Notice2025-03071

Self-Regulatory Organizations; The Options Clearing Corporation; Notice of Filing of Advance Notice Relating to The Options Clearing Corporation's Proposed Amendments to Certain Key Terms of a Master Repurchase Agreement for a Committed Liquidity Facility With a Bank Counterparty as Part of the Options Clearing Corporation's Overall Liquidity Plan

Primary source

Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.

Published
February 26, 2025

Issuing agencies

Securities and Exchange Commission

Full Text

<html>
<head>
<title>Federal Register, Volume 90 Issue 37 (Wednesday, February 26, 2025)</title>
</head>
<body><pre>
[Federal Register Volume 90, Number 37 (Wednesday, February 26, 2025)]
[Notices]
[Pages 10734-10738]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-03071]


-----------------------------------------------------------------------

SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-102462; File No. SR-OCC-2025-801]


Self-Regulatory Organizations; The Options Clearing Corporation; 
Notice of Filing of Advance Notice Relating to The Options Clearing 
Corporation's Proposed Amendments to Certain Key Terms of a Master 
Repurchase Agreement for a Committed Liquidity Facility With a Bank 
Counterparty as Part of the Options Clearing Corporation's Overall 
Liquidity Plan

February 20, 2025.
    Pursuant to Section 806(e)(1) of Title VIII of the Dodd-Frank Wall 
Street Reform and Consumer Protection Act, entitled Payment, Clearing 
and Settlement Supervision Act of 2010 (``Clearing Supervision Act'') 
\1\ and Rule 19b-4(n)(1)(i) \2\ of the Securities Exchange Act of 1934 
(``Exchange Act'' or ``Act''),\3\ notice is hereby given that on 
February 14, 2025, The Options Clearing Corporation (``OCC'' or 
``Corporation'') filed with the Securities and Exchange Commission 
(``Commission'') an advance notice as described in Items I, II and III 
below, which Items have been prepared primarily by OCC. The Commission 
is publishing this notice to solicit comments on the advance notice 
from interested persons.
---------------------------------------------------------------------------

    \1\ 12 U.S.C. 5465(e)(1).
    \2\ 17 CFR 240.19b-4(n)(1)(i).
    \3\ 15 U.S.C. 78a et seq.
---------------------------------------------------------------------------

I. Clearing Agency's Statement of the Terms of Substance of the Advance 
Notice

    This advance notice is submitted in connection with a proposed 
change to its operations in the form of amendments to certain key terms 
of a Master Repurchase Agreement for a committed liquidity facility 
with a bank counterparty as part of OCC's overall liquidity plan. The 
proposed change does not require any changes to the text of OCC's By-
Laws or Rules. All terms with initial capitalization that are not 
otherwise defined herein have the same meaning as set forth in the OCC 
By-Laws and Rules.\4\
---------------------------------------------------------------------------

    \4\ OCC's By-Laws and Rules can be found on OCC's public 
website: <a href="https://www.theocc.com/Company-Information/Documents-and-Archives/By-Laws-and-Rules">https://www.theocc.com/Company-Information/Documents-and-Archives/By-Laws-and-Rules</a>.
---------------------------------------------------------------------------

II. Clearing Agency's Statement of the Purpose of, and Statutory Basis 
for, the Advance Notice

    In its filing with the Commission, OCC included statements 
concerning the purpose of and basis for the advance notice and 
discussed any comments it received on the advance notice. The text of 
these statements may be examined at the places specified in Item IV 
below. OCC has prepared summaries, set forth in sections (A) and (B) 
below, of the most significant aspects of these statements.

(A) Clearing Agency's Statement on Comments on the Advance Notice 
Received From Members, Participants or Others

    Written comments were not and are not intended to be solicited with 
respect to the proposed change and none have been received.

(B) Advance Notice Filed Pursuant to Section 806(e) of the Payment, 
Clearing, and Settlement Supervision Act

Description of the Proposed Change
    OCC is the sole clearing agency for standardized equity options 
listed on national securities exchanges registered with the Commission. 
In its role as a registered clearing agency, and as a derivatives 
clearing organization (``DCO'') registered with the Commodity Futures 
Trading Commission (``CFTC''), OCC acts as a central counterparty 
(``CCP'') that guarantees all contracts it clears. That is, OCC becomes 
the buyer to every seller and the seller to every buyer. In its role as 
guarantor, OCC is exposed to risks from a Clearing Member's failure to 
fulfill its obligations. In the event of a Clearing Member default, OCC 
would be obligated to fulfill that member's cleared transactions and 
meet settlement obligations in a timely manner.
    OCC manages these financial risks by maintaining an overall 
liquidity plan that provides access to a diverse set of funding 
sources, including a syndicated bank credit facility \5\ and a program 
for accessing additional committed sources of liquidity that do not 
increase the concentration of OCC's counterparty exposure (``Non-Bank 
Liquidity Facility'').\6\ These facilities provide OCC with cash in 
exchange for collateral, such as U.S. Government securities deposited 
by Clearing Members in satisfaction of their Clearing Fund 
requirements. Together with the minimum amount of cash OCC requires 
each Clearing Member to deposit in the Clearing Fund (``Clearing Fund 
Cash Requirement'') \7\ and any excess cash a Clearing Member may 
choose to maintain up to its required Clearing Fund contribution,\8\ 
the facilities comprise part of OCC's qualifying liquid resources to 
satisfy its regulatory obligations.\9\
---------------------------------------------------------------------------

    \5\ See, e.g., Exchange Act Release No. 88971 (May 28, 2020), 85 
FR 34257 (June 3, 2020) (SR-OCC-2020-804).
    \6\ See, e.g., Exchange Act Release No. 89039 (June 10, 2020), 
85 FR 36444 (June 16, 2020) (SR-OCC-2020-803).
    \7\ See OCC Rule 1002.
    \8\ Clearing Members that choose to satisfy their Clearing Fund 
requirement with more than the minimum amount of cash may choose to 
do so, in part, because of the interest earned on Clearing Fund cash 
held at a Federal Reserve Bank, which OCC passes through to the 
Clearing Member. See OCC Rule 1002(b). Substitution of U.S. 
Government securities in place of excess cash is subject to a two-
day notification period, which aligns with OCC's liquidation time 
horizon for managing a Clearing Member default. See OCC Rule 
1002(a)(iv). Accordingly, OCC considers excess cash up to the 
Clearing Member's Clearing Fund requirement as part of its 
``Available Liquidity Resources'' under its Liquidity Risk 
Management Framework. See Exchange Act Release No. 89014 (June 4, 
2020), 85 FR 35446, 35447 (June 10, 2020) (SR-OCC-2020-003).
    \9\ See 17 CFR 17ad-22(e)(7)(i) (requiring covered clearing 
agencies to, among other things, maintain sufficient liquid 
resources 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 the default of the participant family that would generate 
the largest aggregate payment obligation in extreme but plausible 
market conditions); 17 CFR 39.11(e) (requiring that a DCO 
effectively measure, monitor, and manage its liquidity risks such 
that it can, at a minimum, fulfill its cash obligations when due and 
that that financial resources allocated to meet its requirements 
shall be sufficiently liquid to enable the DCO to fulfill its 
obligations as a central counterparty during a one-day settlement 
cycle).

---------------------------------------------------------------------------

[[Page 10735]]

    In 2020, OCC also entered into a one-year Master Repurchase 
Agreement (``MRA''), otherwise known as a ``repo,'' with a bank 
counterparty,\10\ and most recently in 2022 filed an advance notice to 
establish an MRA with a bank counterparty on an ongoing basis with a 
commitment amount of up to $1 billion (the ``Bank Repo Facility'').\11\ 
Under the Bank Repo Facility, the buyer (i.e., the bank counterparty) 
would purchase U.S. Government securities from OCC from time to time in 
exchange for a buyer payment to OCC in immediately available funds 
(``Purchase Price''). The buyer would simultaneously agree to transfer 
the purchased securities back to OCC at a specified later date 
(``Repurchase Date''), or on OCC's demand against the transfer of funds 
from OCC to the buyer, where the funds would be equal to the 
outstanding Purchase Price plus the accrued and unpaid price 
differential (together, ``Repurchase Price''). The 2022 advance notice 
also discussed the MRA terms OCC would require under the Bank Repo 
Facility, including that, like the current Non-Bank Liquidity 
Facility,\12\ the buyer may not pledge, charge, encumber, hypothecate, 
transfer, dispose of, or otherwise grant any third party any interest 
in (i.e., ``rehypothecate'') any eligible securities.\13\ This 
prohibition on rehypothecation was intended to prevent the bank from 
granting any third party an interest in purchased securities in order 
to reduce the risk that the third party could interfere with the 
buyer's transfer of the U.S. Government securities collateral to OCC on 
the Repurchase Date.\14\
---------------------------------------------------------------------------

    \10\ See Exchange Act Release No. 88317 (Mar. 4, 2020), 85 FR 
13681 (Mar. 9, 2020) (SR-OCC-2020-801).
    \11\ See Exchange Act Release No. 95669 (Sept. 2, 2022), 87 FR 
55064 (Sept. 8, 2022) (SR-OCC-2022-802).
    \12\ Exchange Act Release No. 89039, supra note 6, at 36445 n.14 
and accompanying text.
    \13\ See Exchange Act Release No. 95669, supra note 11, at 
55064-66.
    \14\ Id.
---------------------------------------------------------------------------

    The parties have yet to execute the Bank Repo Facility following 
the Commission's notice of no objection for OCC's 2022 advance notice. 
The prohibition on rehypothecation is not a standard feature for 
bilateral repo transactions like the one contemplated by the Bank Repo 
Facility and its inclusion in the MRA made the transaction less 
commercially appealing to the bank counterparty than initially 
anticipated. The delay in implementing the Bank Repo Facility has not, 
however, materially affected OCC's liquidity risk management because 
OCC has, since its 2022 expansion of the Non-Bank Liquidity 
Facility,\15\ generally maintained sufficient capacity under its other 
committed facilities to exchange all U.S. Government securities 
deposited in respect of the Clearing Fund.
---------------------------------------------------------------------------

    \15\ See Exchange Act Release No. 89039, supra note 6.
---------------------------------------------------------------------------

Proposed Change
    On a regular basis, OCC reviews its access to such liquidity 
facilities to calibrate its potential funding requirements to meet 
payment obligations under stressed market conditions. The review and 
ongoing negotiations with the bank counterparty identified an 
opportunity for OCC to provide terms that would be more commercially 
attractive, thereby allowing OCC and its bank counterparty to move 
forward with the Bank Repo Facility. Specifically, OCC proposes to 
modify the Bank Repo Facility to provide for a limited right to 
rehypothecate the non-customer collateral,\16\ provided that the 
rehypothecation is: (i) within a tri-party repo program \17\ of a 
third-party custodian where the buyer would hold the eligible 
securities in a custodial account; and (ii) only to a third-party cash 
investor (e.g., large institutional money market funds) that is legally 
restricted from further pledging, charging, encumbering, hypothecating, 
transferring, disposing of or otherwise granting any interest in the 
purchased securities. These limitations would ensure that the 
securities remain at the buyer's custodial bank in a segregated account 
on behalf of the third-party cash investor. OCC believes these terms 
would create the required commercial incentives to move forward with 
the Bank Repo Facility. The remainder of the other terms and conditions 
of the Bank Repo Facility addressed in the 2022 advance notice would 
remain unchanged, including the conditions under which OCC would file 
another advance notice with respect to annual renewals or changes to 
the Bank Repo Facility.\18\
---------------------------------------------------------------------------

    \16\ Clearing Fund collateral and non-customer margin collateral 
of any suspended Clearing Member may be pledged under the Bank Repo 
Facility. OCC Rule 1006(f) and OCC Rule 1104(b) provide for and 
authorize OCC to obtain funds from third parties to meet its 
obligations. The officers who may exercise this authority include 
the Chairman, Chief Executive Officer, and Chief Operating Officer. 
Clearing Fund collateral is distinct from, and does not include, 
margin collateral related to customer positions.
    \17\ Tri-party repos use a custodian bank that provides 
collateral valuation, margining, and management services to the 
counterparties to the agreement. OCC understands that unlike with 
respect to the bilateral repo market, prohibiting further 
rehypothecation is not uncommon in the tri-party repo market.
    \18\ Exchange Act Release No. 95669, supra note 11, at 55066 
(``OCC would submit another advance notice with respect to such 
renewal for the same term only under one of the following 
conditions: (1) OCC determines its liquidity needs merit funding 
levels above the $1 billion; (2) OCC should seek to change the terms 
and conditions of the MRA in a manner that materially affects the 
nature or level of risk presented by OCC; (3) OCC should seek to add 
counterparties or substitute the bank counterparty to the Bank Repo 
Facility program; or (4) the bank counterparty has experienced a 
negative change to its credit profile or a material adverse change 
since the latest renewal of the MRA'').
---------------------------------------------------------------------------

Anticipated Effect on and Management of Risk
    Like any liquidity resource, the Bank Repo Facility would involve 
certain risks, most of which are standard to any repo transaction. OCC 
has structured the program to mitigate and address such risks. As 
discussed above, OCC plays a crucial role as a clearing agency by 
ensuring timely fulfillment of settlement obligations and mitigating 
the risks related to settlement failures. Therefore, it is essential 
for OCC to have continuous, reliable, and consistent access to funds 
from a diverse group of liquidity sources to settle its obligations. In 
removing the prohibition and establishing a limited rehypothecation 
right, OCC believes it can expand access to new sources of funding by 
offering standard market terms that would encourage the bank 
counterparty to enter into and execute an MRA pursuant to the revised 
terms of the Bank Repo Facility. OCC understands that the ability to 
rehypothecate would provide the bank with favorable capital treatment, 
allowing for reduced pricing and a larger commitment size (subject to 
the Bank Repo Facility's currently approved $1 billion maximum). 
Increasing access to additional sources of liquidity would, in turn, 
promote the reduction of OCC's liquidity risk from the default or 
suspension of a member or the other circumstances in which it may 
access the Clearing Fund to meet liquidity needs.
    The Bank Repo Facility, once in place, would also help OCC address 
the risks arising from a change in circumstances that may remove or 
restrict access to one or more of OCC's other current liquidity 
facilities. This facility would act as an alternative source of 
liquidity providing OCC with ability to reallocate across existing 
facilities as necessary to avoid a

[[Page 10736]]

shortfall in its overall resources and meet liquidity demands relative 
to OCC's base liquidity resources. The new facility will also help OCC 
to operationally manage allocations across funding sources more 
effectively based on pricing, market conditions, and liquidity needs.
    Furthermore, OCC believes it can mitigate the risks attendant to 
the Bank Repo Facility without prohibiting rehypothecation by the 
buyer. First, nothing in OCC's current By-Laws or Rules limit how OCC 
may use the Clearing Fund collateral, or what rights it may grant 
others in respect of Clearing Fund collateral, to address a Clearing 
Member default or other circumstance in which use of Clearing Fund 
collateral is permitted. To the contrary, OCC is authorized to take 
possession of the Government securities deposited by Clearing Members 
as contributions to the Clearing Fund to borrow or otherwise obtain 
funds through means determined to be reasonable at the discretion of 
OCC's Chairman, Chief Executive Officer or Chief Operating Officer, 
including, without limitation, pledging such assets as security for 
loans or using such assets to effect repurchase, securities lending or 
other transactions.\19\
---------------------------------------------------------------------------

    \19\ See OCC Rule 1006(f)(2)(A)(iii).
---------------------------------------------------------------------------

    Second, OCC has already mitigated one of the risks relating to the 
prohibition on rehypothecation. Prior to 2021, there was ambiguity as 
to whether OCC was obligated to honor a Clearing Member's request to 
substitute Clearing Fund collateral after OCC had initiated a draw 
through one of the facilities, or otherwise initiated a borrowing using 
Clearing Fund collateral under OCC Rule 1006(f). Given this ambiguity, 
OCC has historically included terms in its facilities that would allow 
OCC to substitute any collateral by a specified time so that OCC could 
then honor its Clearing Members' substitution requests.\20\ The 
prohibition on rehypothecation facilitated such substitution by 
ensuring that a third party could not interfere with OCC's ability to 
honor a Clearing Member's substitution request. However, OCC has since 
amended OCC Rule 1006(f) to make clear that OCC has the authority to 
reject substitution requests for securities contributed to the Clearing 
Fund that the Corporation has taken possession of to borrow funds from 
OCC's liquidity facilities.\21\ While OCC may facilitate substitutions 
following a draw as a convenience and accommodation to Clearing 
Members, it is no longer required to do so.
---------------------------------------------------------------------------

    \20\ See, e.g., Exchange Act Release Nos. 95669, supra note 11, 
at 55065 n.25 and accompanying text; 88317, supra note 10, at 13682; 
73979 (Jan. 2, 2015), 80 FR 1062, 1064 (Jan. 8, 2015) (SR-OCC-2014-
809).
    \21\ See Exchange Act Release No. 89014, supra note 8, at 35450.
---------------------------------------------------------------------------

    Third, OCC would mitigate the risk that a third-party could 
interfere with the buyer's ability to return the purchased securities 
on the Repurchase Date through the limitations on the rehypothecation 
right that OCC is proposing based on its negotiations with the bank 
counterparty. Such rehypothecation would be limited to cash investors 
(e.g., large institutional money market funds) who are party to a tri-
party repo agreement with the bank counterparty. These third parties 
would be prohibited from themselves rehypothecating the collateral, 
which would be maintained in the tri-party custodial bank. 
Additionally, a bank counterparty's failure to return the Clearing Fund 
collateral on the Repurchase Date due to the interference of a third-
party or otherwise would itself be a condition under which OCC could 
utilize Clearing Fund collateral or charge the Clearing Fund in order 
to manage OCC's liquidity risk and meet daily settlement 
obligations.\22\
---------------------------------------------------------------------------

    \22\ See OCC Rule 1006(a) (providing that the Clearing Fund may 
be used for borrowings, or to make good losses or expenses suffered 
by OCC resulting from borrowings, as a result of, among other 
things, the failure of any bank to perform its obligations to OCC); 
Rule 1006(f)(1)(C) (authorizing OCC to initiate a borrowing using 
Clearing Fund collateral when OCC reasonably believes it necessary 
to borrow to meet its liquidity needs for daily settlement as a 
result of, among other things, the failure of any bank to perform 
any obligation to OCC when due).
---------------------------------------------------------------------------

    Finally, OCC's rights under the agreement would not be impaired by 
the bankruptcy or receivership of the bank counterparty. A repo falls 
within the safe harbors from an automatic stay under the Bankruptcy 
Code.\23\ A repo is also a qualified financial contract (``QFC'') under 
the Federal Deposit Insurance Act (``FDIA'') \24\ and Title II of Dodd-
Frank.\25\ Accordingly, OCC's rights under the repo agreement to 
terminate, liquidate or accelerate would not be subject to the 90-day 
stay in receivership.\26\
---------------------------------------------------------------------------

    \23\ 11 U.S.C. 559.
    \24\ 12 U.S.C. 1821(e)(8)(D)(ii)(I). The FDIA is applicable to 
insured national banks and state-charted banks when an institution 
becomes insolvent and the Federal Deposit Insurance Corporation 
(``FDIC'') is appointed as a receiver.
    \25\ 12 U.S.C. 5390(c)(8)(D)(i). Title II of Dodd-Frank is 
applicable to FDIC-insured banks that are designated as systemically 
important financial institutions (``SIFIs'').
    \26\ See, e.g., 12 U.S.C. 5390(c)(8)(A) (``no person shall be 
stayed or prohibited from exercising . . . (i) any right that such 
person has to cause the termination, liquidation, or acceleration of 
any [QFC] with a covered financial company which arises upon the 
date of appointment of the [FDIC] as receiver for such covered 
financial company or at any time after such appointment'').
---------------------------------------------------------------------------

Consistency With the Payment, Clearing and Settlement Supervision Act
    The stated purpose of the Clearing Supervision Act is to mitigate 
systemic risk in the financial system and promote financial stability 
by, among other things, promoting uniform risk management standards for 
systemically important financial market utilities and strengthening the 
liquidity of systemically important financial market utilities.\27\ 
Section 805(a)(2) of the Clearing Supervision Act \28\ also authorizes 
the Commission to prescribe risk management standards for the payment, 
clearing and settlement activities of designated clearing entities, 
like OCC, for which the Commission is the supervisory agency. Section 
805(b) of the Clearing Supervision Act \29\ states that the objectives 
and principles for risk management standards prescribed under Section 
805(a) shall be to:
---------------------------------------------------------------------------

    \27\ 12 U.S.C. 5461(b).
    \28\ 12 U.S.C. 5464(a)(2).
    \29\ 12 U.S.C. 5464(b).
---------------------------------------------------------------------------

    <bullet> promote robust risk management;
    <bullet> promote safety and soundness;
    <bullet> reduce systemic risks; and
    <bullet> support the stability of the broader financial system.
    The Commission has adopted risk management standards under Section 
805(a)(2) of the Clearing Supervision Act and the Exchange Act in 
furtherance of these objectives and principles.\30\ Rule 17Ad-22 
requires registered clearing agencies, like OCC, to establish, 
implement, maintain, and enforce written policies and procedures that 
are reasonably designed to meet certain minimum requirements for their 
operations and risk management practices on an ongoing basis.\31\ 
Therefore, the Commission has stated \32\ that it believes it is 
appropriate to review changes proposed in advance notices against Rule 
17Ad-22 and the objectives and principles of these risk management 
standards as described in Section 805(b) of the Clearing Supervision 
Act.\33\
---------------------------------------------------------------------------

    \30\ 17 CFR 240.17ad-22. See Exchange Act Release Nos. 68080 
(Oct. 22, 2012), 77 FR 66220 (Nov. 2, 2012) (S7-08-11) (``Clearing 
Agency Standards''); 78961 (Sept. 28, 2016), 81 FR 70786 (Oct. 13, 
2016) (S7-03-14) (``Standards for Covered Clearing Agencies'').
    \31\ 17 CFR 240.17ad-22.
    \32\ See, e.g., Exchange Act Release No. 86182 (June 24, 2019), 
84 FR 31128, 31129 (June 28, 2019) (SR-OCC-2019-803).
    \33\ 12 U.S.C. 5464(b).
---------------------------------------------------------------------------

    OCC believes that the proposed changes are consistent with Section

[[Page 10737]]

805(b)(1) of the Clearing Supervision Act \34\ because the proposed 
modified terms of the MRA under the Bank Repo Facility would provide 
OCC with access to an additional source of committed liquidity and 
provide a new funding option within its risk management toolbox to 
manage financial obligations more efficiently and effectively. The Bank 
Repo Facility, as described above, is structured to mitigate the risks 
that arise in connection with this committed liquidity facility by 
allowing OCC to move forward with the Bank Repo Facility while managing 
the related risks by granting the buyer a limited rehypothecation 
right. In this way, the proposed changes are designed to promote robust 
risk management; promote safety and soundness; reduce systemic risks; 
and support the stability of the broader financial system.
---------------------------------------------------------------------------

    \34\ 12 U.S.C. 5464(b)(1).
---------------------------------------------------------------------------

    Rule 17Ad-22(e)(7)(i) under the Exchange Act requires that OCC 
establish, implement, maintain and enforce written policies and 
procedures reasonably designed 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.\35\ As described above, the proposed 
change would allow OCC to implement the Bank Repo Facility, which would 
in turn help provide OCC with a readily available liquidity resource 
that would enable it to continue to meet its obligations in a timely 
manner and address OCC's liquidity demands under stressed or volatile 
market conditions. Accordingly, OCC believes that the proposal is 
consistent with Rule 17Ad-22(e)(7)(i).\36\
---------------------------------------------------------------------------

    \35\ 17 CFR 240.17ad-22(e)(7)(i).
    \36\ Id.
---------------------------------------------------------------------------

    Rule 17Ad-22(e)(7)(ii) under the Exchange Act requires OCC to 
establish, implement, maintain and enforce written policies and 
procedures reasonably designed to hold qualifying liquid resources 
sufficient to satisfy the minimum liquidity resource requirement under 
Rule 17Ad-22(e)(7)(i) in the currency for which OCC has payment 
obligations owed to Clearing Members.\37\ Rule 17Ad-22(a)(14) of the 
Act defines ``qualifying liquid resources'' to include, among other 
things, lines of credit without material adverse change provisions, 
which are readily available and convertible into cash.\38\ As described 
above the proposed change to the Bank Repo Facility would provide OCC 
with an additional committed liquidity resource, which would help 
ensure OCC has sufficient, readily available qualifying liquid 
resources to meet settlement obligations and its minimum liquidity 
resource requirements. Accordingly, OCC believes that the proposal is 
consistent with Rule 17Ad-22(e)(7)(ii).\39\
---------------------------------------------------------------------------

    \37\ 17 CFR 240.17ad-22(e)(7)(ii).
    \38\ 17 CFR 240.17ad-22(a) ``Qualifying liquid resources''.
    \39\ 17 CFR 240.17ad-22(e)(7)(ii).
---------------------------------------------------------------------------

    Rule 17Ad-22(e)(21) under the Exchange Act requires OCC to 
establish, implement, maintain and enforce written policies and 
procedures reasonably designed to be efficient and effective in meeting 
the requirements of its participants and the markets it serves and 
regularly review the efficiency and effectiveness of, among other 
things, its operating structure, including risk management policies, 
procedures and systems.\40\ OCC has, through its regular review of its 
liquidity funding arrangements and negotiations with the bank 
counterparty, identified an impediment to the implementation of an 
additional liquidity source that would further diversify OCC's 
liquidity funding resources. The current prohibition on rehypothecation 
has prevented execution of the facility on commercially acceptable 
terms. Removing this impediment would allow OCC to implement the 
facility for a greater amount and for a lower cost. Because OCC 
operates under a financial market utility model and principally funds 
its operations through the collection of clearing fees, such costs are 
ultimately borne by Clearing Members and, in turn, market participants. 
Establishing access to a facility as part of OCC's overall liquidity 
plan and diverse set of liquidity sources that is comparable or lower 
in cost to OCC's other liquidity facilities would help OCC manage its 
operations in an efficient and effective manner. Accordingly, OCC 
believes that the changes to the Bank Repo Facility are reasonably 
designed to manage OCC's liquidity risk in an efficient and effective 
manner, consistent with Rule 17Ad-22(e)(21)(ii).\41\
---------------------------------------------------------------------------

    \40\ 17 CFR 17ad-22(e)(21)(ii).
    \41\ Id.
---------------------------------------------------------------------------

    For the foregoing reasons, OCC believes that the proposed changes 
are consistent with Section 805(b)(1) of the Clearing Supervision Act 
\42\ and Rules 17Ad-22(e)(7) and (e)(21) under the Exchange Act.\43\
---------------------------------------------------------------------------

    \42\ 12 U.S.C. 5464(b)(1).
    \43\ 17 CFR 240.17ad-22(e)(7), (21).
---------------------------------------------------------------------------

III. Date of Effectiveness of the Advance Notice and Timing for 
Commission Action

    The proposed change may be implemented if the Commission does not 
object to the proposed change within 60 days of the later of (i) the 
date that the proposed change was filed with the Commission or (ii) the 
date that any additional information requested by the Commission is 
received. The clearing agency shall not implement the proposed change 
if the Commission has any objection to the proposed change.
    The Commission may extend period for review by an additional 60 
days if the proposed change raises novel or complex issues, subject to 
the Commission or the Board of Governors of the Federal Reserve System 
providing the clearing agency with prompt written notice of the 
extension. A proposed change may be implemented in less than 60 days 
from the date the advance notice is filed, or the date further 
information requested by the Commission is received, if the Commission 
notifies the clearing agency in writing that it does not object to the 
proposed change and authorizes the clearing agency to implement the 
proposed change on an earlier date, subject to any conditions imposed 
by the Commission. The clearing agency shall post notice on its website 
of proposed changes that are implemented.
    The proposal shall not take effect until all regulatory actions 
required with respect to the proposal are completed.

IV. Solicitation of Comments

    Interested persons are invited to submit written data, views and 
arguments concerning the foregoing, including whether the advance 
notice is consistent with the Act. Comments may be submitted by any of 
the following methods:

Electronic Comments

    <bullet> Use the Commission's internet comment form (<a href="http://www.sec.gov/rules/sro.shtml">http://www.sec.gov/rules/sro.shtml</a>); or
    <bullet> Send an email to <a href="/cdn-cgi/l/email-protection#e795928b82ca84888a8a82899394a7948284c9808891"><span class="__cf_email__" data-cfemail="2a585f464f07494547474f445e596a594f49044d455c">[email&#160;protected]</span></a>. Please include 
File Number SR-OCC-2025-801 on the subject line.

Paper Comments

    <bullet> Send paper comments in triplicate to Vanessa Countryman, 
Secretary, Securities and Exchange Commission,

[[Page 10738]]

100 F Street NE, Washington, DC 20549-1090.

All submissions should refer to File Number SR-OCC-2025-801. 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 (<a href="http://www.sec.gov/rules/sro.shtml">http://www.sec.gov/rules/sro.shtml</a>). 
Copies of the submission, all subsequent amendments, all written 
statements with respect to the advance notice that are filed with the 
Commission, and all written communications relating to the advance 
notice 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 10:00 a.m. and 
3:00 p.m. Copies of such filing also will be available for inspection 
and copying at the principal office of OCC and on OCC's website at 
<a href="https://www.theocc.com/Company-Information/Documents-and-Archives/By-Laws-and-Rules">https://www.theocc.com/Company-Information/Documents-and-Archives/By-Laws-and-Rules</a>.
    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-OCC-2025-801 and should 
be submitted on or before March 19, 2025.

    For the Commission, by the Division of Trading and Markets, 
pursuant to delegated authority.\44\
---------------------------------------------------------------------------

    \44\ 17 CFR 200.30-3(a)(12).
---------------------------------------------------------------------------

Sherry R. Haywood,
Assistant Secretary.
[FR Doc. 2025-03071 Filed 2-25-25; 8:45 am]
BILLING CODE 8011-01-P


</pre><script data-cfasync="false" src="/cdn-cgi/scripts/5c5dd728/cloudflare-static/email-decode.min.js"></script></body>
</html>
Indexed from Federal Register on February 26, 2025.

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.