing securities pledged to BdF, cf 4.2.4.c). For this purpose, the 
sentence ``on top of which is added the market stress risk impact on 
the contractual settlement for repoClear'' will be removed. These 
changes have the purpose of adressing a model validation recommendation 
to enhance the treatment of market stress in the computation of 
liquidity sourced by the Central Bank.
    Moreover an update of wording will be done to consider the Total 
Default Liabilities and Total Available Assets as plural rather than 
singular as currently the case. It will be specified that in the VM 
Erosion calulation all LCH SA services are considered that is Cash & 
Derivatives, Repoclear, EGC, and CDS markets. Two footnotes will be 
updated to specify that Portuguese and Finnish government bonds posted 
via the triparty solution are excluded from the liquid assets because 
not transferrable to the BdF due to operational constraints (4.2.2/
4.2.4). These changes have will increase the accuracy and clarity of 
the document and do not represent a change in the methodology or 
procedure of LCH SA.
    Finally, additional clarifications will be made regarding the 
treatment of FCM/BD client resources in the LCR. In particular, LCH SA 
will further specify that in a context of default (and purpose of the 
LCR monitoring) LCH SA will only treat FCM/BD client collateral as 
available liquidity resources if and only if this FCM/BD client 
defaults and generates some liquidity needs. Its resources will not be 
considered as available liquidity assets for any other FCM/BD clients 
and/or the FCM/BD clearing member or any other clearing member of the 
CCP. In particular, in case of one FCM/BD client defaulting, other FCM/
BD clients assets will not be considered to cover the liquidity needs 
of the defaulting FCM/BD client. These changes are also replacing 
``clearing member'' with client where relevant to increase clarity.
    The changes will enhance the accuracy and clarity of the document 
and does not represent a change in the methodology or procedure of LCH 
SA.
    Section 4.2.5, Model Assumptions, describes the various risks that 
each business line must consider in determining liquidity requirements 
as well as other liquidity requirements that LCH SA must meet.\27\ 
Title of Section 4.2.5.1 will be changed to `Description of risks per 
Business line' to reflect that different risks are tackled in different 
sub section.
---------------------------------------------------------------------------

    \27\ As noted earlier, in addition to its CDSClear service, LCH 
SA provides clearing services in connection with cash equities and 
derivatives listed for trading on Euronext (EquityClear), commodity 
derivatives listed for trading on Euronext (CommodityClear), and 
tri-party Repo transactions (RepoClear). LCH SA also maintains an 
interoperability link with Euronext Clearing.
---------------------------------------------------------------------------

    Section 4.2.5.1.1, RepoClear, will be revised to provide that 
settlement cash outflows will be calculated over a period of 7 days and 
on a gross basis, aggregated by ISIN, settlement date and Clearing 
Member level. The final settlement outflows are then aggregated at the 
Clearing Member Group level without allowing any netting across members 
of the same Clearing Member Group. The objective of these changes is to 
address two model validation recommendations: to align the LCR 
liquidity monitoring period to the RepoClear new maximum holding period 
to manage a default (5 days holding period of margin +2 of settlement 
convention); and to not allow any netting between entity of the same 
Group. Moreover, a table summarizing the liquidity requirements 
according to the direction of the repo transactions as well as a 
paragraph describing the specific treatment of forward starting repo in 
the calculation of the settlement obligation outflows have been removed 
because a new enhanced algorithm was designed and described in the new 
sections 4.2.5.1.1.1 and 4.2.5.1.1.2 as described later in the present 
form. One bullet point is proposed to be removed as well as the 
sentence ``Note that the post default date forward start leg of cash 
borrower transaction are excluded for the LCR calculation (e.g., starts 
date: Default date + 1 day and returns legs: Default date +2). The 
transactions are performed through DVP so LCH SA will fail to deliver 
the securities leading no liquidity requirements related to the returns 
legs to factor in the LCR to keep consistency with the new algorithm.
    Section 4.2.5.1.1.1, Liabilities contractual obligations on 
physical delivery, will describe the methodology

[[Page 1957]]

to compute liabilities due to settlement obligations. In particular, in 
case of default, LCH SA shall assume and honour the obligations of the 
defaulted Members. In case of securities with physical settlement, this 
may represent substantial liquidity needs for LCH SA. The enhanced 
methodology presented in this section leverages on the actual 
management of settlement instructions performed by the Fixed Income 
Operations department during an event of default to fully take into 
account in the calculation of the liquidity needs the specific 
settlement dynamics over the time horizon of the LCR with the objective 
to more closely align the computation of the LCR with the actual 
default management process.
    To model the settlement obligation, the DCO would start by 
constructing the contractual balance of net buyer/seller position by 
Clearing Member, ISIN and date within the LCR time horizon:
    1. Identify transactions (each leg independently for repos) that 
settles within the time horizon of the LCR and allocate, to the 
settlement date, the contractual cash amount to be settled and the 
corresponding nominal of securities to be delivered; and
    2. Aggregate cash amounts and nominals by member, ISIN and date.
    This contractual view of cash and security flows is then adjusted 
to take into account the eventual effect of carrying forward the 
liquidity position (the effect of one day fails on the contractual 
flows of the following dates). In fact, in case of a net seller 
position on date t, LCH SA would fail to deliver securities if they are 
not already sourced and/or pledged at the BdF and would continue to 
fail until the date t' on which the balance is net buyer (or until the 
end of the time horizon when the portfolio would be perfectly matched 
again). In that case, LCH SA would receive no cash on date t for the 
securities in which it fails to deliver and would need to inject less 
cash into the settlement system on date t' because of the netting 
effect of carrying forward. The real cash injection flows obtained are 
aligned with the Operations Team view of the settlement obligation in 
case of default.
    When the real cashflow injections are obtained as described above 
for each member they are then aggregated at group level.
    A simplified numerical example is provided to demonstrate the 
sequence of steps used to calculate the liquidity needs deriving from 
settlement obbligation.
    The changes described in this section will improve the liquidity 
monitoring of LCH SA and address two model validation recommendations: 
to improve the liquidity needs estimation related to Settlement Risk 
and to not allow any netting between entity of the same Group.
    Section 4.2.5.1.1.2, Assets: settlement securities pledged at 
Central Bank, will describe the methodology to compute the liquidity 
raised through the pledge at a Central Bank of the settlement 
securities withdrawn from the settlement system on behalf of the 
defaulter. In particular, when LCH SA pledges eligible securities at 
the Central Bank in exchange of liquidity, two important factors need 
to be considered:

--the market price of the securities that may be decreased by 
unfavorable market conditions therefore reducting the value of the 
collateral and consequently the amount of liquidity that can be sourced 
out of it; and
--the haircut applied by the Central Bank when lending cash to LCH SA 
in exchange of securities.

    The changes described in the following paragraph provide a summary 
of the calculation performed by the DCO when modelling the liquidity 
that it would be able to source from the Central Bank.
    The amount raised is the sum of the unstressed assets value after 
taking into account the ECB haircut and a stress price market impact 
applied to the value of the securities. In order to calculate the 
amount of liquidity raised from the BdF, LCH SA will consider the real 
security flows calculated in Section 4.2.5.1.1.1 which are equivalent 
to securities pledged at/retrieved from the BdF (with an opposite 
direction with respect to settlement). The securities are then valued 
at current market price at the moment of default with the application 
of an ECB haircut. To quantify the market impact, a preliminary 
screening is applied in order to identify correctly only the subset of 
transactions to which the market impact applies because they are not 
covered by offsetting inflow. In particular for long cash transactions 
or Cash Borrower Repo--Return Leg:
     Before the settlement date: an eventual bond price 
decrease would result in a margin decrease of the non-defaulting member 
due to Variation Margin credit which is accounted for in the LCR 
liabilities in a separate entry.
     On the settlement date: LCH SA would get the securities 
from the non-defaulting member, pledge them at the BdF and receive an 
amount of cash equal to the stressed price of the bond minus the 
haircut. The additional liquidity impact, with regards to the 
unstressed assets described previously, rises from the bond price move 
from the default date until the settlement date. Hereunder, we will 
refer to this component by ``Settlement Market Price Impact''.
     After the settlement date: once the bond is pledged 
overnight, the price decrease afterwards would trigger an additional 
liquidity impact to cover the cash that needs to be returned to the BdF 
because of the lower amount of the collateral deposited, i.e., the 
price move from the settlement date until the date on which LCH SA will 
have a settlement obligation to deliver the bond (or until the book is 
perfectly matched again after the settlement of the auction). 
Hereunder, we will refer to this component by ``Pledge Market Price 
Impact''.
    The total market impact is calculated as the sum of Settlement 
Market Price Impact and Pledge Market Price Impact. The bond prices 
moves generating the market impact is calculated in accordance with 
RepoClear stress test scenarios. The final amount of liquidity 
retrieved from the BdF resulting from the pledge of securities 
retrieved from settlement on behalf of the defaulted members will be:

Liquidity retrieved from the BdF (t) = Real Security Flow * Market 
Price at moment of default * (1-ECB Haircut)-Settlement Market Price 
Impact-Pledge Market Price Impact.

A simplified numerical example is added to the Framework to demonstrate 
the sequence of steps used to calculate the liquidity amount retrieved 
from the BdF.
    The change will improve the liquidity monitoring of LCH SA and 
address a model validation recommendation to improve the liquidity 
needs estimation related to Market Risk.
    To remain consistent with the calculation of settlement 
obligations, after calculating the Liquidity retrieved from the BdF for 
all dates in the LCR period at Member level, the amounts are aggregated 
at the Clearing Member Group level. This change address a model 
validation recommendation.
    Section 4.2.5.1.1.3, Market Risk, will be revised to provide that, 
in addition to the settlement obligations driven flows, the position of 
the defaulter may generate a liquidity drain for LCH SA in the form of 
negative mark to market to be paid to non-defaulting members. The 
formula to estimate this amount is changed and will consider the worst 
stress loss of the defaulter position according to the relevant 
RepoClear stress test scenario and add additional margin to model any 
concentration,

[[Page 1958]]

market liquidity issues. The purpose of this change is to address a 
model validation recommendation by improving the liquidity needs 
estimation related to Market Risk in the LCR. Additionally, a footnote 
will be added to disclose that a list of stress scenario is reported in 
appendix 6.7.
    Section 4.2.5.1.2, [euro]GCPlus, will be revised to provide that, 
when calculating the settlement driven cash outflows, the aggregation 
is based on data provided by the triparty agent and that only positions 
in which the defaulter is a cash borrower (collateral giver) in the 
first leg of the repo and, therefore, collateral taker when the repo 
closes, generate a liquidity need. Therefore, in case of default of a 
Member collateral giver in the first leg, LCH SA has to inject cash and 
withdraw securities when the repo closes (cf new footnotes).
    Finally a repetition of words have been cancelled to remove 
redundancy in the text. The changes will enhance the accuracy and 
clarity of the Framework and do not represent a change in the 
methodology or procedure of LCH SA.
    Section 4.2.5.1.2.1, Market risk, will be revised to provide that 
for [euro]GCPlus the additional liquidity needs generated by negative 
mark to market payments to non-defaulting members is estimated in line 
with what is done for RepoClear \28\ as the worst stress loss of the 
defaulter position according to the relevant [euro]GCPlus stress test 
scenario and adding additional margins. The change will incorporate a 
model validation recommendation by improving the liquidity needs 
estimation related to Market Risk in the LCR.
---------------------------------------------------------------------------

    \28\ Please refer to changes to section 4.2.5.1.1.3 described in 
the present document.
---------------------------------------------------------------------------

    Moreover, a numerical example has been added to the Framework to 
demonstrate that the eventual BdF haircut will always be covered by the 
collateral posted by the collateral giver as requested by the current 
margin methodology (corresponding to ``Example''). The change will 
increase the accuracy and clarity of the document and does not 
represent a change in the methodology or procedure of LCH SA.
    Section 4.2.5.1.3.1, Cash Equity, will be revised to provide that 
the settlement cash outflows will be calculated on a gross basis at the 
Clearing Member level and then aggregated at the Clearing Member Group 
level without allowing any netting across the Clearing Members of the 
same Group. The objective of the change is to enhance the accuracy and 
clarity of the document and does not represent a change in the 
methodology or procedure of LCH SA.
    Moreover, the methodology to consider among the liquidity 
requirements the equity settlement arising from the expiration of 
physically settled futures is detailed. In particular, in case the 
defaulting member is long futures which expire during the LCR horizon, 
LCH SA will have to pay the future price to the non-defaulting 
counterparty in order to settle the physical underlying. Therefore the 
enhanced algorithm daily identifies all the potential maturing long 
futures positions on the day of the computation and on the upcoming 
business day as well, identifies the positions of the Cover 2 Members 
Group and finally, given the potential physical settlement, adds the 
relevant liquidity needs to the computation of the LCR. A numerical 
example is included to provide a sample of the calculation.This change 
has the purpose of addressing a model validation recommendation by 
including the liquidity needs related to the expiry of physical 
delivery single stock futures in the LCR.
    In addition, this section will provide that the liquidity needs 
generated by negative mark to market payments to be made to non-
defaulting members is changed in line with what is done for the other 
LCH SA services \29\ (RepoClear, [euro]GCPlus, CDSClear) and will be 
calculated as the worst stress loss of the defaulter position according 
to the relevant EquityClear stress test scenario with the addition of 
additional margins.
---------------------------------------------------------------------------

    \29\ Please refer to changes for Sections 4.2.5.1.1.3, 
4.2.5.1.2.1 and 4.2.5.1.4 described in the present document.
---------------------------------------------------------------------------

    The objective of the change is to incoporate a model validation 
recommendation by improving the liquidity needs estimation related to 
Market Risk in the LCR.
    A footnote has been added to improve the accuracy of the document 
to specify that the full list of stress scenarios used is presented in 
a dedicated Appendix.
    Finally, this section will explain that because equities are not 
eligible at the BdF they will not be considered as liquidity sources in 
the assets of the LCR. The change will increase the accuracy and 
clarity of the document and does not represent a change in the 
methodology or procedure of LCH SA.
    Section 4.2.5.1.3.2, Listed derivatives, will be revised to clarify 
that futures on equity index contracts are included among the listed 
derivatives instruments considered in the calculation of the LCR and 
that derivatives expirations occur on a monthly basis rather than the 
previously stated quarterly basis. These changes will improve the 
accuracy and clarity of the document and does not represent a change in 
the methodology or procedure of LCH SA (i.e., monthly expiry is already 
efficiently implemented in the computation of the LCR).
    The calculation of the liquidity needs generated by negative mark 
to market payments to be done to non-defaulting members is changed in 
line with what is done for the other LCH SA services \30\ (RepoClear, 
[euro]GCPlus, CDSClear) and will be calculated as the worst stress loss 
of the defaulter position according to the relevant EquityClear stress 
test scenario with the addition of Additional margins. The change will 
address a model validation recommendation by improving the liquidity 
needs estimation related to Market Risk in the LCR. Finally, please 
note scenario is now stated in plural to reflect that several scenarios 
(disclosed in appendix 6.7) are used to model stressed VM.
---------------------------------------------------------------------------

    \30\ Id.
---------------------------------------------------------------------------

    Section 4.2.5.1.4, Credit Default Swaps, will be revised to clarify 
that the calculation of the liquidity needs generated by negative mark 
to market payments to be done to non-defaulting members is changed in 
line with what is done for the other LCH SA services \31\ (RepoClear, 
[euro]GCPlus, EquityClear) and will be calculated as the worst stress 
loss of the defaulter position according to the relevant CDSClear 
stress test scenario with the addition of additional margins. The 
change adresses a model validation recommendation by improving the 
liquidity needs estimation related to Market Risk in the LCR. Finally, 
please note scenario is now stated in plural to reflect that several 
scenarios (disclosed in appendix 6.7) are used to model stressed VM.
---------------------------------------------------------------------------

    \31\ Please refer to changes for Sections 4.2.5.1.1.3, 
4.2.5.1.2.1, 4.2.5.1.3.1 and 4.2.5.1.3.2 described in the present 
document.
---------------------------------------------------------------------------

    A footnote have been added to improve the accuracy of the document 
to specify that the full list of stress scenarios is disclosed in a 
dedicated Appendix.
    Section 4.2.5.2 will be revised to modify those provisions of the 
Framework relating to the other liquidity requirements to be taken into 
account in calculating the LCR.
    Section 4.2.5.2.1 will be revised to provide that the Operational 
Target to be included in the calculation of the LCR will be restated by 
removing margin outflows calculated in the Operational Target and 
related to Cover 2 for LCR. This is because LCH SA has the right to 
fully use the collateral of the

[[Page 1959]]

defaulters including excess. The changes enhance the accuracy and 
clarity of the document and do not represent a change in the 
methodology or procedure of LCH SA.
    Section 4.2.5.2.2, Margin non-cash collateral, will be revised to 
provide that LCH SA will compute the pure stress loss of such 
collateral rather than the stress loss over haircut (less conservative) 
as currently stated, by applying a set of stress scenarios used by 
RepoClear in the calibration of the Default Fund and choosing the one 
that generates the biggest liquidity exposure in terms of Cover 2. The 
choice of application of Repoclear scenarios is driven by the fact that 
only bonds deposited as collateral can be used to raise liquidity while 
equities are completely excluded from the calculation of liquid assets. 
The change aims to improve the liquidity monitoring by leveraging on 
the same coherent scenarios for all bonds position included in the LCR 
computation. A list of scenarios is disclosed in appendix of the LRMF.
    Section 4.2.5.2.3, CaLM investments, will be revised to specify 
that when calculating the liquidation losses related to the collateral 
posted by the defaulting Member through the reverse repo activity and 
the potential outright purchases losses deriving from the CCP 
portfolio, LCH SA will apply the driving stress scenario chosen among 
the set of scenarios from RepoClear consistent with the determination 
of the Cover 2 described in section 4.2.5.4. ``Potential'' has been 
added because the loss on the outright portfolio will be only realized 
if the DCO is forced to sell the portfolio because of liquidity needs 
and does not wait until maturity. The changes will increase the 
accuracy and clarity of the document and do not represent a change in 
the methodology or procedure of LCH SA.
    Section 4.2.5.2.4, Collateral pledge modelling, is added to 
describe in details how pledged collateral has to be modelled when 
calculating the asset of the LCR. In particular LCH SA assumes that 
Clearing Members will utilize their ability to pledge collateral near 
the maximum allowed on each LCH SA service and, therefore, this amount 
will be subtracted from the amount of non-cash collateral included in 
the LCR assets.
    The expected additional pledge will be calculated as the difference 
between the Maximum pledge capacity scaled by a parameter that can 
capture Clearing Members behaviour and the actual pledge capacity used 
currently by the Clearing Members.
    The Maximum pledge capacity amount will take into consideration 
eventual concentration limits in places for specific LCH SA services 
(i.e., Repoclear, [euro]GCPlus and EquityClear).
    In contrast, for the Members not having a pledge account active, 
CDSClear non-cash collateral deposited under Full Title Transfer with 
the exclusion of securities in DKK, NOK, SEK, JPY, CHF, CAD and AUD is 
considered to be eligible to raise liquidity and, therefore, is 
included among liquidity resources. This section has been added to 
address a model validation recommendation by disclosing more details in 
the modelling of the collateral pledge.
    Section 4.2.5.3, Stress scenario selection, will be revised to 
clarify that the stress tests scenarios selected for each LCH SA 
service will be consistent with a market state resulting from the 
default of the Cover 2 as assumed by the LCR. The scenarios selected 
are taken from the set of scenarios used to calibrate the Default Fund 
amount on the different services and in particular include scenarios 
that simulate an increase in interest rates and credit spreads and a 
decrease of equity indexes. The change has the purpose of increasing 
the accuracy and clarity of the document and ensure that the stress 
scenarios chosen are coherent with the LCR assumption of Cover 2 
default and the consequent increased volatility on the market. In other 
terms, additions of wording aim to highlight the consistency of 
stressed scenarios applied on different market to define the Cover 2 
(i.e., rate up (iii), index and equities down (ii) and CDSClear 
widening (i)).
    A full list of the selected stress test scenarios for each service 
is set out in an Appendix to the Framework. The driving scenario is 
then selected as the one that produces the largest stress loss on a 
Cover 2 basis as described in Section 4.2.5.4.
    The list of scenarios has been updated to select, among the 
available scenarios used by the LCH SA services, only the most relevant 
ones given the LCR assumptions. The purpose is to improve the liquidity 
monitoring of LCH SA.
    In addition, when describing the additional stress scenario where a 
downgrade of sovereign ratings results in an increase of ECB haircuts 
applied when the securities are pledged at the BdF to raise liquidity, 
the table reporting the values of the ECB haircuts applicable will be 
updated. The new values are the official values applied by the ECB \32\ 
on each eligible collateral posted to raise liquidity as a function of 
the collateral category and maturity.
---------------------------------------------------------------------------

    \32\ Please refer to https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023O0832.
---------------------------------------------------------------------------

    Section 4.2.5.4, Cover 2 selection, provide the description of the 
methodology used by the DCO to identify the two Member Groups most 
exposed in term of liquidity (Cover 2) which are assumed to be 
simultaneously in default in the LCR. Liquidity needs deriving from 
Settlement risk, Market risk and Investment risk are aggregated to rank 
the Member Group and identify the most exposed ones. The section will 
be revised to specify that the Cover 2 will be identified by 
calculating the following liquidity requirements at the Clearing Member 
Member level, aggregating the total requirement at the Clearing Member 
Group level and then choosing the two most exposed Clearing Member 
Groups:
     Stress Variation Margin: for all the services the 
variation margins are modelled by applying the most punitive scenario 
among the chosen sets and consistent with the LCR assumptions;
     Settlement liquidity requirements due to RepoClear and 
Cash equity settlement obligations. In case of securities pledged at 
the BdF their value would be stressed according to the scenario that 
would generate the highest loss;
     Non-cash Collateral stress losses are estimated by 
stressing the non-cash collateral eligible for BdF liquidity with the 
set of scenarios consistent with the LCR assumptions;
     Investment stress losses over haircut are estimated by 
applying the stress scenarios to the collateral received from the 
reverse repo activity with each specific counterpart; and
     ECB Haircut impact is quantified by applying the relevant 
haircut to all the securities received from a specific member that are 
eligible for Central Bank liquidity.
    Between the set of scenarios used from the RepoClear Stress Test 
framework, the set of scenarios used from the CDSClear Stress Test 
framework and the set of scenarios used from the EquityClear stress 
test framework, only the one jointly generating the maximum loss of the 
sum of all the above elements for the two most exposed Clearing Member 
Groups will be used to determine the Cover 2 and calculate the final 
LCR.
    The changes have the objective to coherently include in the 
computation of the Cover 2 the changes related to the update of the 
stress test scenarios considered in the LCR (described in

[[Page 1960]]

Section 4.2.5.3), the changes related to the impact of market risk on 
the securities pledged at Central Bank (described in Section 
4.2.5.1.1.2) and the changes related to the estimation of the Variation 
Margin Outflows (described in Sections 4.2.5.1.1.3, 4.2.5.1.2.1, 
4.2.5.1.3.1, 4.2.5.1.3.2 and 4.2.5.1.4).

--Section 4.3: All the changes reflect the new branding of CC&G 
(Euronext Clearing). No change in the methodology or procedure applied 
by LCH.

    Section 5, Model Performance Testing and Ongoing Monitoring, will 
be revised to provide throughout that the length of time for which LCH 
SA must maintain liquidity resources sufficient to meet its liquidity 
requirements for each service will be extended from five (5) days to 
seven (7) days.\33\ In addition, Section 5.1, Ongoing Monitoring, will 
be revised to provide that cash or non-cash collateral available for 
pledge to the BdF should represent at least 25 percent (25%) of LCH 
SA's available liquid resources after the default of its most 
significant Clearing Member. This section currently provides that cash 
alone should represent at least 25 percent (25%) of LCH SA's available 
liquid resources after the default of its most significant Clearing 
Member. This change will align the text of the Framework to the updated 
text of the Liquidity Policy approved in 2022.
---------------------------------------------------------------------------

    \33\ See, Section 5.1, Ongoing Monitoring, Section 5.3, Reverse 
Stress Test, and Section 5.3.1, Independent stress of various risk 
factors.
---------------------------------------------------------------------------

    Section 5.3 on Reverse Stress Tests will be modified to include a 
paragraph providing the regulatory requirements pursuant to SEC Rule 
17Ad-22(e)(7)(vi)(B) \34\ and SEC Rule 17Ad-22(e)(7)(vi)(C).\35\
---------------------------------------------------------------------------

    \34\ 17 CFR 240.17Ad-22(e)(7)(vi)(B).
    \35\ 17 CFR 240.17Ad-22(e)(7)(vi)(C).
---------------------------------------------------------------------------

    Consistent with this change, Section 5.3.1, Independent stress of 
various risk factors, which describes the single factor reverse stress 
test (or `core' reverse stress test), which examines the stress on 
liquidity outflows caused by different risk factors that are 
independently stressed (one signle factor at time) to assess extreme 
market conditions necessary to observe a breach of the LCR limit will 
be revised as follow:
 Risk Factor 1: Liquid Assets Reduction
    It will be stated that non-cash collateral deposited by Clearing 
Members and eligible for pledge at the BdF represents another primary 
source of liquidity for LCH SA.
    The sentence `A primary source of liquidity for a CCP is from 
investments maturing management by the CaLM team at the opening of the 
day' will be revised to `A primary source of liquidity for a CCP is 
from investments maturing management performed by the CaLM team at the 
opening of the day'.
    The sentence `The overall liquid asset is reduced to obtain the 
stress required to reduce the LCR below 100%' will be revised to `The 
overall liquid assets are reduced to obtain the stress required to 
reduce the LCR below 100%'.
    The changes described will improve the accuracy and clarity of the 
document and do not represent a change in the methodology or procedure 
of LCH SA.
    Moreover it will be stated that the reduction in assets necessary 
to breach the LCR will be compared against the 7 days historical data 
in order to assess the plausibility of the scenario rather than the 5 
days historical data currently reported. The change has the purpose of 
aligning the time horizon of the reverse stress with the time horizon 
of the LCR (described in Section 4.2.1).
 Risk Factor 2: Switches to Non ECB Eligible Assets
    It will provide that when calculating the single factor reverse 
stress test that simulates a switch of collateral from ECB eligible 
assets to non-ECB eligible assets such that a liquidity breach occurs, 
the non-ECB eligible assets includes GILT or US bonds, Central Bank 
guarantee, equities, non-Euro non cash collateral, and pledge 
collateral. The addition of pledge collateral to the list will improve 
the accuracy and clarity of the document and does not represent a 
change in the methodology or procedure of LCH SA.
    The required amount of switches necessary to produce a liquidity 
breach will be compared against the 7 days historical data rather than 
the 5 days historical data currently reported in the Framework. The 
change has the purpose of aligning the time horizon of the reverse 
stress to the tme horizon of the LCR.
 Risk Factor 3: Rating Downgrade of the Euro Zone Peripheral 
and Core Countries
    The sentence `This reverse stress test aims at modelling the 
downgrade of the relevant countries and estimate the theoretical ECB 
haircuts generating a liquidity shortfall' will be revised to `This 
reverse stress test aims at modelling the downgrade of the relevant 
countries and estimate the theoretical ECB haircuts needed to generate 
a liquidity shortfall'.
    The change described will improve the accuracy and clarity of the 
document and does not represent a change in the methodology or 
procedure of LCH SA.
 Risk Factor 6: CC&G VM
    The subparagraph will be renamed Risk Factor 6: CC&GEuronext 
Clearing VM to reflect the updated name of the interoperable CCP.
    The sentence `The direction of the position' will be revised to 
`The direction of the positions'.
    The change described will improve the accuracy and clarity of the 
document and does not represent a change in the methodology or 
procedure of LCH SA.
    Moreover it will be stated that this specific reverse stress test 
aims to asses the amount of VM fails by the interoperable CCP during 7 
days that could generate a liquidity shortfall rather than 5 days as 
currently reported in the Framework. The change has the purpose of 
aligning the time horizon of the reverse stress to the tme horizon of 
the LCR.
 Risk Factor 7: Multiple Defaults
    The sentence `Given that liquidity requirements are sized to a 
cover 2 standard, is it plausible that more than 2 members defaults who 
could lead to a liquidity deficit' will be revised to `Given that 
liquidity requirements are sized to a cover 2 standard, is it plausible 
that more than 2 member Groups defaults who could lead to a liquidity 
deficit'.
    In addition, the sentence: ``In order to answer this question, LCH 
SA ranks order Members Groups based on their ICS and starting from the 
ones with the worst ICS (and hence highest probabilities of default)'' 
will be revised to read: ``In order to answer this question, LCH SA 
ranks Members Groups based on their ICS and starts considering the ones 
with the worst ICS (and hence highest probabilities of default)''.
    Finally it will be added that all Clearing Member Groups with a 
credit score of 6 or higher will be considered in the reverse stress 
test. The changes described will improve the accuracy and clarity of 
the document and does not represent a change in the methodology or 
procedure of LCH SA.
    Section 5.3.2.1, Context & Objective, will be revised to provide 
that the combined reverse stress test scenarios \36\ that include 
multiple risk factors will be

[[Page 1961]]

performed at least quarterly. The purpose of the change is to align the 
frequency of combined reverse stress stress described in the framework 
to the one state in the Liquidity Risk Policy.
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    \36\ Combined reverse stress test scenario are known as ``non 
core''. Please refer to change to Section 1.4 described previously 
herein.
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    Section 5.3.2.2, Behavioural scenario, will be revised to provide a 
more updated example of report layout. The change will increase the 
accuracy and clarity of the document and does not represent a change in 
the methodology or procedure of LCH SA.
    Section 5.3.2.3, Macro-economic scenario, describes the reverse 
stress test, which examines the stress on liquidity outflows caused by 
a set of macro-economic scenarios that combine market, credit and 
concentration risk to determine the number of defaults that LCH SA can 
sustain in a shocked macro-economic environment until it suffers a 
liquidity shortfall. This section will be revised, in part, to clarify 
that the market risk driving scenarios will be selected from the 
scenarios used to calculate LCR in accordance with the logic described 
in Section 4.2.5.4. The current Framework considers only 2 
macroeconomic scenarios that will be replaced by the new set of 
scenarios dscribed in Appendix 6.7. Additional external rating 
downgrade will be considered on top of the selected market risk 
scenario as it is the case of the current Framework.
    Moreover, the Operational outflow considered in the scenario will 
be aligned to the calculation of the Operational Target and therefore 
assuming a margin reduction of 24.7% over 7 days.
    The changes will improve the liquidity monitoring of LCH SA by 
aligning the reverse stress test calculation to the changes proposed 
for the LCR and described in Sections 4.1.5g, 4.2.5.3, 4.2.5.4, and 
Appendix 6.7.
    This Section will also be revised to provide that LCH SA will 
consider Clearing Member Groups, rather than individual Clearing 
Members, when simulating the multiple defaults driven by credit quality 
criteria, concentration criteria or total liquidity exposure criteria 
as this Section currently provides. The changes will improve the 
accuracy and clarity of the document and does not represent a change in 
the methodology or procedure of LCH SA.
 Multiple Defaults Based on the Credit Quality of the Member 
Groups
    The sentence `By expanding the analysis presented on the individual 
risk factor 8 this case highlights the evolution of the LCR for each 
macro-economic scenario' will be revised to `By expanding the analysis 
presented on the individual risk factor 7 this case highlights the 
evolution of the LCR under the driving macro-economic shock scenario'. 
The change has the purpose of correcting a typo and alignin the 
description to the new computation of the driving macroeconomic 
scenario described above.
    Moreover, the example table that reports a sample of member Groups 
and their respective liquidity needs will be updated to anonymize the 
name of each Group.
 Multiple Defaults of the Most Concentrated Countries (FR & US 
Member Groups)
    The sentence `More specifically, we assume that the Macro-Eco 2 
scenario (Peripheral shock accompanied with a contagion on core 
countries) affects French and the European entities of the US members 
(two different simulations)' will be revised to `More specifically, we 
assume that the Driving macro economic scenario affects French and the 
European entities of the US members (two different simulations)'. The 
change will align the description to the new computation of the driving 
macroeconomic scenario described above.
    Moreover, the various report examples reported in this section 
displaying the multiple defaults of member Groups from most 
concentrated countries will be updated \37\ to provide a more recent 
example of report layout. The change will increase the accuracy and 
clarity of the document and does not represent a change in the 
methodology or procedure of LCH SA.
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    \37\ Figures as of October 2022.
---------------------------------------------------------------------------

 Default of the Biggest Member Groups in Terms of Liquidity 
(Cover N)
    The report example reported in this section displaying the default 
of the biggest Member Groups in terms of liquidity will be updated \38\ 
to provide a more recent example of report layout. The change will 
increase the accuracy and clarity of the document and does not 
represent a change in the methodology or procedure of LCH SA.
---------------------------------------------------------------------------

    \38\ Id.
---------------------------------------------------------------------------

    Section 5.3.3 is being added to the Framework in order to include 
provisions governing frequency and reporting. This section specifies 
that LCH SA performs core reverse stress tests at least on a monthly 
basis and that the results of the analysis are shared with the CRO on a 
monthly basis and quarterly to LCH SA Risk Committee.
    LCH SA also performs an ad-hoc analysis of the existing stress 
testing scenarios, models, and underlying parameters and assumptions 
used in evaluating liquidity needs and resources through the core 
reverse stress tests exercise (i) when the products cleared or markets 
served display high volatility or become less liquid, (ii) when the 
size or concentration of positions held by the clearing agency's 
participants increases significantly, or (iii) in any other appropriate 
circumstances that would lead to a liquidity coverage ratio falling 
below the alert threshold of 107%. The ad-hoc analysis triggered by a 
liquidity coverage ratio falling below 107% are reported to LCH SA CRO, 
the Head of LCH SA Collateral and Liquidity Management division and to 
the LCH SA Risk Committee.
    Section 5.5, Testing Summary and Model Limitation, will be revised 
to add a footnote to provide that single factor reverse stress tests 
are performed monthly. Single and combined reverse stress tests are 
performed quarterly. These requirements come from the LCH Liquidity 
Risk Policy.
    Appendix 6.2, Members behavior analysis, that analyses the 
assumptions used in calculation the Operational Target and the LCR will 
be revised to provide that the volume of the non-ECB eligible non cash 
collateral (mainly Gilts, U.S. Treasury securities, securities 
denominated in Danish Krone, Norwegian Krone, Swedish Krona, Japanese 
Yen, Swiss Francs, Canadian Dollars and Australian Dollars and Central 
Bank Guarantee) will remain at a level that does not downgrade LCH SA 
liquidity profile (i.e., quarterly reverse stress test) and that LCH SA 
imposes concentration limits on non-Euro non cash collateral. The 
change will enhance the accuracy and clarity of the document and does 
not represent a change in the methodology or procedure of LCH SA.
    Moreover, this Appendix will be revised to specify that the margin 
reduction is estimated at 24.7% over 7 days assuming that the daily 
margin reductions are independent (sum of the daily margin reduction 
vs. 7 days margin reduction). This level is bigger than the historical 
margin reduction over 7 days observed over a 10-year lookback period. 
This change has the purpose of updating the Appendix to be coherent 
with the changes described is Section 4.1.5 and driven by the necessity 
to address a model validation recommendation. Finally the graph 
reporting the LCH SA total margin is updated to provide a more recent 
orverview of the data.
    Appendix 6.3, Reminder of SA's sources of liquidity and related 
risk drivers, will be revised to update the table to include as a risk 
driver the

[[Page 1962]]

pledge collateral. In particular it will provide that because of higher 
concern toward LCH SA, the Clearing Members may increase their use of 
the pledge collateral capacity. This behavior is modelled in the LCR. 
Moreover, LCH SA may adjust the maximum limit allowed in pledge.
    The change will align the Appendix with what presented in Section 
4.2.5.2.4 and highlighted above.
    In addition, when reporting the cash settlement option in case of 
Euronext Clearing default, the following footnote will be updated to 
read: ``There is a residual risk (uncertainty--delay/amount--with 
regards SA's margins return by Euronext Clearing administrator)''. The 
footnote is amended following the completion by LCH SA of its review of 
risk drivers and related mitigation measures for cash received from 
Euronext Clearing.
    Appendix 6.4, Liquidity risk drivers synthesis by reports, will be 
revised to update the table summarizing the components of each 
liquidity indicator (Operational Target, LCR Cover 2 and LCR Euronext 
Clearing) to reflect the fact that the liquidity monitoring period will 
be extended from 5 days to 7 days and that the overall margin reduction 
considered is 24.7%. Moreover, for LCR Cover 2, the Appendix will 
provide that when calculating the settlement obligation and the 
resulting BdF liquidity, the securities pledge will take into account 
ECB haircut and market stress, and when estimating excess reduction LCH 
SA will consider only non-defaulting Clearing Members as LCH SA has the 
right to use for liquidity purposes any amounts left in excess from a 
defaulting Clearing Member.
    Appendix 6.5, Liquidity risk monitoring report, will be updated by 
including the more recent layout versions of liquidity reports used by 
the DCO to monitor liquidity. The change will improve the accuracy and 
clarity of the document and does not represent a change in the 
methodology or procedure of LCH sA.
    Appendix 6.7, Stress scenarios list, will be added to report the 
specific list of stress scenarios used for each service.
    Appendix 6.8, Pseudo-code of settlement and market risk 
calculation, will be added to provide the details on the algorithm used 
to calculate the settlement obligation driven liquidity requirements in 
the monitoring of the LCR and the resulting BdF liquidity raised by 
pledging the securities withdrawn from the settlement systems. This 
appendix translate into a pseudo code the algorithm described in detail 
in sections 4.2.5.1.1.1 (liabilities contractual obligations on 
physical delivery) and 4.2.5.1.1.2 (settlement securities pledged at 
Central Bank). Different steps of computation are described covering 
both liabilities and assets and the resulting aggegations to get the 
finale outputs. The Appendix has the purpose of providing a technical 
overview of the implementation of the algorithm described in the 
referred sections and duly commented in the present 19b4. Please refer 
to such sections for a theorical decription of the methodology.
    Finally in the whole Framework the name of the interoperable CCP 
have been updated from ``Cassa di Compensazione e Garanzia (CC&G)'' 
into ``Euronext Clearing''.
2. Statutory Basis
    LCH SA has determined that the Proposed Rule Change is consistent 
with the requirements of Section 17A of the Act \39\ and regulations 
thereunder applicable to it. In particular, Section 17A(b)(3)(F) of the 
Act requires, inter alia, that the rules of a clearing agency should be 
designed to ``promote the prompt and accurate clearance and settlement 
of securities transactions . . . and, to assure the safeguarding of 
securities and funds which are in the custody or control of the 
clearing agency or for which it is responsible[.]'' \40\ In addition, 
Regulation 17Ad-22(e)(7)(ii) \41\ requires a covered clearing agency to 
establish, implement, maintain and enforce written policies and 
procedures reasonably designed to assure that it holds qualifying 
liquid resources sufficient to meet the minimum liquidity resource 
requirement in each relevant currency for which the covered clearing 
agency has payment obligations owed to clearing members.
---------------------------------------------------------------------------

    \39\ 15 U.S.C. 78q-1.
    \40\ 15 U.S.C. 78q-1(b)(3)(F).
    \41\ 17 CFR 240.17Ad-22(e)(7)(ii).
---------------------------------------------------------------------------

    As discussed above, the Framework is being amended primarily to 
enhance the manner in which the LCR is calculated, thereby increasing 
the robustness of LCH SA's liquidity profile. In particular, the 
amendments will: (a) revise the manner in which the settlement 
obligation is calculated by aligning it to the actual process used by 
the Operations Team during a default management and ensuring that no 
netting is allowed between Members of the same Group; (b) revise the 
manner in which securities pledged to the Banque de France are valued 
by providing that such securities be valued at the stressed mark-to-
market price rather than the contract price; (c) extend from five (5) 
days to seven (7) days the length of time for which LCH SA must 
maintain liquidity resources sufficient to meet its liquidity 
requirements; (d) include the liquidity needs generated by the 
expiration of physically settled stock futures in the liquidity 
monitoring; and (e) require LCH SA, in calculating its required 
liquidity resources, to take into account that Clearing Members may 
switch from depositing non-cash collateral in a Full Title Transfer 
Account, which may be pledged at the BdF to obtain a liquidity line of 
credit, to depositing non-cash collateral instead in a Pledge Account.
    By enhancing the manner in which the LCR is calculated, thereby 
increasing the robustness of LCH SA's liquidity profile, the policies 
and procedures set out in the amended Framework are designed to promote 
the prompt and accurate clearance and settlement of securities 
transactions and continue to assure the safeguarding of securities and 
funds that are in LCH SA's custody or control or for which it is 
responsible to be consistent with the requirements of Section 
17A(b)(3)(F) of the Act.\42\ Specifically, the Proposed Rule will 
revise the manner in which the settlement obligation liquidity 
requirements are calculated, revise the manner in which securities 
pledged at the BdF are valued, extend the length of time LCH SA must 
maintain its liquidity resources, include the liquidity needs from the 
expiration of physically settled stock futures and account for in the 
way LCH SA calculates its liquidity resources, the process by which 
Clearing Members pledge non-cash collateral. Further, the amended 
Framework continues to assure that LCH SA holds qualifying liquid 
resources sufficient to meet the minimum liquidity resource requirement 
in each relevant currency for which the covered clearing agency has 
payment obligations owed to Clearing Members, as required by Regulation 
17Ad-22(e)(7)(ii).\43\
---------------------------------------------------------------------------

    \42\ 15 U.S.C. 78q-1(b)(3)(F).
    \43\ 17 CFR 240.17Ad-22(e)(7)(ii).
---------------------------------------------------------------------------

    LCH SA also believes that the Proposed Rule Change is consistent 
with Exchange Act Rule 17Ad-22(e)(1) \44\ that requires a covered 
clearing agency to establish, implement, maintain and enforce written 
policies and procedures reasonably designed to provide for a well-
founded, clear, transparent, and enforceable legal basis for each 
aspect of its activities in all relevant jurisdictions. As described 
above, the Proposed Rule Change will ensure that the Framework complies 
with the provisions of SEC Rule 17Ad-

[[Page 1963]]

22(e)(7) \45\ with respect to liquidity risk, including with respect to 
its requirement to determine the amount and regularly test the 
sufficiency of the liquid resources held for purposes of meeting the 
minimum liquid resource requirement.\46\
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    \44\ 17 CFR 240.17Ad-22(e)(1).
    \45\ 17 CFR 240.17Ad-22(e)(7).
    \46\ 17 CFR 240.17Ad-22(e)(7)(vi).
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    Finally, LCH SA believes that the Proposed Rule Change is 
consistent with Exchange Act Rule 17Ad-22(e)(7)(vi)(B) \47\ and 
Rule17Ad-22(e)(7)(vi)(C).\48\ Rule 17Ad-22(e)(7)(vi)(B) requires a 
covered clearing agency to establish, implement, maintain and enforce 
written policies and procedures reasonably designed to effectively 
measure, monitor, and manage the liquidity risk that arises in or is 
borne by the covered clearing agency, including measuring, monitoring, 
and managing its settlement and funding flows on an ongoing and timely 
basis, and its use of intraday liquidity by . . . [d]etermining the 
amount and regularly testing the sufficiency of the liquid resources 
held for purposes of meeting the minimum liquid resource requirement 
[as required by SEC Rule 17Ad-22(e)(7)(i)] by establishing requirements 
for conducting monthly comprehensive analyses of stress testing 
scenarios, models, parameters and assumptiosn with respect to liquidity 
needs.\49\ Rule 17Ad-22(e)(7)(vi)(C) further provides that LCH SA 
conduct such analyses more frequently than monthly, ``the products 
cleared or markets served display high volatility or become less 
liquid, when the size or concentration of positions held by [LCH SA's] 
participants increases significantly.'' \50\
---------------------------------------------------------------------------

    \47\ 17 CFR 240.17Ad-22(e)(7)(vi)(B).
    \48\ 17 CFR 240.17Ad-22(e)(7)(vi)(C).
    \49\ 17 CFR 240.17Ad-22(e)(7)(vi)(B).
    \50\ 17 CFR 240.17Ad-22(e)(7)(vi)(C).
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    LCH SA is proposing to amend the Framework to reflect its current 
practice of conducting monthly analysis of its existing stress testing 
scenarios, models, and underlying parameters and assumptions used in 
evaluating liquidity needs and resources for purposes of ensuring they 
are appropriate for determining the LCH SA's identified liquidity needs 
and resources in light of current and evolving market conditions. LCH 
SA is also proposing to amend the Framework to include the additional 
requirement that it conduct more frequent analysis when the products 
cleared or markets served display high volatility or become less 
liquid, when the size or concentration of positions held by LCH SA's 
participants increases significantly, or in other appropriate 
circumstances. By revising the Framework to reflect its current 
practice of conducting monthly analysis and including the requirement 
to conduct more frequent analysis, subject to certain conditions, LCH 
SA believes that the Proposed Rule Change is therefore consistent with 
Exchange Act Rule 17Ad-22(e)(7)(vi)(B) \51\ and Rule 17Ad-
22(e)(7)(vi)(C).\52\
---------------------------------------------------------------------------

    \51\ 17 CFR 240.17Ad-22(e)(7)(vi)(B).
    \52\ 17 CFR 240.17Ad-22(e)(7)(vi)(C).
---------------------------------------------------------------------------

B. Clearing Agency's Statement on Burden on Competition

    Section 17A(b)(3)(I) of the Act requires that the rules of a 
clearing agency not impose any burden on competition not necessary or 
appropriate in furtherance of the purposes of the Act.\53\ LCH SA does 
not believe the Proposed Rule Change would have any impact, or impose 
any burden, on competition. The Proposed Rule Change does not address 
any competitive issue or have any impact on the competition among 
central counterparties. LCH SA operates an open access model, and the 
Proposed Rule Change will have no effect on this model.
---------------------------------------------------------------------------

    \53\ 15 U.S.C. 78q-1(b)(3)(I).
---------------------------------------------------------------------------

C. Clearing Agency's Statement on Comments on the Proposed Rule Change 
Received From Members, Participants or Others

    Written comments relating to the Proposed Rule Change have not been 
solicited or received. LCH SA will notify the Commission of any written 
comments received by LCH SA.

III. Date of Effectiveness of the Proposed Rule Change and Timing for 
Commission Action

    Within 45 days of the date of publication of this notice in the 
Federal Register or within such longer period up to 90 days (i) as the 
Commission may designate if it finds such longer period to be 
appropriate and publishes its reasons for so finding or (ii) as to 
which the self-regulatory organization consents, the Commission will: 
(A) by order approve or disapprove such proposed rule change, or (B) 
institute proceedings to determine whether the proposed rule change 
should be disapproved.

IV. Solicitation of Comments

    Interested persons are invited to submit written data, views, and 
arguments concerning the foregoing, including whether the proposed rule 
change is consistent with the Act.

Comments May Be Submitted by Any of the Following Methods

     Use the Commission's internet comment form (https://www.sec.gov/rules/sro.shtml) or
     Send an email to [email protected]. Please include 
File Number SR-LCH SA-2023-007 on the subject line.

Paper Comments

     Send paper comments in triplicate to Secretary, Securities 
and Exchange Commission, 100 F Street NE, Washington, DC 20549-1090.

All submissions should refer to file number SR-LCH SA-2023-007. This 
file number should be included on the subject line if email is used. To 
help the Commission process and review your comments more efficiently, 
please use only one method. The Commission will post all comments on 
the Commission's internet website (https://www.sec.gov/rules/sro.shtml). Copies of the submission, all subsequent amendments, all 
written statements with respect to the proposed rule change that are 
filed with the Commission, and all written communications relating to 
the proposed rule change between the Commission and any person, other 
than those that may be withheld from the public in accordance with the 
provisions of 5 U.S.C. 552, will be available for website viewing and 
printing in the Commission's Public Reference Room, 100 F Street NE, 
Washington, DC 20549, on official business days between the hours of 10 
a.m. and 3 p.m. Copies of such filings will also be available for 
inspection and copying at the principal office of LCH SA and on LCH 
SA's website at https://www.lch.com/resources/rulebooks/proposed-rule-changes.
    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 to File Number SR-LCH SA-2023-007 and 
should be submitted on or before February 1, 2024.

    For the Commission, by the Division of Trading and Markets, 
pursuant to delegated authority.\54\
---------------------------------------------------------------------------

    \54\ 17 CFR 200.30-3(a)(12).
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Christina Z. Milnor,
Assistant Secretary.
[FR Doc. 2024-00383 Filed 1-10-24; 8:45 am]
BILLING CODE 8011-01-P