Notice2024-29474
Self-Regulatory Organizations; ICE Clear Credit LLC; Order Approving Proposed Rule Change Relating to ICC's Treasury Operations Policies and Procedures
Primary source
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Published
December 16, 2024
Issuing agencies
Securities and Exchange Commission
Full Text
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<title>Federal Register, Volume 89 Issue 241 (Monday, December 16, 2024)</title>
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[Federal Register Volume 89, Number 241 (Monday, December 16, 2024)]
[Notices]
[Pages 101666-101673]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2024-29474]
[[Page 101666]]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-101871; File No. SR-ICC-2024-005]
Self-Regulatory Organizations; ICE Clear Credit LLC; Order
Approving Proposed Rule Change Relating to ICC's Treasury Operations
Policies and Procedures
December 10, 2024
I. Introduction
On August 22, 2024, ICE Clear Credit LLC (``ICC''), filed with the
Securities and Exchange Commission (``Commission''), pursuant to
Section 19(b)(1) of the Securities Exchange Act of 1934 (``Act'') \1\
and Rule 19b-4 thereunder,\2\ a proposed rule change to revise the ICC
Treasury Operations Policies and Procedures (``Treasury Policy'')
(``Proposed Rule Change''). The Proposed Rule Change was published for
comment in the Federal Register on September 11, 2024.\3\
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ Securities Exchange Act Release No. 100935 (Sept. 5, 2024),
89 FR 73734 (Sept. 11, 2024) (File No. SR-ICC-2024-005)
(``Notice'').
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On October 25, 2024, pursuant to Section 19(b)(2) of the Exchange
Act,\4\ the Commission designated a longer period within which to
approve, disapprove, or institute proceedings to determine whether to
approve or disapprove the Proposed Rule Change, until December 10,
2024.\5\ The Commission has not received any comments on the Proposed
Rule Change. For the reasons discussed below, the Commission is
approving the Proposed Rule Change.
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\4\ 15 U.S.C. 78s(b)(2).
\5\ Securities Exchange Act Release No. 101440 (Oct. 25, 2024),
89 FR 86867 (Oct. 31, 2024) (File No. SR-ICC-2024-005).
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II. Description of the Proposed Rule Change
ICC is registered with the Commission as a clearing agency for the
purpose of clearing CDS contracts.\6\ Its Treasury Policy contains
policies and procedures used to support the ICC Treasury Department
(``Treasury Department''). The Treasury Department manages ICC's margin
and guaranty fund assets posted by Clearing Participants as
collateral.\7\
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\6\ Capitalized terms not otherwise defined herein have the
meanings assigned to them in ICC's Clearing Rules or the Treasury
Policy, as applicable.
\7\ Notice, 89 FR at 73734.
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The Proposed Rule Change would make a number of changes to the
Treasury Policy that fit into seven categories: (i) additions to the
minimum criteria for ICC's settlement banks; (ii) alterations to the
investment guidelines contained in the Treasury Policy; (iii)
clarifications that add detail to the Treasury Policy; (iv) increases
to the breadth of certain Treasury Policy provisions; (v) various
corrections to the Treasury Policy; (vi) deletion of unnecessary
language from the Treasury Policy; and (vii) certain changes to make
the Treasury Policy more consistent with federal and ICC rules.\8\
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\8\ ICC also proposes several non-substantive changes to the
Treasury Policy. For example, the current Treasury Policy notes that
``Treasury reconciles daily and previous day cash and collateral
balances.'' This language would be modified to read ``Treasury
reconciles daily: current and previous day cash and non-cash
collateral balances.''
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1. Minimum Criteria for Settlement Banks
ICC maintains relationships with various settlement banks to
facilitate the holding and movement of Margin and Clearing Fund cash
and collateral between ICC and its Clearing Participants.\9\ The
current Treasury Policy includes standards and criteria that settlement
banks must meet in order to be considered for such a relationship with
ICC, including capitalization, operational capability, and regulatory
supervision.\10\ To aid in ICC's management of liquidity risk arising
from settlement arrangements with these banks, the Proposed Rule Change
would add a requirement that a settlement bank provide ICC with
specific liquidity information.\11\ An example of liquidity information
that ICC requires from settlement banks is the banks' Liquidity
Coverage Ratio. In the event that a bank does not report LCR, the
Proposed Rule Change would specify that ICC will consider other
criteria to assess the liquidity of the bank. These other criteria may
include a description of the bank's liquidity risk management policy or
the liquidity coverage ratio of the settlement bank's affiliated
reporting entity within the bank's group.
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\9\ Notice, 89 FR at 73736.
\10\ Id.
\11\ Id.
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2. Investment Guidelines
The Treasury Policy governs ICC's investment strategy for its own
operating capital and for the Margin and Guaranty Fund cash collateral
that it holds. That strategy is designed to provide yield with reduced
credit and market risk while preserving liquidity and principal.\12\
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\12\ ICE Clear Credit LLC Treasury Operations Policies and
Procedures.
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With respect to ICC's operating capital, currently, the Treasury
Policy requires ICC to invest operating capital in either bank deposits
or in U.S. Treasury/Agency reverse repurchase agreements (``repos'').
However, in the event that bank deposits or reverse repos are
unavailable or not feasible, ICC may make direct investments in U.S.
Treasury securities with a maturity of no greater than 98 days.\13\
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\13\ Notice, 89 FR at 73737.
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With respect to reverse repos, the current Treasury Policy requires
that the value of treasury collateral received by ICC must be between
100.5 percent and 102 percent of the invested U.S. Dollar amount. The
Proposed Rule Change would eliminate this range and instead require
that the value of the treasury collateral received by ICC be 102
percent of the invested U.S. Dollar amount. ICC believes this change
would reflect current market practice and provide greater protection to
ICC.\14\
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\14\ Id. These changes also would apply where ICC invests
Guaranty Fund and Margin cash in reverse repos. As explained below,
in certain circumstances, ICC may invest in reverse repos USD cash
posted by Clearing Participants to satisfy Guaranty Fund and Margin
requirements. See infra Section II.3.
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In addition, to provide ICC with greater flexibility to implement
its investment strategy while still maintaining the quality of its
investments,\15\ the Proposed Rule Change would eliminate the current
limitation on the Treasury Department's ability to invest operating
capital in U.S. Treasury securities only if bank deposits or reverse
repos are unavailable or infeasible and instead allow ICC's Treasury
Department the discretion to invest operating capital in bank deposits,
reverse repos, or U.S. Treasury securities with a final maturity of no
greater than 98 days. The Proposed Rule Change also would specify that
ICC would primarily directly invest in U.S. Treasury securities with
respect to stable balances, for example, restricted cash held for
regulatory capital purposes.\16\
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\15\ Notice, 89 FR at 73737.
\16\ Id.
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3. Additions of Clarifying Details
The Proposed Rule Change would add clarifying details to the
Treasury Policy. In a discussion of the Treasury Department's
responsibilities, the Proposed Rule Change would add a sentence
explaining that ICC's capacity to facilitate the prompt and accurate
clearance and settlement of securities transactions and derivative
agreements, contracts, and transactions for which ICC is responsible,
and to safeguard securities and funds in ICC's custody or control for
which it is responsible, is
[[Page 101667]]
aided by the Treasury Department. ICC also proposes clarifying that
references to the Guaranty Fund in the Treasury Policy are to the
General Guaranty Fund as defined in ICC Rule 102.\17\ The Proposed Rule
Change would modify certain current references to ``cash and
collateral'' and ``cash or collateral'' to ``cash and non-cash
collateral'' and ``cash and/or non-cash collateral,'' respectively.\18\
It also would modify the current description of the Treasury Department
as being responsible for managing postings by ICC Clearing Participants
to a statement that the Treasury Department is responsible for managing
Guaranty Fund collateral postings by ICC Clearing Participants.\19\ In
the Treasury Department Organizational Structure and Governance
subsection of the Treasury Policy, ICC also proposes adding text to
clarify that the Treasury Director oversees the Treasury Department and
reports to the ICC Chief Operating Officer.\20\
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\17\ Notice, 89 FR at 73734.
\18\ Id. For example, ICC proposes that a description of one of
the Treasury Department's responsibilities should indicate that it
works with Clearing Participants to assist with other cash and non-
cash collateral related requests rather than cash and collateral
related requests. Similar changes are also made in the introduction
to the Treasury Department section and the Funds Management, Types
of Funds section of the Treasury Policy.
\19\ Notice, 89 FR at 73734.
\20\ Id. at 73735.
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Where ICC describes the types of funds it manages, ICC proposes
specifying that the definition for Margin is in Rule 102 of ICC's
Clearing Rules and that the Treasury Policy would refer to Initial
Margin and Mark-to-Market Margin collectively as Margin.\21\ Similarly,
the Proposed Rule Change would highlight the location of definitions
for House Margin, Client-Related Positions, and Client-Related Margin;
clarify that the Treasury Policy would use the term Client Positions in
place of Client-Related Positions; \22\ and give a definition of House
Margin and Client-Related Margin.\23\
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\21\ Id. ICC's proposal would incorporate Margin and other
related defined terms throughout the Treasury Policy.
\22\ Unlike the term Client Positions, Client-Related Positions
is a term defined in ICC Rule 102.
\23\ Id. at 73735. The Proposed Rule Change would indicate that
Initial Margin collateral is maintained and managed separately for
Clearing Participant House Positions (``House Margin'') and clearing
activities associated with indirect participant or client positions
(i.e., Client-Related Margin referred to in the Treasury Policy as
``Client Margin''). The definitions for House Position, Client-
Related Positions, and Client Related Margin (Client-Related Initial
Margin) are in Rule 102 of the ICC Rule Book.
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ICC also proposes adding clarifying language to a subsection of the
Treasury Policy discussing ICC's investment of US Dollar cash.\24\ This
language would identify the Federal Reserve Bank (``FRB'') of Chicago
as a central bank. The amendments would also clarify that if ICC is
unable to deposit all or a portion of its Guaranty Fund and Margin that
was posted as USD cash at its FRB accounts, ICC's Treasury Department
may invest such cash in US Treasury/Agency reverse repurchase
agreements rather than Treasury/Agency reverse repurchase agreements.
Similarly, in a subsection of the Treasury Policy addressing liquidity
protection, ICC proposes specifying that it would call additional
Initial Margin, rather that additional margin, if a Clearing
Participant does not meet certain liquidity requirements.\25\
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\24\ Notice, 89 FR at 73735.
\25\ Id.
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The Proposed Rule Change would also add detail to the Cash
Settlement section of the Treasury Policy. ICC proposes adding options
premia and interest on Mark-to-Market Margin to a list of Transaction
Payments in order to reflect current ICC practice.\26\ In a discussion
of ICC's direct settlement model, ICC also proposes adding detail to
clarify its settlement operations.\27\ Specifically, ICC would add text
indicating that in the direct settlement model, Clearing Participants
must establish settlement bank arrangements and make all requested
payments to ICC within the required timeframe. The Treasury Policy
would be further updated to note that, under the direct settlement
model, ICC does not maintain accounts at each of the Clearing
Participant settlement banks. Instead, ICC maintains direct debit
authority over the Clearing Participant settlement bank accounts as
such authority is granted by each Clearing Participant.
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\26\ Id. ICC also proposes replacing Trade Payments with
transaction payments in this provision.
\27\ Id. at 73736.
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ICC's proposal would also add detail to the discussion of Clearing
Participant requirements for direct settlement. Specifically, ICC
proposes clarifying that, under the direct settlement model, Clearing
Participants are responsible for ensuring that ICC has timely received
all requested payments. If timely payment is not received, the Clearing
Participant may be declared to be in default of its obligations to ICC.
This proposed addition is meant to clarify ICC's existing
practices.\28\
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\28\ Id.
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In relation to the description of ICC's daily settlement process in
the Treasury Policy, ICC proposes additions that would describe current
practice.\29\ To that end, the Treasury Policy would be updated to
explain that ICC's daily settlement process occurs with each Clearing
Participant every business day as applicable, and that settlement is
final and irrevocable at the earlier of the time when (i) ICC receives
the relevant payment or (ii) a financial institution used by ICC sends
a confirmation message to ICC confirming that the relevant payment has
been made.
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\29\ Id.
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ICC's amendments would also add detail to the Custodial Assets
section of the Treasury Policy. ICC proposes clarifying that its
policies regarding acceptable forms of cash and non-cash collateral for
Initial Margin and Guaranty Fund and their associated ``haircuts'' are
designed to provide protection for market risk management in addition
to liquidity risk management. Additionally, ICC's proposed changes to
the excess collateral sub-section would require that Clearing
Participant requests to transfer excess collateral be completed prior
to 9 a.m. ET for GBP denominated collateral in addition to EUR
denominated collateral in order to receive the assets on the same day.
ICC proposes this change because currently the sub-section does not
contain the applicable GBP deadline for the transfer of excess GBP
denominated collateral.\30\
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\30\ Id. at 73737.
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In the treasury reconciliations section, the Proposed Rule Change
would clarify that ICC's Treasury Department conducts a daily
reconciliation process with respect to its cash and non-cash collateral
accounts in accordance with its internal procedures.\31\ ICC also
proposes clarifying that ``cite checks'' involve the manual review of
transaction activity rather than the manual review of the ISG requests.
In ICC's view, this would be a clarifying change because the term ``ISG
requests'' is vague and undefined.\32\
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\31\ Id. These procedures include cite checks for validating the
status of margin payments; a check of prior-day cash balances,
withdrawals, and/or deposits; and a comparison of current and
expected balances.
\32\ Id. at 73737.
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4. Proposed Changes That Broaden Certain Provisions
The Proposed Rule Change also increases certain provisions'
breadth. In the section of the Treasury Policy covering the Treasury
Department's responsibilities, the current term ``settlement issues''
would be replaced with the term ``treasury management related issues.''
As a result of this proposed change, the Treasury Policy
[[Page 101668]]
would specify that the Treasury Department is responsible for
maintaining relationships and contacts with Clearing Participants to
efficiently and effectively identify, validate, escalate and correct
``treasury management related issues'' rather than ``settlement
issues.'' ICC also proposes replacing the phrase ``substitute
collateral for cash'' with the phrase ``perform collateral
substitutions'' in another provision in the same section. As a result
of this change, the Treasury Policy would describe the Treasury
Department as being responsible for managing the process whereby
Clearing Participants ``perform collateral substitutions'' instead of
the process whereby Clearing Participants ``substitute collateral for
cash.'' ICC proposes these changes to provide a more complete picture
of its current payment practices.\33\ Additionally, the Proposed Rule
Change would replace the word cash with the word collateral in a
separate provision. As a result of this proposed change, the Treasury
Department would be required to work to develop ``investment and
collateral'' management strategies rather than ``investment and cash''
management strategies. In ICC's view, this change would more fully
describe the scope of ICC's current practice and be consistent with the
rest of the Treasury Policy.\34\
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\33\ Id. at 73735.
\34\ Id.
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The Proposed Rule Change would also broaden the Funds Management
section of the Treasury Policy. In this section's discussion of
investment of Guaranty Fund and Margin requirements posted in US Dollar
cash, ICC proposes adding that bilateral reverse repo transactions may
be settled through alternative counterparties that may be added to the
Treasury Policy in the future. The policy already notes that these
repos are settled through a specific bank or additional counterparties
that may be added in the future. This proposed addition aims to
encompass potential future changes in ICC's financial service provider
relationships.\35\
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\35\ Id.
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In the Treasury Policy's Cash Settlement section, ICC proposes
changing how it describes its settlement banking relationships.
Currently, ICC provides the names of its backup settlement banks in a
subsection of the Treasury Policy addressing its banking relationships.
Instead of naming specific backup settlement banks in one provision,
ICC proposes that the provision indicate that ICC maintains appropriate
backup settlement banking relationships. In the same subsection, ICC
also proposes conforming changes related to this proposed change.
Similarly, when addressing bank to bank and credit SWIFT messages,
ICC's proposal would remove a reference to ICC's specific settlement
banks and instead refer to ``applicable ICC settlement banks.'' These
changes would help ICC avoid amending the Treasury Policy if its
specific settlement banks it uses change.\36\ ICC's amendments would
also add text to a subsection discussing when settlement banks fail to
perform. This text currently lists specific banks that ICC's Treasury
Department would instruct Clearing Participants to wire funds to
directly if they do not pay because a settlement bank failed to
perform. The Proposed Rule Change would add a new bank to the current
list. It would also provide that if a settlement bank does not perform,
ICC's Treasury Department would instruct the Clearing Participant to
wire funds directly to ICC's accounts at alternative or additional
settlement banks. These changes would broaden the list of settlement
banks that ICC may designate.\37\
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\36\ Id. at 73736.
\37\ Id.
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ICC also proposes replacing references to specific types of SWIFT
messages with more general descriptions. Making this change would
account for potential changes to specific types of SWIFT messages.\38\
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\38\ Id. at 73736. Similar changes are made throughout the
Treasury Policy.
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ICC proposes broadening provisions in the Custodial Assets section
of the Treasury Policy as well. Currently, the Treasury Policy provides
that ICC accounts for the risk associated with changes in the value of
US Treasuries and non-USD currencies by applying ``haircuts.'' \39\ The
amendments would instead provide that ICC accounts for the risk
associated with fluctuations in the value of cash and non-cash
collateral by applying ``haircuts.'' ICC proposes this change because
ICC accepts more than just U.S. Treasuries and non-USD currencies as
collateral.\40\
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\39\ ICE Clear Credit LLC Treasury Operations Policies and
Procedures.
\40\ Notice, 89 FR at 73737.
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5. Proposed Corrections to the Treasury Policy
ICC also proposes to make various corrections to the Treasury
Policy. In the Treasury Department Responsibilities section of the
Treasury Policy, ICC proposes replacing a reference to margin
requirements with a more general reference to requirements, a reference
to margin deficit payments with a reference to payments, a reference to
margin accounts with a reference to accounts, and a reference to the
daily margin process with a reference to the daily clearing process.
These proposed changes would improve the accuracy of the Treasury
Policy because, in practice, the references to requirements, payments,
accounts, and processes are not limited solely to margin.\41\ The
Proposed Rule Change would also indicate that ICC, rather than ICC's
Risk Department, generates daily requirements for all Clearing
Participants (including requirements for indirect participants, i.e.,
Client-Related requirements). ICC's entity-wide clearing systems
automatically create these requirements, not the ICC Risk
Department.\42\ The Proposed Rule Change would also modify the
description of these requirements to indicate that they would be based
on ``cleared positions'' rather than ``cleared trades.'' In ICC's view,
the word ``positions'' better describes Clearing Participants' cleared
activity at ICC.\43\ ICC also proposes correcting text related to
receipt of payments under the Treasury Policy.\44\ Currently, the
Treasury Policy notes that Treasury ensures that payments are received
and honored by Clearing Participant's CDS related banking
relationships. Because ICC does not base its settlement of transactions
on whether a Clearing Participant's bank honors a payment direction,
ICC proposes correcting this text to note that Treasury ensures that
payments are received from Clearing Participants.\45\ ICC also proposes
removing text reading, ``within the Risk Management framework of the
clearing house'' from a provision that currently reads ``working within
the Risk Management framework of the clearing house to develop
investment and cash management strategies.'' The proposed rule change
would require the Treasury Department to work to develop investment and
collateral management strategies.\46\ ICC proposes removing the Risk
Management Framework language from this provision because the relevant
investment and collateral management policies are now housed in the
Treasury Policy instead of the Risk Management Framework.\47\ In the
Treasury Department Organizational Structure and Governance section of
the Treasury
[[Page 101669]]
Policy, ICC proposes removing text indicating that the Treasury
Department is part of ICC's Operations Department. The Treasury
Department is not and has never been a part of the Operations
Department.\48\
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\41\ Id. at 73734.
\42\ Id.
\43\ Id.
\44\ Id.
\45\ Id.
\46\ ICC's proposed replacement of cash management strategies
with collateral management strategies is described above in Section
4.
\47\ Notice, 89 FR at 73735.
\48\ Id.
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ICC also proposes corrections to the Funds Management section of
the Treasury Policy. Specifically, ICC would replace certain current
references to the Treasury Director making investments with statements
that the Treasury Department makes these investments. ICC proposes
these changes because it is ICC's practice for Treasury Department
personnel to make these investments under the Treasury Director's
supervision.\49\
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\49\ Id.
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In the Funds Management section's discussion of investment of US
Dollar cash posted as Margin or to the Guaranty Fund, ICC proposes a
change to reflect that ICC has multiple FRB accounts rather than a
single FRB account.\50\ ICC also proposes changing the description of
the minimum cash it is required to invest in a bilateral reverse repo
under certain circumstances. The current description states that the
minimum cash requirement is equal to 45% of the top two Clearing
Participant's ``risk margin,'' plus any excess margin not released,
plus 45% of the total Guaranty Fund. The revised description would
state that the minimum cash requirement is equal to 45% of the top two
Clearing Participant's ``Margin requirement,'' plus any excess margin
not released, plus 45% of the total Guaranty Fund. ICC believes this
change better reflects ICC's current practices because it is more
detailed and accurate. ICC believes the term ``Margin requirement''
specifically includes both initial and mark-to-market margin
requirements whereas the term ``risk margin'' is less specific.\51\
Where the Funds Management section discusses outside investment
management of Guaranty Fund and Margin cash, ICC proposes using the
plural term ``investment managers'' instead of the singular
``investment manager'' because, in practice, ICC uses more than one
outside investment manager to help it invest Guaranty Fund and Margin
cash.\52\ In a discussion of liquidity protection, ICC's proposal would
describe a requirement for Clearing Participants to maintain ``tiers of
collateral'' rather than ``tiers of assets.'' This is because ICC
believes the term ``collateral'' is more accurate in this instance
because it is a more precise description.\53\
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\50\ Id.
\51\ Id.
\52\ Id.
\53\ Id.
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ICC proposes corrections to the cash settlement section of the
Treasury Policy as well. In relation to routine settlement procedures,
the Treasury Policy currently indicates that, during the process of
monitoring whether a Clearing Participant has made timely payment, if a
Clearing Participant's payment is late ICC's Treasury Department
contacts the Clearing Participant and/or the agent bank. Because ICC
contacts the Clearing Participant directly if a payment is late and
does not contact the agent bank, ICC proposes removing the reference to
the agent bank.\54\ With respect to settlement procedures during a
SWIFT outage, the current Treasury Policy indicates that in the event
that ICC is unable to send SWIFT messages to its direct settlement
banks, the following back-up procedures would be used. ICC proposes
changes to this provision so that it indicates that in the event that
ICC is unable to send SWIFT messages to ``Clearing Participant
settlement banks,'' rather than ``direct settlement banks,'' it would
use certain back-up procedures. This proposal corrects an incorrect
reference to ``direct settlement banks'' in the current Treasury
Policy.\55\ For the same reason, ICC proposes replacing the term
``direct settlement banks'' with ``Clearing Participants'' in revisions
to procedures for communicating directly with a Clearing Participant
when there is a SWIFT outage.\56\ Specifically, ICC proposes changes to
the Treasury Policy noting that when there is a SWIFT message
disruption, it may become necessary to send a report directly to
``ICC's Clearing Participants'' rather than ``ICC's direct settlement
banks.'' As noted above, under the direct settlement model, ICC does
not maintain accounts at each of the Clearing Participant settlement
banks. Instead, ICC maintains direct debit authority over the Clearing
Participant settlement bank accounts as such authority is granted by
each Clearing Participant. Thus, it is more accurate to describe the
settlement banks as they relate to ICC's Clearing Participants, rather
than being ICC's direct settlement banks.
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\54\ Id. at 73736.
\55\ Id.
\56\ Id.
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ICC also proposes correcting language in the Treasury Policy
related to its FRB accounts. Currently, a subsection of the Treasury
Policy addressing ICC's FRB accounts addresses the possibility that ICC
would have only one FRB account. Due to certain requirements that ICC
segregate funds, ICC currently has separate FRB accounts for house and
client margin. To reflect this, ICC would refer to ``accounts'' instead
of an ``account'' or ``account(s)'' and remove outdated language
focused on the possibility that ICC would have a single FRB account.
ICC would also add text defining the terms House Account and Client
Account,\57\ replace text to utilize those terms,\58\ and note that ICC
maintains separate margin accounts for each Clearing Participant's
House Positions and Client Positions.
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\57\ ICC's proposal would also refer to the Client Account as a
Cleared Swaps Customer Account. The Proposed Rule Change would
incorporate these definitions throughout the Treasury Policy.
\58\ Specifically, ICC proposes replacing FRB House cash account
with FRB House Account and FRB Client cash account with FRB Client
Account.
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The Proposed Rule Change would also correct portions of the
Custodial Assets section of the Treasury Policy and update reporting
requirements for ICC's custodial banks. Instead of indicating that
custodial banks are required annually to submit a specific report, the
updated Treasury Policy would explain that custodial banks are subject
to ongoing monitoring pursuant to ICC's Counterparty Monitoring
Procedures, and the current requirement that custodial banks must
submit the specific report to ICC would be removed.\59\ With respect to
its collateral haircut methodology, ICC's proposed changes would
require ICC's Treasury Department to provide a report containing
current ``haircuts'' to the ICC Risk Department at least once a month
rather than only once a month and, further, this requirement would no
longer depend on whether the haircuts changed. Relatedly, ICC proposes
changes to reflect its current practice of making its haircuts publicly
available and notifying Clearing Participants of any changes to those
haircuts.\60\ The current Treasury Policy notes only that ICC will
establish and publish the haircuts to Clearing Participants monthly.
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\59\ Notice, 89 FR at 73736.
\60\ Id. at 73737.
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In the Bank Monitoring section of the Treasury Policy, ICC proposes
updating the current reference to the CDS Clearing Counterparty
Monitoring Procedures to reflect that these procedures are now called
the Counterparty Monitoring Procedures.\61\
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\61\ Id.
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6. Proposed Deletions of Obsolete and Unnecessary Text
ICC's proposal would delete unnecessary and obsolete language
[[Page 101670]]
throughout the Treasury Policy. In the description of the funds and
requirements that ICC's Treasury Department manages, the Proposed Rule
Change would remove a footnote identifying where to find the definition
of Guaranty Fund because, under ICC's proposal, the location of this
definition is now found in the Treasury Department Responsibilities
section of the Treasury Policy.\62\
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\62\ Notice, 89 FR at 73735.
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ICC proposes changing the description of ICC's investment of US
Dollar Cash posted as Margin or in the Guaranty Fund to remove language
it deems unnecessary. Currently, a provision in this section indicates
that, to facilitate reverse repo transactions, ICC has arrangements in
place to settle reverse repo transactions, either by tri-party or
bilateral, and that both arrangements settle delivery vs. payment. The
proposed provision would instead note that, to facilitate reverse repo
transactions, ICC has arrangements in place to settle reverse repo
transactions delivery vs. payment. This section of the Treasury Policy
also currently requires that when a security must be substituted, ICC
will ensure the replacement security is eligible and is valued
correctly by reviewing the replacement ticket issued by the
counterparty. ICC proposes deleting this requirement in its entirety.
In each case, ICC proposes the deletions because it does not believe
that the Treasury Policy needs to discuss these matters at the current
level of detail.\63\
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\63\ Id.
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The Proposed Rule Change would delete unnecessary provisions in the
Cash Settlement section of the Treasury Policy as well. With respect to
non-routine settlement procedures, the Treasury Policy current explains
that if ICC must process a cash payment from a Clearing Participant
outside of the normal daily process, an ICC authorized person will work
with the Clearing Participant to confirm the particulars of the non-
routine settlement. The Treasury Policy currently further explains that
ICC sends SWIFT MT-204(USD)\MT-202(EUR) settlement instructions to the
designated bank via the SWIFT network. The proposed rule change would
maintain the substance of this provision--ICC would work with the
Clearing Participant to confirm settlement outside of the daily
process--but it would delete the reference to the specific SWIFT
message. ICC maintains that reference the specific SWIFT message is
unnecessary because ICC and the Clearing Participant in question would
be expected to separately confirm the particulars of the settlement,
and further the type of SWIFT message could change in the future.\64\
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\64\ Id. at 73736.
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In the Treasury Policy's discussion of settlement procedures in the
event of a SWIFT outage, the Proposed Rule Change would also remove the
requirement that Margin Deficit Call Reports would be sent using a
password protected email. The Treasury Policy currently explains that,
in the event of a SWIFT outage, it may become necessary for ICC to
manually send these reports,\65\ as needed to satisfy margin debit
calls. The Treasury Policy currently explains that these Margin Deficit
Call Reports would be sent using a password protected email. The
Proposed Rule Change would remove the requirement that the email be
password protected. Because ICC does not believe that email security
measures need to be addressed in the Treasury Policy, the Proposed Rule
Change would instead require Margin Deficit Call Reports to be sent via
email.\66\ Thus, ICC would still send the Margin Deficit Call Reports
via email, as needed, but the Treasury Policy would not contain a
requirement that this email be password protected.\67\
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\65\ As described in Section II.5, ICC proposes changes to the
Treasury Policy to send these reports to ICC's Clearing Participants
rather than ICC's direct settlement banks. See infra Section II.5.
\66\ Notice, 89 FR at 73736.
\67\ Nevertheless, per other ICC policies, such as the ICE
Corporate Information and Security Policy, the Commission expects
this information would be sent in a secure manner.
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Currently, the Treasury Policy explains that, when a bank rejects a
SWIFT debit message because of a technical defect, the Treasury
Department will manually update the SWIFT Transaction Summary Report
and will manually initiate and send a SWIFT MT202 (bank to bank) and/or
MT204 (direct debit) message to reverse and/or correct previous
message(s) to the bank. ICC would amend this text to indicate that the
Treasury Department will correct the previous message(s) and/or re-
issue a corrected SWIFT message to the bank. Thus, rather than
referring to the specific type of SWIFT message (i.e. MT202), the
revised Treasury Policy would refer to SWIFT messages generally. This
change would remove what ICC views as unnecessary detail regarding
reissuing and correcting the SWIFT message and the specific type of
SWIFT message that will be sent, and further helps ensure that the
Treasury Policy remains accurate if the numbers of SWIFT messages are
updated or otherwise changed.\68\
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\68\ Notice, 89 FR at 73736.
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ICC would also remove unnecessary text from the Treasury Policy's
Custodial Assets section and Treasury Management for Client Business
section. Specifically, ICC would remove outdated language contemplating
a scenario where ICC only has one FRB securities account.\69\ ICC has
multiple FRB securities accounts.\70\ Further, when discussing when
client margin is due, ICC proposes removing text highlighting that
ICC's deadlines are in keeping with daily payment processes. ICC states
that it views this text as unnecessary.\71\ The remaining text would
still note when payments related to client business are due to ICC.
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\69\ Id.
\70\ Id.
\71\ Id. at 73737.
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In Appendix 2 of the Treasury Policy, ICC would remove information
related to its key contacts at a number of specific banks.
Specifically, ICC proposes removing the names of banks for which it
maintains a list of key contacts. ICC does not believe it needs to list
this level of detail in the Treasury Policy because the specific banks
are likely to change.\72\
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\72\ Id.
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7. Proposed Changes for Consistency Purposes
Finally, some of ICC's proposed changes are designed to ensure that
the Treasury Policy is internally consistent with itself, other ICC
rules and procedures, and external regulatory requirements. In the
Funds Management Section of the Treasury Policy, ICC proposes to add
the word ``requirements'' in multiple places to ensure that Margin and
Guaranty Fund requirements are referred to consistently throughout the
document.\73\ To ensure the Treasury Policy is consistent with other
ICC rules and procedures, ICC proposes adding language to the Treasury
Policy indicating that it maintains and manages House Margin and Client
Margin separately.\74\ To ensure the Treasury Policy is consistent with
certain regulatory requirements applicable to ICC, the Proposed Rule
Change would require that Initial Margin and Guaranty Fund requirements
are held in a manner
[[Page 101671]]
which minimizes the risk of loss or delay in ICC's access to
collateral, which mirrors the language used in the relevant regulatory
requirements.\75\ This would be a change from the current language,
which indicates that Margin and Guaranty Fund requirements must be held
in highly liquid and short term investments.
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\73\ Notice, 89 FR at 73735. For example, ICC would add the word
requirements to the introductory paragraph of the Funds Management
section so that it notes that Treasury is responsible for developing
investment strategies and managing each of the types of funds and
requirements in accordance with their respective restrictions and
ICC's Investment Policy. In another example, ICC proposes clarifying
that the Treasury Department is responsible for cash and non-cash
collateral originating from Initial Margin requirements posted by
Clearing Participants.
\74\ Id.
\75\ Id.
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The text and titles in and around several tables in the Funds
Management section of the Treasury Policy would also be changed to
ensure they are consistent with other sections of the Treasury
Policy.\76\ Specifically, in these tables ICC proposes using the terms
``USD cash'' instead of ``US Dollar Cash'' and ``US Cash,'' ``US
Treasury Securities'' instead of ``US Treasuries,'' and ``EUR cash''
instead of ``Euro Cash'' to mirror the terms used in the rest of the
revised Treasury Policy.\77\ ICC also proposes using defined terms
throughout the Treasury Policy, such as House Margin.
---------------------------------------------------------------------------
\76\ Id.
\77\ Similar changes are made throughout the Treasury Policy.
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ICC proposes changes to the Participants' Withdrawal subsection of
the Funds Management section as well. Specifically, ICC would add text
indicating that Guaranty Fund deposits are not eligible to be returned
to a withdrawing Clearing Participant until after all of the open
positions of such withdrawing Clearing Participant are closed out and
all obligations of such withdrawing Clearing Participant to ICC have
been satisfied. ICC proposes this change to make this provision
consistent with Rule 807 of the ICC Rulebook. Similarly, a current
provision in the Participants' Withdrawal subsection indicates that, if
a Clearing Participant provides notice of withdrawal less than 60 days
from the end of the quarter, the Clearing Participant's withdrawal will
be effective at the end of the subsequent calendar quarter. However,
because this is not consistent with or required under ICC's rules, the
Proposed Rule Change would delete this provision from the Treasury
Policy.\78\
---------------------------------------------------------------------------
\78\ Id. at 73735.
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Finally, in the section of the Treasury Policy discussing ICC's use
of committed repo facilities, ICC proposes modifying certain text
describing how expenses are attributed. Currently, the Treasury Policy
indicates that interest expenses incurred through such facilities are
attributed to the account of the defaulting Clearing Participant. ICC's
proposal would indicate that all expenses incurred through such
facilities, including interest expenses, are attributed to the account
of the defaulting Clearing Participant. ICC indicates that this
proposed change is consistent with the approach for allocation of
close-out costs to a defaulter under ICC's Rulebook.\79\
---------------------------------------------------------------------------
\79\ Id.
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III. Discussion and Commission Findings
Section 19(b)(2)(C) of the Act requires the Commission to approve a
proposed rule change of a self-regulatory organization if it finds that
the proposed rule change is consistent with the requirements of the Act
and the rules and regulations thereunder applicable to the
organization.\80\ For the reasons given below, the Commission finds
that the proposed rule change is consistent with Section 17A(b)(3)(F)
of the Act \81\ and Rule 17Ad-22(e)(7) \82\ and (e)(16).\83\
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\80\ 15 U.S.C. 78s(b)(2)(C).
\81\ 15 U.S.C. 78q-1(b)(3)(F).
\82\ 17 CFR 240Ad-22(e)(7).
\83\ 17 CFR 240Ad-22(e)(16).
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A. Consistency With Section 17A(b)(3)(F) of the Act
Under Section 17A(b)(3)(F) of the Act, ICC's rules, among other
things, must be ``designed to promote the prompt and accurate clearance
and settlement of securities transactions and, to the extent
applicable, derivative agreements, contracts, and 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.'' \84\ Based on a review of the record, and for the
reasons discussed below, ICC's proposed rule change is consistent with
Section 17A(b)(3)(F).
---------------------------------------------------------------------------
\84\ 15 U.S.C. 78q-1(b)(3)(F).
---------------------------------------------------------------------------
Among other things, the Proposed Rule Change updates the Treasury
Policy by adding additional detail to various provisions and making
various clarifications.\85\ For example, the Proposed Rule Change would
better explain what the Treasury Department does; define specific
terms, such as Margin, and use those terms consistently throughout the
Treasury Policy; and align the language and descriptions used in the
Treasury Policy with ICC's current practices, such as assigning
responsibility for ICC's timely receipt of requested payments to the
Clearing Participants under the direct settlement model.
---------------------------------------------------------------------------
\85\ Notice, 89 FR at 73734.
---------------------------------------------------------------------------
The Proposed Rule Change also updates the Treasury Policy by
correcting certain inaccuracies within the policy, deleting unnecessary
language, and making various conforming changes to ensure that the
Treasury Policy is internally consistent with itself, consistent with
other ICC policies and rules, and consistent with external rules. For
example, because relevant investment and collateral management policies
are now housed in the Treasury Policy instead of the Risk Management
Framework, ICC would remove language indicating that developing
investment and collateral management strategies could only be performed
within ICC's Risk Management Framework. As a result, ICC's Treasury
Department will be required to work to develop investment and
collateral management strategies irrespective of whether it does so
within ICC's Risk Management Framework. The Treasury Policy would also
be updated to correctly identify the parties responsible for investing
certain funds, correctly identify certain procedures referenced within
the Treasury Policy, and make changes reflecting that ICC has more than
one FRB account and more than one investment manager. ICC would also
remove what it believes are unnecessary details from certain provisions
of the Treasury Policy, such as information identifying specific types
of repo transactions and specific information regarding email security.
To help ensure the Treasury Policy is both internally and externally
consistent, the Proposed Rule Change would revise the Treasury Policy
to indicate that ICC manages House Margin and Client Margin
separately--consistent with other ICC policies and procedures--and
modify certain terms used in the Treasury Policy to mirror the terms
used elsewhere in the Treasury Policy and in other ICC rules. These
changes also improve the clarity of the Treasury Policy and decrease
the possibility for error in using and applying the Treasury Policy.
Moreover, eliminating unnecessary details and provisions from the
Treasury Policy helps ensure both that it will need to be amended less
frequently in the event those details change and that, in the event
revisions are necessary, that such revisions are less prone to error.
Avoiding errors in the amendment process also improves their clarity as
a whole and decreases the possibility for error in applying them.
The Proposed Rule Change would also expand certain provisions in
the Treasury Policy by replacing specific terms in the Treasury Policy
with more general terms and adding broadening language to existing
text. For example, in certain instances, ICC would refer to collateral
generally instead of more specific forms of collateral. ICC would
[[Page 101672]]
also account for potential changes in banking relationships and SWIFT
messages by referring to these relationships and messages more
generally. Taken together, the use of these broader, more general terms
would immediately improve the accuracy of the Treasury Policy and help
ensure that it remains accurate in the event there are non-substantive
changes to ICC's banking relationships and the specific types of SWIFT
messages that ICC uses.
By adding additional details and clarifications, correcting
inaccuracies, deleting unnecessary language, making conforming changes
to ensure internal and external consistency, and replace unnecessarily
specific terms with broader, more general terms, the Proposed Rule
Change helps ensure that the Treasury Policy is and will remain clear,
consistent, and current, which in turn decreases the likelihood that
the Treasury Policy and its provisions will be applied erroneously or
inconsistently. This decreases the likelihood of ICC's mismanagement of
collateral, which facilitates the prompt and accurate clearance and
settlement of transactions and assures the safeguarding of securities
and funds within ICC's custody or control.
ICC also proposes adding additional criteria for settlement banks.
Because settlement banks ultimately custody the funds that Clearing
Participants will use to satisfy their obligations to ICC, ICC needs
visibility into a settlement bank's liquidity. To ensure that ICC has
such visibility, the Proposed Rule Change would update the Treasury
Policy to require that settlement banks provide specific liquidity
information to ICC. An example of the liquidity information that ICC
requires from settlement banks is the banks' Liquidity Coverage Ratio.
In the event that the bank does not report LCR, the Proposed Rule
Change would specify that ICC will consider other criteria to assess
the liquidity of the bank. These other criteria may include a
description of the bank's liquidity risk management policy or the
liquidity coverage ratio of the settlement bank's affiliated reporting
entity within the bank's group. Ensuring that ICC has this information
will help ICC avoid a relationship with a settlement bank that is
unable to satisfy obligations on a Clearing Participant's behalf,
despite the Clearing Participant being financially sound. Preventing
relationships with illiquid settlement banks would help facilitate the
prompt and accurate clearance and settlement of transactions and assure
the safeguarding of securities and funds within ICC's custody or
control.
Finally, ICC proposes changes to its investment guidelines.
Specifically, ICC proposes eliminating the restriction that it may only
invest in certain U.S. Treasury Securities when bank deposits or
Treasury/Agency reverse repos become unavailable or are not feasible.
The Proposed Rule Change would specify that ICC would primarily
directly invest in U.S. Treasury securities with respect to stable
balances, for example, restricted cash held for regulatory purposes.
ICC proposes this change because it believes the change would give it
greater flexibility while preserving the quality of investments. ICC
also proposes requiring the value of collateral in the case of a
reverse repo to be fixed at 102 percent instead of ranging between
100.5 percent to 102 percent. Given the safety of these investments,
ICC's proposal to potentially invest cash held for regulatory purposes
in U.S. Treasury securities is consistent with the safeguarding of
securities and funds within ICC's custody or control.\86\ Further,
ICC's proposal to ensure that the value of collateral will always be
102 percent in a reverse repo provides ICC with greater protection in
the event that it provides cash to an entity in exchange for the
entity's promise to repurchase a security from ICC at a higher price
because it helps to ensure that ICC will receive a larger amount if an
entity is unable to purchase securities back at the agreed upon price.
This protects ICC as it invests its cash balances and therefore is
consistent with the safeguarding of securities and funds within ICC's
control.
---------------------------------------------------------------------------
\86\ Certain maturity limitations will still apply to the U.S.
Treasuries in which ICC is allowed to invest. Id. at 73738.
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Accordingly, the proposed rule change is consistent with the
requirements of Section 17A(b)(3)(F) of the Act.\87\
---------------------------------------------------------------------------
\87\ 15 U.S.C. 78q-1(b)(3)(F).
---------------------------------------------------------------------------
B. Consistency With Rule 17Ad-22(e)(7)
Rule 17Ad-22(e)(7) requires ICC to ``establish, implement,
maintain, and enforce written policies and procedures reasonably
designed to . . . effectively measure, monitor, and manage the
liquidity risk that arises or is borne by the covered clearing agency .
. . by at a minimum . . . undertaking due diligence to confirm that it
has a reasonable basis to believe each of its liquidity providers,
whether or not such liquidity provider is a clearing member, has . . .
the capacity to perform as required under its commitments to provide
liquidity to the covered clearing agency.'' \88\ Based on a review of
the record, and for the reasons discussed below, ICC's proposed rule
change is consistent with Rule 17Ad-22(e)(7).
---------------------------------------------------------------------------
\88\ 17 CFR 240.17Ad-22(e)(7).
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The Proposed Rule Change would add to ICC's minimum criteria for
settlement banks by requiring that a settlement bank provide specific
liquidity information such as the Liquidity Coverage Ratio. Obtaining
this information can help ensure that ICC is able to determine whether
a settlement bank with which it has a relationship is facing liquidity
issues. Performing such diligence is consistent with the requirements
of Rule 17Ad-22(e)(7) because a settlement bank's liquidity issues may
prevent an otherwise liquid Clearing Participant from satisfying its
obligations.
Accordingly, that the proposed rule change is consistent with the
requirements of Rule 17Ad-22(e)(7).\89\
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\89\ 17 CFR 240.17Ad-22(e)(7).
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C. Consistency With Rule 17Ad-22(e)(16)
Rule 17Ad-22(e)(16) requires ICC to ``establish, implement,
maintain, and enforce written policies and procedures reasonably
designed to . . . safeguard the covered clearing agency's own and its
participants' assets, minimize the risk of loss and delay in these
assets, and invest such assets in instruments with minimal credit,
market, and liquidity risks.'' \90\ Based on a review of the record,
and for the reasons discussed below, ICC's proposed rule change is
consistent with Rule 17Ad-22(e)(16).
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\90\ 17 CFR 240.17Ad-22(e)(16).
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As noted above, ICC proposes eliminating the restriction that it
may only invest its operating capital in certain U.S. Treasury
Securities when bank deposits or Treasury/Agency reverse repos become
unavailable or are not feasible. While ICC is not required to invest
its own or its Participants' assets, if it does so, it generally should
seek to minimize the risk of loss or delay in access to the invested
assets by investing in highly liquid assets.\91\ The Commission has
previously stated that U.S. Treasury securities are highly liquid.\92\
ICC's proposal to invest its assets in U.S. treasury securities is
therefore consistent with Rule 17Ad-22(e)(16).
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\91\ Securities Exchange Act Release No. 78961 (Sept. 28, 2016),
81 FR 70786, 70837 (Oct. 13, 2016) (File No. S7-03-14).
\92\ Id.
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Accordingly, the Proposed Rule Change is consistent with the
requirements of Rule 17Ad-22(e)(16).\93\
---------------------------------------------------------------------------
\93\ 17 CFR 240.17Ad-22(e)(16).
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[[Page 101673]]
IV. Conclusion
On the basis of the foregoing, the Commission finds that the
proposed rule change is consistent with the requirements of the Act,
and in particular, Section 17A(b)(3)(F) of the Act \94\ and Rule 17Ad-
22(e)(7) \95\ and (e)(16) thereunder.\96\
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\94\ 15 U.S.C. 78q-1(b)(3)(F).
\95\ 17 CFR 240.17Ad-22(e)(7).
\96\ 17 CFR 240.17Ad-22(e)(16).
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It is therefore ordered pursuant to Section 19(b)(2) of the Act
that the proposed rule change (SR-ICC-2024-005) be, and hereby is,
approved.\97\
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\97\ In approving the proposed rule change, the Commission
considered the proposal's impacts on efficiency, competition, and
capital formation. 15 U.S.C. 78c(f).
For the Commission by the Division of Trading and Markets,
pursuant to delegated authority.\98\
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\98\ 17 CFR 200.30-3(a)(12).
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Sherry R. Haywood,
Assistant Secretary.
[FR Doc. 2024-29474 Filed 12-13-24; 8:45 am]
BILLING CODE 8011-01-P
</pre></body>
</html>Indexed from Federal Register on December 16, 2024.
This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.