SEC Finalizes Capital, Margin and Segregation Requirements

Shearman & Sterling LLP

As a further step towards the implementation of its security-based swap regime, the Securities and Exchange Commission (SEC) has adopted a number of long-awaited capital, margin and segregation requirements for security-based swap dealers (SBSDs) and major security-based swap participants (MSBSPs).[1] The SEC has also provided alternative procedures under which certain swap dealers registered with the Commodity Futures Trading Commission (CFTC) and foreign SBSDs and MSBSPs can request substituted compliance from the SEC with respect to the requirements.

The final rules were adopted in accordance with Title VII of the Dodd-Frank Wall Street Reform and Protection Act, which established a framework for the regulation of swaps and security-based swaps, among other things. The SEC’s final rules differ in significant respects from the requirements applicable to swap dealers under CFTC rules[2] and rules adopted by the prudential regulators.[3] Although they have been finalized, the requirements will not come into effect until the registration compliance date for SBSDs and MSBSPs, which is not expected to occur for at least another 18 months (for further details please see “SEC moves closer to registration of security-based swap entities”).

The SEC’s regulations apply to SBSDs and MSBSPs that do not have a prudential regulator (i.e., SBSDs that are not banks or bank holding companies). SBSDs and MSBSPs that have a prudential regulator are subject to the capital and margin regulations of that regulator and not the SEC’s regulations. SBSDs and MSBSPs subject to the SEC’s rules include both registered securities broker-dealers that are also SBSDs and so-called ‘stand-alone’ non-bank SBSDs.[4]

Capital Requirements

The final rules establish capital requirements for non-bank SBSDs and MSBSPs through amendments to SEC Rule 15c3-1 (for broker-dealer SBSDs) and the adoption of SEC Rules 18a-1 and 18a-2 (for stand-alone SBSDs and MSBSPs). Certain amendments to the capital requirements for non-SBSD broker-dealers apply to the extent that they engage in security-based swap and swap activity.

As with current broker-dealer capital requirements, non-bank SBSDs (both broker-dealer and stand-alone) may obtain approval to calculate their capital using internal models or using a standard approach set out in the rule.

In general, net capital under the SEC’s rules will be the greater of a fixed-dollar amount or an amount calculated using a financial ratio reflecting a percentage of the entity’s exposures to its security-based swap customers (the ‘margin factor’). The margin factor will initially be 2% of the relevant exposure, but after three years following implementation, the margin factor may be subject to increase by the SEC (up to a 4% level after three years and up to an 8% level after five years).

The following table outlines the minimum net capital requirements applicable to non-bank SBSDs:

TYPE OF REGISTRANT

RULE

TENTATIVE NET CAPITAL

(NET CAPITAL BEFORE HAIRCUTS)

NET CAPITAL (GREATER OF)

FIXED DOLLAR

FINANCIAL RATIO

Stand-alone SBSD (not using internal models)

18a-1

N/A

$20 million

2% margin factor

Stand-alone SBSD (using internal models)[5]

18a-1

$100 million

$20 million

2% margin factor

Broker-dealer SBSD (not using internal models)

15c3-1

N/A

$20 million

2% margin factor plus Rule 15c3-1 ratio

Broker-dealer SBSD (using internal models)

15c3-1

$5 billion

$1 billion

2% margin factor plus Rule 15c3-1 ratio

Non-bank SBSDs authorized to use models to compute net capital are subject to higher, tentative net capital requirements (determined before the application of relevant haircuts). Non-bank SBSDs and broker-dealers will also be required to implement standardized haircuts to proprietary positions if they are not approved to use model-based haircuts.

For broker-dealer SBSDs using internal models, a 10% portfolio concentration charge would also apply. In addition, all non-bank SBSDs would be subject to a concentration charge for large exposures to a single counterparty, determined using the existing methodology for broker-dealers in Rule 15c3-1e.

Stand-alone MSBSPs would be subject to a separate requirement to maintain a positive tangible net worth, in lieu of the SBSD capital requirements.

Non-bank SBSDs and MSBSPs must also comply with Rule 15c3-4, which will require them to establish internal risk management control requirements.

Margin Requirements

The final rules establish initial margin (IM) and variation margin (VM) requirements applicable to non-bank SBSDs and MSBSPs in respect of uncleared security-based swaps.

Under the final rules, non-bank SBSDs are required to post VM (and not IM) to their counterparties, although they are permitted (but not required) to post IM as well. However, they are required to collect both IM and VM from certain counterparties. This marks a significant difference in approach from that of the CFTC and the prudential regulator margin rules.

Collateral to meet margin requirements under the SEC rules must consist of cash, securities, money market instruments, a major foreign currency, the settlement currency of the uncleared security-based swap or gold. Standardized haircuts under the SEC’s net capital rules or the CFTC’s margin rules (if applied consistently with respect to a particular counterparty) must be applied when valuing such collateral.

Non-bank SBSDs are permitted to use either a standardized approach or an industry standard model (pending SEC approval, which the SEC believes will generally be sought) to calculate IM.[6] The final rules also provide non-bank SBSDs with provisional approval of IM models that have been approved by other federal regulators.There are a number of exceptions to the margin collection and posting requirements for SBSDs under the final rules, which are detailed in the following table.

EXCEPTION

EXCEPTIONS TO COLLECTING MARGIN

EXCEPTIONS TO DELIVERING VM

VM

IM

Commercial end user

Need not collect

Need not collect

Need not deliver

Bank for international settlements or European stability mechanism

Need not collect

Need not collect

Need not deliver

Multilateral development bank

Need not collect

Need not collect

Need not deliver

Financial Market Intermediary[7]

Must collect

Need not collect

Must deliver

Affiliate

Must collect

Need not collect

Must deliver

Sovereign with minimal credit risk

Must collect

Need not collect

Must deliver

Legacy account

Need not collect

Need not collect

Need not deliver

IM below $50 million threshold

Must collect

Need not collect

Must deliver

$500,000 minimum transfer amount

Need not collect

Need not collect

Need not deliver

SBSDs dealing with security-based swap market participants, such as investment companies, insurance companies, pension funds and private hedge funds that do not fall under one of the above-listed exceptions, however, would be subject to the requirements of the rules.

Under the final rules, non-bank MSBSPs are also required to collect and deliver VM, subject to certain exceptions, but are not obligated to collect or deliver IM.

The SEC rules contain some key differences from the comparable CFTC and prudential regulator rules. The SEC rules: (i) provide an exception from IM collection from Financial Market Intermediaries which is not provided under the CFTC and prudential regulator rules; (ii) do not require SBSDs to post IM; (iii) provide an exception from IM collection from central governments that the SBSD has determined have a minimal amount of credit risk, while the CFTC and prudential rules provide the exception to all central governments; and (iv) provide an exception from IM collection from affiliates, while under the CFTC and prudential regulator rules this exception is subject to certain conditions (though the prudential regulators have recently proposed amendments to repeal the requirement that affiliates post IM).

Segregation Requirements

The final rules also establish segregation requirements for both cleared and uncleared security-based swaps for SBSDs and broker-dealers. Such requirements generally contemplate that an SBSD or broker-dealer must segregate money, securities and property of security-based swap customers; however, the assets may be commingled with money, securities or property of other such customers (omnibus segregation).

This omnibus segregation approach is required for customer property received in connection with cleared security-based swaps. Such property may be commingled in a single or multiple accounts with any bank, trust company or clearing agency.

Customers are not permitted to waive segregation in respect of money, securities or other property held by an SBSD or broker-dealer relating to a cleared security-based swap.

In the context of uncleared security-based swaps, omnibus segregation requirements are an alternative to existing statutory provisions allowing a counterparty to elect to have initial margin individually segregated or to waive segregation.

Under such requirements, an SBSD or broker-dealer must maintain:

  • possession or control over excess securities collateral (i.e., collateral not being used to meet a counterparty VM requirement), subject to certain exceptions for meeting clearing house margin requirements for cleared security-based swaps and for certain hedging transactions by the SBSD for uncleared security-based swaps; and
  • a security-based swap customer reserve account to segregate cash and qualified securities in an amount equal to the net cash owed to the security-based swap customers, computed weekly.

A non-broker-dealer SBSD can be exempt from the omnibus segregation requirements if such an entity does not clear security-based swap transactions for other persons and provides certain disclosures to their customers about the absence of segregation, among other conditions.

Alternative and Substituted Compliance

The final rules provide an alternative compliance mechanism for stand-alone, non-broker-dealer SBSDs that are registered as swap dealers with the CFTC and predominately engage in a swaps business.[8] Under the final rules, such entities may elect to comply with the capital, margin and segregation requirements of the Commodity Exchange Act and other CFTC rules in lieu of the SEC’s final rules if they meet certain conditions.

The final rules also implement a substituted compliance mechanism in respect of capital and margin requirements for foreign SBSDs and MSBSPs that will apply if the SEC determines that such entities are subject to comparable regulation in their home country. However, the SEC has determined that segregation requirements are not eligible for substituted compliance as these are deemed transaction-level requirements.

Comment

The SEC’s final rules address one of the key remaining questions required to implement the security-based swap regime: which capital and margin requirements will apply to non-bank dealers? The approach differs in important respects from the requirements for bank SBSDs and for swap dealers regulated by the CFTC. Market participants will need to consider those differences in structuring their security-based swap businesses, and the differences may complicate the process of implementing the SEC’s rules for institutions that are active in both swaps and security-based swaps.

In addition, it is likely to be some time before these rules take effect. While the rules became effective on October 21, 2019, the compliance date for the final rules will be 18 months from the effective date of final rules addressing the cross-border application of certain security-based swap requirements (which is the last remaining key security-based swap rulemaking).

Therefore, it will likely be well into 2021 before the final rules are operative for market participants.

Footnotes

[1] Capital, Margin, and Segregation Requirements for Security-Based Swap Dealers and Major Security-Based Swap Participants and Capital and Segregation Requirements for Broker-Dealers, SEC Rel 34-86175 (21 June 2019), available here.

[2] 17 CFR 23 and 140.

[3] 12 CFR 45, 237, 349, 624 and 1221. The prudential regulators are the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Farm Credit Administration and the Federal Housing Finance Agency.

[4] The SEC rules generally treat over-the-counter (OTC) derivatives dealers (so-called ‘broker-dealer lites’) that are SBSDs as stand-alone SBSDs, rather than broker-dealer SBSDs.

[5] Includes stand-alone SBSDs that are also OTC derivatives dealers.

[6] Broker-dealer SBSDs must use standardized haircuts to calculate IM for equity security-based swaps, while stand-alone SBSDs may use an industry model to calculate IM for uncleared equity security-based swaps, provided that the account of the counterparty does not hold equity security positions other than equity security-based swaps (and potentially equity swaps).

[7] The SEC lists examples of Financial Market Intermediaries as swap dealers, SBSDs, broker-dealers, futures commission merchants, banks, foreign broker-dealers and foreign banks.

[8] Meaning the aggregate gross notional amount of the firm’s security-based swap positions must not exceed the lesser of a maximum fixed-dollar amount or 10% of the combined aggregate gross notional amount of the firm’s security-based swap and swap positions.

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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