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Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934 (“Act”), and Rule 19b-4 thereunder, notice is hereby given that on October 23, 2024, Banque Centrale de Compensation, which conducts business under the name LCH SA (“LCH SA”), filed with the Securities and Exchange Commission (“Commission”) the proposed rule change (“Proposed Rule Change”) described in Items I, II and III below, which Items have been primarily prepared by LCH SA. LCH SA filed the proposed rule change pursuant to Section 19(b)(3)(A) of the Act, and Rule 19b-4(f)(2) thereunder, so that the proposal was effective upon filing with the Commission. The Commission is publishing this notice to solicit comments on the Proposed Rule Change from interested persons.
I. Clearing Agency's Statement of the Terms of Substance of the Proposed Rule Change
LCH SA is proposing to amend the fees it charges clearing members for cash and securities collateral posted as initial margin for its clearing services including CDSClear (the “Proposed Rule Change”).
The text of the Proposed Rule Change has been annexed as Exhibit 5 to File No. SR-LCH SA-2024-004. The implementation of the Proposed Rule Change will be contingent on LCH SA's receipt of all necessary regulatory approvals.
All capitalized terms not defined herein have the same definition as in the CDS Clearing Rule Book available at https://www.lch.com/system/files/media_root/CDSClear_Rule_Book_01.02.2024.pdf.
II. Clearing Agency's Statement of the Purpose of, and Statutory Basis for, the Proposed Rule Change
In its filing with the Commission, LCH SA included statements concerning the purpose of and basis for the Proposed Rule Change and discussed any comments it received on the Proposed Rule Change. The text of these statements may be examined at the places specified in Item IV below. LCH SA has prepared summaries, set forth in sections A, B, and C below, of the most significant aspects of such statements.
A. Clearing Agency's Statement of the Purpose of, and Statutory Basis for, the Proposed Rule Change
1. Purpose
LCH SA currently applies a spread for clearing member cash collateral and charges fees on securities collateral posted to cover initial margin requirements for its CDSClear business. Cash collateral spreads are primarily based on underlying market conditions for a given currency and are subtracted from a reference index to determine a total rate to be applied to CDSClear house and client accounts. Securities collateral fees are primarily based on a combination of factors, including, but not limited to operational costs to manage a specific non-cash collateral type, the liquidation profile and subsequent impact on LCH SA's liquidity coverage ratio of the securities collateral and commercial considerations such as competitive landscape. The securities collateral fees charged to clearing members varies based on the instrument type ( e.g., government securities), whether the securities collateral is posted on behalf of the CDSClear house account or on behalf of CDSClear clients and the method of posting the collateral ( i.e., full title transfer, pledge or tri-party). The purpose of the Proposed Rule Change is for LCH SA to amend the cash spreads and securities collateral fees for margin collateral posted by clearing members.
i. Changes to Cash Collateral Spreads
LCH SA currently accepts euro, GBP and USD cash to satisfy initial margin requirements for its CDSClear business. Clearing members that post these eligible currencies as margin may receive interest on these balances based on an associated benchmark index and cash collateral spreads applied by LCH SA. The total rate that clearing members and their clients may be eligible for is the difference between the value of the underlying benchmark index and the spreads applied by LCH SA. Interest earned on cash collateral is based on daily balances by account and posted monthly to clearing member accounts.
LCH SA currently applies the following cash collateral spreads for CDSClear house and client accounts:
Currency | Unsecured overnight index | Cash collateral fee/spread (bps) | ||
---|---|---|---|---|
All markets | CDSClear clients | Default funds | ||
EUR | €STR | 21.5 | 6.5 | 11.5 |
GBP | SONIA | 35 | 20 | |
USD | FEDFUND | 30 | 15 |
Securities | House | Client | |||
---|---|---|---|---|---|
Full title transfer | Pledge | Triparty | CDSClear clients | ||
Government Securities | Australia | 13 | NA | NA | 10 |
Austria | 11 | 15 | 9.5 | 10 | |
Belgium | 11 | 15 | 9.5 | 10 | |
Canada | 13 | NA | NA | 10 | |
Denmark | 13 | NA | NA | 10 | |
Finland | 11 | 15 | 9.5 | 10 | |
France | 11 | 15 | 9.5 | 10 | |
Germany | 11 | 15 | 9.5 | 10 | |
Italy | 11 | 15 | 9.5 | 10 | |
Japan | 13 | NA | NA | 10 | |
Netherlands | 11 | 15 | 9.5 | 10 | |
Norway | 13 | NA | NA | 10 | |
Portugal | 11 | NA | 9.5 | 10 | |
Spain | 11 | 15 | 9.5 | 10 | |
Sweden | 13 | NA | NA | 10 | |
Switzerland | 13 | NA | NA | 10 | |
UK | 11 | 15 | NA | 10 | |
USA | 11 | 15 | NA | 10 | |
Supranationals | European Financial Stability Facility | 13 | 15 | 11.5 | 10 |
European Stability Mechanism | 13 | 15 | 11.5 | 10 | |
European Investment Bank | 13 | 15 | 11.5 | 10 | |
European Union | 13 | 15 | 11.5 | 10 | |
Investment Bank for Reconstruction and Development | 13 | 15 | 11.5 | 10 | |
Agencies | Rentenbank | 13 | 15 | 11.5 | 10 |
Kreditanstalt für Wiederaufbau | 13 | 15 | 11.5 | 10 | |
CADES | 13 | 15 | NA | 10 | |
Equities | All (as listed in Haircut Schedule) | 13 | NA | NA | NA |