[Federal Register Volume 85, Number 100 (Friday, May 22, 2020)]
[Notices]
[Pages 31235-31239]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-11122]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-88906; File No. SR-OCC-2020-803]
Self-Regulatory Organizations; The Options Clearing Corporation;
Notice of Filing of Advance Notice Concerning Changes to The Options
Clearing Corporation's Non-Bank Liquidity Facility Program as Part of
Its Overall Liquidity Plan
May 19, 2020.
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\ under the Securities Exchange Act of
1934 (``Exchange Act''),\3\ notice is hereby given that on April 15,
2020, the Options Clearing Corporation (``OCC'') 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 by OCC. The Commission is publishing this notice to solicit
comments on the advance notice from interested persons.
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\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.
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I. Clearing Agency's Statement of the Terms of Substance of the Advance
Notice
This advance notice is filed by The Options Clearing Corporation
(``OCC'') in connection with a proposed change to its operations to:
(i) Set the aggregate commitment amount that it may seek under its
program for accessing additional committed sources of liquidity that do
not increase the concentration of OCC's counterparty exposure (``Non-
Bank Liquidity Facility'') as part of OCC's overall liquidity plan and
(ii) allow more flexibility for OCC to negotiate the Non-Bank Liquidity
Facility's commitment term. 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\
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\4\ OCC's By-Laws and Rules can be found on OCC's public
website: http://optionsclearing.com/about/publications/bylaws.jsp.
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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 Notices Filed Pursuant to Section 806(e) of the Payment,
Clearing, and Settlement Supervision Act
Description of Change
This advance notice concerns a change to OCC's operations to: (i)
Set the aggregate commitment amount that it may seek under the Non-Bank
Liquidity Facility to up to $1 billion as part of OCC's overall
liquidity plan and (ii) allow more flexibility for OCC to negotiate the
Non-Bank Liquidity Facility's commitment term.
Background
OCC's current liquidity plan provides it with access to a diverse
set of funding sources, including banks (i.e., OCC's syndicated credit
facility \5\ and a master repurchase agreement with a bank counterparty
(``Repo Liquidity Facility'') \6\), the Non-Bank Liquidity Facility
program,\7\ and Clearing Members' Cash Clearing Fund Requirement.\8\
The Non-Bank Liquidity Facility program reduces the concentration of
OCC's counterparty exposure with respect to its overall liquidity plan
by diversifying its lender base among banks and non-bank, non-Clearing
Member institutional investors, such as pension funds or insurance
companies.
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\5\ See Exchange Act Release No. 85924 (May 23, 2019), 84 FR
25089 (May 30, 2019) (SR-OCC-2019-803).
\6\ See Exchange Act Release No. 88317 (March 4, 2020), 85 FR
13681 (March 9, 2020) (SR-OCC-2020-801).
\7\ See Exchange Act Release No. 73979 (Jan. 2, 2015), 80 FR
1062 (Jan. 8, 2015) (SR-OCC-2014-809) (``Notice of No Objection to
2014 Advance Notice''); Exchange Act Release No. 76821 (Jan. 4,
2016), 81 FR 3208 (Jan. 20, 2016) (SR-2015-805) (``Notice of No
Objection to 2015 Advance Notice'').
\8\ See OCC Rule 1002.
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The currently approved Non-Bank Liquidity Facility program is
comprised of two parts: A Master Repurchase Agreement (``MRA'') and
confirmations with one or more institutional investors, which contain
certain individualized terms and conditions of transactions executed
between OCC, the institutional investors and their agents. The MRA is
structured like a typical repurchase arrangement in which the buyer
(i.e., the institutional investor) would purchase from OCC, from time
to time, United States government securities (``Eligible
Securities'').\9\ OCC, as the seller, would transfer Eligible
Securities to the buyer in exchange for a payment by the buyer to OCC
in immediately available funds (``Purchase Price''). The buyer would
[[Page 31236]]
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 by OCC to the buyer in an amount equal to
the outstanding Purchase Price plus the accrued and unpaid price
differential (together, ``Repurchase Price''), which is the interest
component of the Repurchase Price.
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\9\ OCC would use U.S. government securities that are included
in Clearing Fund contributions by Clearing Members and margin
deposits of any Clearing Member that has been suspended by OCC for
the repurchase arrangements. OCC Rule 1006(f) and OCC Rule 1104(b)
authorize OCC to obtain funds from third parties through securities
repurchases using these sources. The officers who may exercise this
authority include the Executive Chairman, Chief Executive Officer,
and Chief Operating Officer.
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The confirmations establish tailored provisions of repurchase
transactions permitted under the Non-Bank Liquidity Facility that are
designed to reduce concentration risk and to promote certainty of
funding and operational effectiveness based on the specific needs of a
party. For example, OCC would only enter into confirmations with an
institutional investor that is not a Clearing Member or affiliated
bank, such as pension funds or insurance companies, in order to allow
OCC to access stable and reliable sources of funding without increasing
the concentration of its exposure to counterparties that are affiliated
banks, broker/dealers, or futures commission merchants. In addition,
any such institutional investor is obligated to enter repurchase
transactions even if OCC experiences a material adverse change,\10\
funds must be made available to OCC within 60 minutes of OCC's
delivering eligible securities, and the institutional investor is not
permitted to rehypothecate purchased securities.\11\ Additionally, the
confirmations set forth the term and maximum dollar amounts of the
transaction permitted under the MRA.\12\
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\10\ When included in a contract, a ``material adverse change''
is typically defined as a change that would have a materially
adverse effect on the business or financial condition of a company.
\11\ See Notice of No Objection to 2014 Advance Notice, 80 FR at
1064.
\12\ Because the arrangements between OCC and the individual
buyers have not been fully negotiated, OCC has summarized the
indicative terms in Exhibit 3a to File No. SR-OCC-2020-803. Exhibit
3a shows the terms indicated in prior advance notices, as modified
by the proposed changes in this advance notice. The exhibit is a
non-public document for which OCC has submitted a request for
confidential treatment to the Commission.
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In 2019, the Non-Bank Liquidity Facility counterparty decided not
to renew its commitments, and two confirmations totaling $1 billion
(``Prior Confirmations'') expired on January 2, 2020 and January 6,
2020. In anticipation of the expiration of the Prior Confirmations and
to prevent a drop in OCC's overall liquidity resources, OCC (i)
exercised an accordion feature under its syndicated credit facility to
increase the amount from $2 billion to $2.5 billion, and (ii) exercised
authority under OCC Rule 1002 to temporarily increase the size of the
Cash Clearing Fund Requirement from $3 billion to $3.5 billion.\13\
After obtaining regulatory approval, OCC also executed the Repo
Liquidity Facility with a bank counterparty for $500 million.\14\
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\13\ After reviewing that temporary increase in accordance with
Rule 1002, the Risk Committee determined to maintain the increase,
which was already contemplated as part of a proposed rule change
that OCC has since filed with the Commission. See File No. SR-OCC-
2020-003. The proposed rule change would, among other things, modify
Rule 1002 to allow OCC to periodically set the Clearing Fund Cash
Requirement based on an analysis of OCC's projected liquidity
demands under a variety of stressed scenarios. Subject to regulatory
approval of that filing, the Risk Committee would initially reset
the Clearing Fund Cash Requirement to $3.5 billion based on an
analysis of stress test results demonstrating that this amount, in
combination with OCC's current and anticipated committed liquidity
facilities--a $2 billion syndicated credit facility and $1 billion
in other committed liquidity facilities (i.e., the Repo Liquidity
Facility and/or the Non-Bank Liquidity Facility)--would be
sufficient to cover OCC's liquidity risk tolerance of 1-in-50 year
statistical market event at a 99.5% level over a two-year look back
period.
\14\ After the Repo Liquidity Facility became effective, OCC
terminated the $500 million accordion on the syndicated credit
facility.
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Since learning that the Prior Commitments would not be renewed, OCC
has also been working with a lending agent to identify interested
institutional investors to secure replacement Commitments for the $1
billion in Prior Confirmations. The purpose of this filing is to modify
certain aspects of the Non-Bank Liquidity Facility program to give OCC
the flexibly to seek confirmations up to $1 billion in the aggregate
with such durations as approved by its Board of Directors (``Board'').
Aggregate Commitment Amount OCC May Seek Under the Confirmations
OCC is proposing to adjust the aggregate amount it can seek through
the Non-Bank Liquidity Facility program to an amount up to $1 billion,
as opposed to no less than $1 billion and no greater than $1.5
billion--allowing OCC the ability to seek commitments even if the
aggregate commitment level falls below $1 billon. The Non-Bank
Liquidity Facility program, as initially proposed, authorized
commitments of $1 billion in the aggregate.\15\ In 2015, OCC filed an
advance notice to modify the Non-Bank Liquidity Facility program to
allow OCC to seek aggregate commitments of no less than $1 billion and
no greater than $1.5 billion (the ``2015 Advance Notice'').\16\ The
increase to the permissible range was made as part of OCC's plan to
transition from a single $1 billion confirmation to two confirmations
of $500 million with staggered expiration dates.\17\ While the current
Non-Bank Liquidity Facility program gives OCC discretion to seek
aggregate commitments of no more than $1.5 billion, OCC's Board has
consistently authorized OCC to seek commitments up to an aggregate
amount of $1 billion since 2016. OCC is proposing to modify the Non-
Bank Liquidity Facility program to align the program's terms with the
commitment level approved by the Board.
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\15\ Notice of No Objection to 2014 Advance Notice, 80 FR at
1064 & n.11.
\16\ Notice of No Objection to 2015 Advance Notice, 81 FR at
3208.
\17\ See id. at 3209 (discussing the extension of the existing
confirmation and the execution of a second confirmation).
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OCC's ability to secure or renew commitments under the Non-Bank
Liquidity Facility is subject to market conditions, among other factors
outside of OCC's control. As evidenced by the recent expiration of the
Prior Confirmations, a counterparty's decision not to renew its
commitment under the facility may cause the aggregate commitment amount
to fall below $1 billion. As part of OCC's overall liquidity plan,
however, OCC maintains access to a diverse set of funding sources in
addition to the Non-Bank Liquidity Facility. To address the expiration
of a Non-Bank Liquidity Facility commitment, OCC would have several
options, including (i) execution of one of more commitments under the
Non-Bank Liquidity Facility up to the $1 billion aggregate commitment
amount proposed, (ii) exercising the accordion feature under the
syndicated credit facility, (iii) exercising authority under OCC Rule
1002 to temporarily increase the Cash Clearing Fund Requirement, and
(iv) filing an advance notice to execute a master repurchase agreement
with other counterparties, similar to the Repo Liquidity Facility.
Allowing OCC to seek one or more Non-Bank Liquidity Facility
commitments that, in the aggregate, are less than $1.0 billion would
allow OCC the flexibility to adjust the mix of liquidity resources
based on market conditions, availability and shifting liquidity needs.
If OCC is unable to secure commitments to replace existing
confirmations, OCC would reallocate shortfalls to other liquidity
resources to prevent a drop in total liquidity resources.
Without this change, OCC arguably could not execute individual
commitments that result in an aggregated commitment of less than $1
[[Page 31237]]
billion at the time executed, making it difficult or impossible for OCC
to negotiate individual commitments, each less than $1 billion, with
multiple counterparties that may be proceeding on different timelines.
In addition, allowing OCC to execute confirmations at different times
would have the benefit of staggering expiration dates--to the extent
such confirmations are for fixed terms--mitigating the risk that
overlapping expirations may cause a drop in OCC's overall liquidity
resources.
Confirmation Term
OCC is also proposing to modify the confirmation term to allow more
flexibility in negotiating terms with institutional investors.
Confirmations under the current Non-Bank Liquidity Facility program are
limited to a commitment term greater than or equal to 364-days. Based
on ongoing negotiations with potential institutional investors, OCC
believes there is interest for commitments that are shorter than one
year.\18\ OCC is proposing to adjust the required terms and conditions
as filed with the Commission in the 2015 Advance Notice filing to allow
for a commitment term of less than 364 days, as negotiated by the
parties and approved by OCC's Board. The proposed modification to the
program would allow for, among other things, a confirmation with a
shorter commitment term as well as an open-ended term that allows for
termination subject to a notice period. Providing flexibility in the
commitment term may make the Non-Bank Liquidity Facility more
commercially attractive to institutional investors who desire more
flexibility in the confirmation term. Additionally, termination subject
to notice would benefit OCC by ensuring that OCC will have a pre-set
notice period to manage its liquidity resources to replace an expiring
confirmation or adjust the levels of other liquidity resources.
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\18\ OCC included information about the current status of
negotiations with potential counterparties in Exhibit 3b to File No.
SR-OCC-2020-803. The exhibit is a non-public document for which OCC
has submitted a request for confidential treatment to the
Commission.
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The Board reviews proposed terms under the Non-Bank Liquidity
Program and authorizes Management to enter into and renew transactions
upon expiration. The length of term or notice period OCC would be
willing to accept would be conditioned on factors including, but not
limited to, the initial committed length of the term, market conditions
and OCC's liquidity needs. For a confirmation without a defined
commitment term, OCC would target to negotiate a six-month notice
period. Based on the expiration of the Prior Confirmations, OCC
believes that six-months' notice is sufficient time to allow OCC to
reallocate liquidity resources to address a confirmation's termination.
Because of the time and cost required to negotiate and close
transactions, OCC believes it unlikely that it would pursue a
commitment of less than three months.
Anticipated Effect On and Management of Risk
Completing timely settlement is a key aspect of OCC's role as a
clearing agency performing central counterparty services. Modifying the
Non-Bank Liquidity Facility program to provide OCC more flexibility in
seeking confirmations would continue to promote the reduction of risks
to OCC, its Clearing Members and the options market in general because
it would allow OCC to continue to obtain short-term funds from the Non-
Bank Liquidity Facility to address liquidity demands arising out of the
default or suspension of a Clearing Member, in anticipation of a
potential default or suspension of Clearing Members, the insolvency of
a bank or another securities or commodities clearing organization, or
the failure of a bank or another securities or commodities clearing
organization to achieve daily settlement.
The Non-Bank Liquidity Facility helps OCC minimize losses in the
event of a default, suspension, insolvency, or failure to achieve daily
settlement, by allowing it to obtain funds from sources not connected
to OCC's Clearing Members on extremely short notice to ensure clearance
and settlement of transactions in options and other contracts without
interruption. OCC believes that the reduced settlement risk presented
by OCC resulting from the proposed change would correspondingly reduce
systemic risk and promote the safety and soundness of the clearing
system. The ability to borrow funds from the Non-Bank Liquidity
Facility would allow OCC to avoid liquidating margin or clearing fund
assets in what would likely be volatile market conditions, which would
preserve funds available to cover any losses resulting from the failure
of a Clearing Member, bank or other clearing organization.
The proposed change to allow OCC to seek an aggregate commitment
amount under the Non-Bank Liquidity Facility for up to the currently
approved limit would help OCC ensure the continued availability of its
liquidity resources by providing OCC with the flexibility to seek
additional funding amounts at substantially the same terms, conditions,
operations, and mechanics of the Prior Confirmations. Furthermore,
allowing for OCC to negotiate a term less than 364-days would allow OCC
more flexibility in negotiating confirmations with institutional
investors, and would allow OCC the ability to negotiate terms that give
OCC more time to respond to an institutional investor's decision not to
renew a confirmation. Such flexibility would allow OCC to reallocate
the amount of funding available under the confirmations at the time of
a confirmation's renewal or termination and to manage liquidity needs
and enhance its ability to ensure continual liquidity resources.
Because the proposed change preserves substantially the same terms
and conditions as the MRA and the Prior Confirmation, OCC believes that
the proposed change would not otherwise affect or alter the management
of risk at OCC.
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.\19\
Section 805(a)(2) of the Clearing Supervision Act \20\ 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 \21\ states that the objectives
and principles for risk management standards prescribed under Section
805(a) shall be to:
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\19\ 12 U.S.C. 5461(b).
\20\ 12 U.S.C. 5464(a)(2).
\21\ 12 U.S.C. 5464(b).
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Promote robust risk management;
promote safety and soundness;
reduce systemic risks; and
support the stability of the broader financial system.
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.\22\
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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.\23\ Therefore, the Commission has stated \24\ 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.\25\
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\22\ 17 CFR 240.17Ad-22. See Exchange Act Release Nos. 68080
(October 22, 2012), 77 FR 66220 (November 2, 2012) (S7-08-11)
(``Clearing Agency Standards''); 78961 (September 28, 2016), 81 FR
70786 (October 13, 2016) (S7-03-14) (``Standards for Covered
Clearing Agencies'').
\23\ 17 CFR 240.17Ad-22.
\24\ See, e.g., Exchange Act Release No. 86182 (June 24, 2019),
84 FR 31128, 31129 (June 28, 2019) (SR-OCC-2019-803).
\25\ 12 U.S.C. 5464(b).
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OCC believes that the Non-Bank Liquidity Facility program, as
modified, is consistent with Section 805(b)(1) of the Clearing
Supervision Act \26\ because the proposed confirmations would provide
OCC with an additional source of committed liquidity to meet its
settlement obligations while at the same time being structured to
mitigate certain operational risks, as described above, that arise in
connection with this committed liquidity source. 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.
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\26\ 12 U.S.C. 5464(b)(1).
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OCC believes that the Non-Bank Liquidity Facility program, as
modified, is also consistent with the requirements of Rule 17Ad-
22(e)(7) under the Exchange Act.\27\ Rule 17Ad-22(e)(7) requires OCC to
establish, implement, maintain and enforce written policies and
procedures reasonably designed to effectively measure, monitor, and
manage liquidity risk that arises in or is borne by OCC, including
measuring, monitoring, and managing its settlement and funding flows on
an ongoing and timely basis, and its use of intraday liquidity, as
specified in the rule.\28\ In particular, Rule 17Ad-22(e)(7)(i) under
the Exchange Act \29\ directs that OCC meet this obligation by, among
other things, ``[m]aintaining sufficient liquid resources at the
minimum in all relevant currencies to effect same-day . . . 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 [OCC] in extreme but plausible
market conditions.''
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\27\ 17 CFR 240.17Ad-22(e)(7).
\28\ Id.
\29\ 17 CFR 240.17Ad-22(e)(7)(i).
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As described above, the proposed change would allow OCC to seek a
readily available liquidity resource that would enable it to, among
other things, continue to meet its obligations in a timely fashion and
as an alternative to selling Clearing Member collateral under what may
be stressed and volatile market conditions. For these reasons, OCC
believes that the proposal is consistent with Rule 17Ad-
22(e)(7)(i).\30\
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\30\ Id.
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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 payment obligations owed to Clearing Members.\31\
Rule 17Ad-22(a)(14) of the Exchange Act defines ``qualifying liquid
resources'' to include, among other things, lines of credit without
material adverse change provisions, that are readily available and
convertible into cash.\32\ The MRA under the Non-Bank Liquidity
Facility would not be subject to any material adverse change provision
and would continue to be designed to permit OCC to, among other things,
help ensure that OCC has sufficient, readily-available qualifying
liquid resources to meet the cash settlement obligations of its largest
Clearing Member Group. Therefore, OCC believes that the proposal is
consistent with Rule 17Ad-22(e)(7)(ii).\33\
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\31\ 17 CFR 240.17Ad-22(e)(7)(ii).
\32\ 17 CFR 240.17Ad-22(a)(14).
\33\ 17 CFR 240.17Ad-22(e)(7)(ii).
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For the foregoing reasons, OCC believes that the proposed changes
are consistent with Section 805(b)(1) of the Clearing Supervision Act
\34\ and Rule 17Ad-22(e)(7) \35\ under the Exchange Act.
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\34\ 12 U.S.C. 5464(b)(1).
\35\ 17 CFR 240.17Ad-22(e)(7).
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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 the proposed change was filed with the Commission or (ii) the date
any additional information requested by the Commission is received. OCC
shall not implement the proposed change if the Commission has any
objection to the proposed change.
The Commission may extend the period for review by an additional 60
days if the proposed change raises novel or complex issues, subject to
the Commission 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.
OCC 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 Clearing Supervision Act. Comments may be
submitted by any of the following methods:
Electronic Comments
Use the Commission's internet comment form (http://www.sec.gov/rules/sro.shtml); or
Send an email to [email protected]. Please include
File Number SR-OCC-2020-803 on the subject line.
Paper Comments
Send paper comments in triplicate to Secretary, Securities
and Exchange Commission, 100 F Street NE, Washington, DC 20549.
All submissions should refer to File Number SR-OCC-2020-803. 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 (http://www.sec.gov/rules/sro.shtml).
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
[[Page 31239]]
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 the filing also will be available
for inspection and copying at the principal office of the self-
regulatory organization.
All comments received will be posted without change. Persons
submitting comments are cautioned that we do not redact or edit
personal identifying information from comment submissions. You should
submit only information that you wish to make available publicly.
All submissions should refer to File Number SR-OCC-2020-803 and
should be submitted on or before June 8, 2020.
By the Commission.
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020-11122 Filed 5-21-20; 8:45 am]
BILLING CODE 8011-01-P