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Home Source documents Exhibit 35 (Dkt. 568-35)

Exhibit 35 (Dkt. 568-35, S.D. Fla.)

Summary

Exhibit 35 (Document 568-35) in Case 1:21-md-02989-CMA, entered on the FLSD docket June 8, 2023, is a 27-page printout, made 1/29/2021 from the DTCC portal and stamped RHMDL00011594 to RHMDL00011619, of the DTCC NSCC Risk Margin Component Guide with a publication date of July 10, 2020. An important notice states that the guide is for informational purposes only and that the NSCC Rules govern in any discrepancy. The guide describes the components of a Member's Required Deposit, including a volatility component designed to capture market price risk at a 99th percentile level of confidence through a parametric Value-at-Risk model, which usually comprises the largest portion, and states that NSCC may impose a premium charge when a Member's Required Fund Deposit exceeds its excess net capital.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Date
2023-06-08

Cite this document

“Exhibit 35 (Dkt. 568-35).” Original at archive.org, dated 2023-06-08. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-06-08-covid-era-misc-0def7bb5-1/, SHA-256 0def7bb5110a104faff9ff29c91b6344b421db64ea1d8015c19113f9b9f5189b.

Full text

Case 1:21-md-02989-CMA Document 568-35 Entered on FLSD Docket 06/08/2023 Page 1 of
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                              Exhibit 35
1/29/2021
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                  DTCC




                          NSCC RISK MARGIN COMPONENT GUIDE
                                                      PUBLICATION DATE: JULY 10, 2020




                                                                 Important Notice

                    This document and the information described herein is provided as a convenience to NSCC
                   Members and is for informational purposes only. This document should not be regarded as a
                   definitive or exhaustive description of NSCC's dearing fund methodology or risk-management
                     framework; nor should it be regarded as a substitute for the NSCC Rules and Procedures
                     ("Rules"), Vvhich governs in all respects the relationship between NSCC and its Members.
                  Members should refer to the NSCC Rules for a complete statement of NSCC procedures, rights,
                                                    obligations, and requirements.

                    Notwithstanding anything stated herein, NSCC retains all discretion and rights set forth in the
                    NSCC Rules. Nothing in this document shall be deemed to impose any obligations on NSCC
                     that are not set forth in the NSCC Rules, and in the case of any discrepancy between this
                                   document and the NSCC Rules, the NSCC Rules shall govern.

                     This document may be amended at any time without prior notice and the risk-management
                      practices described herein may be changed at any time without update to this document.




                                                 ADVANCING FINANCIAL MARKETS. TOGETHER-'



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                                                                                                                      RHMDL00011594
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                                                                           Table of Contents

                  Introduction ................................................................................................................................ 3
                  1      Volatility Component ........................................................................................................... 3
                      1.1 Overview of Methodology ............................................................................................... 3
                      1.2 In-Scope Products and Process ..................................................................................... 3
                         1.2.1      Equity Margining ..................................................................................................... 4
                        1.2.2       Fixed Income Margining .......................................................................................... 4
                      1.3    Equity Volatility Component Calculations........................................................................ 4
                        1.3.1       VaR Charge ............................................................................................................ 4
                        1.3.2       Illiquid Equity and IPO Haircut Volatility Charge ...................................................... 9
                      1.4 Fixed Income Volatility Component Calcullations ........................................................... 10
                        1.4.1       Calculation Methodology for Corporate Bonds .......................................................10
                        1.4.2       Calculation Methodology for Municipal Bonds ........................................................10
                        1.4.3       Calculation Methodology for Other Fixed Income Securities .................................. 11
                      1.5 Family-Issued Securities Volatility Component Calculation ............................................ 11
                  2      Mark to Market Component........................... ..................................................................... 12
                        2.1.1       Start of Day Mark to Market Charge ....................................................................... 12
                        2.1.2       lntraday Mark to Market Charge ...... . ..................................................................... 12
                  3      Special Charge ................................................................................................................... 12
                  4     CNS Fails Charge Component............................................................................................ 12
                  5      Margin Requirement Differential ("MRD") Component ........................................................ 13
                  6     Coverage Component ("CC") Charge ........... ..................................................................... 14
                  7      Illiquid Charge Component ................................................................................................ 16
                  8     Other Transactions Charge ................................................................................................. 17
                  9     Mutual Fund Transactions Charge ..................................................................................... 17
                  10     Excess Capital Premium ("CF Premium") Charge ..............................................................17
                  11     Backtesting Charge ........................................................................................................... 18
                  12 Bank Holiday Charge ......................................................................................................... 19
                  13 Appendices ........................................................................................................................19




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                  Introduction

                  On a daily basis NSCC calculates a Clearing Fund requirement for each Member based upon
                  their unsettled and pending transactions, using the prior day's securities closing market price.
                  The formula uses a risk-based methodology and includes a number of components.
                  Some of these components are described in this document, including the volatility charges, mark­
                  to-market charges, fail charges (for CNS transactions), a charge for Family-Issued Securities to
                  mitigate wrong way risk, a charge for Illiquid Positions, a charge to mitigate day over day margin
                  differentials. a coverage component, and a Backtesting Charge. In addition. NSCC may impose
                  a premium charge when a Member's Required Fund Deposit exceeds its excess net capital.
                  Not all required components to the Clearing Fund or other Clearing Fund deposit requirements
                  are described in this document; NSCC may require additional deposits to a Member's Clearing
                  Fund, as described in the NSCC Rules.


                  1     Volatility Component

                  1.1    Overview of Methodology

                  The volatility component of each Member's Required Deposit is designed to measure market
                  price volatility and is calculated for Members' Net Unsettled Positions. The volatility component
                  is designed to capture the market price risk associated with each Member's portfolio at a 99th
                  percentile level of confidence.

                  The volatility component applicable to most Net Unsettled Positions is calculated utilizing a
                  parametric Value-at-Risk ("VaR") model and is referred to as the VaR Charge. Net Unsettled
                  Positions in certain securities are excluded from this calculation and are instead charged a
                  haircut-based charge as the volatility component.

                  The volatility component usually comprises the largest portion of a Member's Required Deposit.
                  The volatility component is described in Procedure XV, l(A)(1)(a) and l(A)(2)(a) of the NSCC
                  Rules.

                  1.2    In-Scope Products and Process

                  Securities that are eligible to be cleared at NSCC can generally be classified into tvilo broad
                  categories: equity and fixed income instruments. Equity securities can be considered either liquid
                  or illiquid, which include, for example, IPOs. Fixed income securities can include, for example,
                  corporate bonds, municipal bonds and other types of securities that are non-corporate/non­
                  municipal securities. Examples are unit investment trusts, preferred stock, or other fixed income
                  securities that are amenable to generally accepted statistical analysis only in a complex manner.

                  Generally, liquid equity securities are subject to the VaR Charge, which uses a parametric VaR
                  approach with a number of flooring mechanisms which each targets specific risk drivers; and both
                  illiquid equity securities as well as fixed income securities are subject to a haircut-based volatility
                  charge.




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                  1.2.1    Equity Margining

                  All equities, other than those that are "Illiquid Securities", as defined in the NSCC Rules are
                  classified as liquid securities. In general, these securities include securities that are traded on
                  the national securities exchanges with its first available price more than 30 business dates ago in
                  the FAME historical price file over the past 153 business days. These securities are subject to
                  the VaR Charge, which utilizes a parametric method with additional components of a Volatility
                  Floor, Gap Risk, and Margin Floor.

                  In general, other equity securities traded on a national securities exchange that does not meet
                  the available pricing criteria is classified as an Initial Public Offering ("IPO"). Securities for which
                  there is no price data from the FAME historical price file for the day are generally considered
                  Illiquid Securities. Securities that are not listed on a national securities exchange and are traded
                  in over-the-counter marketplaces will also be defined as Illiquid Securities. A haircut-based charge
                  is applied as the volatility component for both the IPO and equities that are considered Illiquid
                  Securities.

                  1.2.2    Fixed Income Margining

                  There are generally three categories of fixed income securities that are eligible to be cleared at
                  NSCC: (1) corporate bonds. (2) municipal bonds, and (3) other fixed income securities (non­
                  corporate/non-municipal securities. A haircut-based volatility charge applied to all fixed income
                  securities. Specific haircut rates depend on the category of the security.

                  The haircut rates for corporate bonds are derived from the maturity/credit rating category into
                  which that bond is classified. There are currently 36 maturity/credit rating categories. For
                  municipal bonds, the haircut rates depend on bond maturity, credit rating and the bond's sector.
                  All other non-corporate/non-municipal bond fixed income securities are subject to a single haircut
                  rate.

                  Under the NSCC Rules, NSCC may exclude other securities from the application of the VaR
                  Charge and instead apply a haircut-based volatility charge.

                  1.3     Equity Volatility Component Calculations

                  1.3.1    VaR Charge

                  NSCC uses a parametric VaR methodology to calculate the VaR Charge. Parametric VaR is
                  assessed by simultaneously calculating four separate VaR types - (i} an exponentially-weighted
                  moving average ('EWMA') volatility estimation, (ii) an evenly-weighted volatility estimation, (iii) a
                  gap risk measure, and (iv) a portfolio margin floor. The highest resultant value among all of the
                  parametric VaR calculations becomes the surviving parametric VaR that is applied to the start-of­
                  day liquid equity position.

                  Parametric VaR Calculation

                  The parametric VaR for a given Member's liquid security portfolio, VaRp , is calculated as follows:

                                                VaR p = frat -tail x 2.327 x -./3 x JVai-iance(P)



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                                                                                                                        RHMDL00011597
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                  where 2.327 represents the 99th percentile of the Normal distribution, {3 is a time scaling factor
                  for the 3-day risk horizon, and ftat-tait is an adjustment factor from Normal distribution to
                  corresponding Student's t distribution.

                  Note that the variance is calculated with a decay factor and a lookback period, as follows:




                  where

                                ,t decay factor

                               w: look-back window size for EVVMA decay factor

                               ri (k): the 1-day return of the ith equity in the portfolio on the kth day counting
                               backward, based on FAME corporate action adjusted historical prices

                               v;: the position value of the ith equity in the portfolio

                               and



                                                                                 Iii.'·
                                                                                 w-1

                                                                            0=
                                                                                 k=O




                  The core parametric VaR is the larger of the base VaR and the Volatility Floor, where

                           1. the base VaR is calculated with A= 0.97 and w = 152

                           2. the Volatility Floor is calculated with A = 1 and w = 252

                  Gap Risk

                  The gap risk measure is designed to ensure that NSCC collects enough margin to cover the
                  idiosyncratic price movement of the most concentrated position in the guaranteed portfolio.

                  First, a concentration threshold is determined by conducting portfolio-level backtesting over a
                  look-back period of not less than the previous 12 months. 1




                  1        This concentration threshold is 10.0% as of the publication date of this document; this threshold
                           may change from time to time.


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                 Second, if the absolute value of the largest non-index position in the portfolio exceeds the
                 concentration level, the charge is determined by taking the gross market value of the concentrated
                 position and multiplying by a percent. 2

                  NSCC defines the gap risk as follows:3

                                                                                     mIMVd
                                           gap risk(c,9) = 9 x mIMVd (where
                                                                      I.             II[ MVi   I > c)
                  where

                          c = concentration level, which is the % threshold of the top non-ETF concentrated
                          position in the portfolio, beyond which GalP Risk would be assessed for the portfolio.

                          9 = gap size, which is the haircut applied to the top concentrated position in the
                          portfolio.

                          MV; = market value of position i.

                  Margin Floor

                  To address the remaining idiosyncratic and other risk factors in the portfolio not accounted for in
                  the other VaR calculations, NSCC utilizes a portfolio-level margin floor, parameterized as a
                  combined margin haircut on the value of net directional market exposure and the value of
                  balanced market exposures, respectively. These margin haircuts are equivalent to the reciprocal
                  of the directional or balanced Leverage Ratios.

                  First, the net directional market value of the portfolio is calculated by taking the absolute difference
                  between the market value of the long net unsett:led positions and the market value of the short
                  net unsettled positions in the portfolio and then multiplying that amount by a percentage.4




                  2       NSCC determines such percent empirically as no less than the larger of the 1st and 99th
                          percentiles of three-day returns of a set of CUSIPs that are subject to the volatility component,
                          giving equal rank to each to determine which has the highest movement over that three-day
                          period. NSCC uses a look-back period of not less than ten years that includes a one-year stress
                          period. If the one-year stress period overlaps with the look-back period, only the non-overlapping
                          period is combined with the look-back period. The result is then be rounded up to the nearest
                          whole percentage. Currently, as of the publication date of this document, the calculation uses
                          16%, and this is subject to change.

                  3       While positions in ETPs are generally excluded from the calculation of the Gap Risk measure,
                          NSCC does maintain a list of ETPs that will be subject to Gap Risk measure.

                  4       NSCC determines the applicable percentage by examining the annual historical volatility levels of
                          benchmark indices over a historical look-back period.


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                 Second, NSCC calculates the balanced market value of the portfolio by taking the lowest absolute
                 market value of long net unsettled positions and short net unsettled positions in the portfolio and
                 then multiplying that value by a percentage.5

                  More specifically,




                 where

                               HCa 6: haircut rate on directional market value

                              HCb : haircut rate on balanced market value

                              GM Vd : directional gross market value, IIGMV10n9 I-IGMVshort ll

                              GMVb : balanced gross market value, min(IGMV10,,9 I, IGMVshort l)

                  Final Parametric VaR

                 NSCC takes the highest result of the calculation of the core parametric VaR, the Gap Risk
                 measure and the margin floor as the final parametric VaR Charge.

                 NSCC calculates the Parametric VaR at the individual Account level and sums up to the Member
                 level.

                  Missing Security Return Backfiling

                 In calculating the VaR Charge, if the price return cannot be computed for a security due to
                 inaccurate or incomplete data, the following procedure is followed:

                  •   Calculate the front weighted correlations of this CUSIP with the list of indexing CUSIPs in
                      the table below as follows:

                      Step 1: Exclude any index ETF CUSIPs with less than n days of price history from FAME.
                      where n is the length of the estimation window.

                      Step 2: Calculate 1-day log returns for each CUSIP as well as the index ETF for each
                      historical business day

                                                                                (Eqn. 1.3.1.1)

                      where Pr represents the historical price on business date t.


                  5       NSCC determines the applicable percentage to be an amount that covers the transaction costs
                          and other re levant risks associated with the positions in the portfolio.

                  6       Haircuts are equivalent to the reciprocal of Leverage Ratios (LV).


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                      Step 3: For each CUSIP and index ETF pair (i, /), calculate the correlation:

                           1. Calculate the front-weighted mean of each CUSIP and index ETF pair

                                                                                                                (Eqn. 1 .3.1.2)


                                                                                                                (Eqn. 1 .3.1.3)

                           where i represents CUSIP and/ represents index ETF, T0 stands for date of the
                           calculation, and N is the nunnber of days between the earliest date when a return was
                           calculation in step 2 and T0 -- 1 for CUSIP. And h'o -k is the indicator function and

                                                [,. - . =
                                                             fO, when 11.ro-k is missing
                                                   10    k   h,                                          (Eqn. 1.3.1.4)
                                                                              otherwise
                           As any missing return will ha,ve no contribution to the mean calculation, any missing
                           return in the mean calculation can be simply filled with zero. 0 is default to the same
                           decay factor as the VaR Charge. Please note that the same indicator function is used in
                           both (Eqn. 1.3.1.2) and (Eqn. 1.3.1.3).

                           2. Calculate the front-weighted standard deviation and covariance

                                                                                                                (Eqn. 1.3.1.5)


                                                   l
                                                                                                       O ) )2
                                                                             0 k-1
                            a,(70) =
                                                             '°N [                  ( •
                                           v:-N          k-1 "-,kaal 10 -k X
                                                                                               ..,.( 1
                                                                                   X 11,T0-k - 11 ..,.          (Eqn. 1.3.1.6)
                                           k=1 1ro-kx 9

                                       1
                  CJ;• 1 (T0 ) = IN                 _ 1 f.r. -k >( e -l x (r,-r.
                                                                                          T
                                                                             ' o - k. -r,( 0 )) x (r, • ro -k -fi(T0 ))   (Eqn. 1.3.1.7)
                                                                     k
                                              k 1 L-
                                 1<=1 lro-kx O -        ._   o


                           where r,(T0 ) and fi(T0 ) are calculated in (Eqn. 1.3.1.2) and (Eqn. 1.3.1.3) separately,
                           and l70_k is specified in (Eqn. 1.3.1.4). As mentioned, that there is no impact on the
                           variance or covariance, the missing return can be simply filled with zero. a1 (T0 ) is
                           calculated differently for difforent ri series when having less than n returns. The r,.ro-k
                           terms in a1 (7'.0 ) calculation must matchr;•r. -k .. In other word, IrO -k· is determined by if r;is
                                                                        ' 0  I

                           missing and shared across Eqn. 1.3.1.5, Eqn. 1.3.1.6 and Eqn. 1.3.1. 7 above.

                           3. Calculate the correlation

                                                                                               (Eqn. 1.3.1.8)

                           where i represents the i-th CUSIP, j represents the }-th index ETF.




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                                             Type of
                           CUSIP              CUSIP          SYMBOL                        DESCRIPTION

                          46090E103           Liquid            QQQ        PowerShares QQQ Trust, Series 1 (ETF)

                                                                           SPDR Dow Jones Industrial Average
                          78467X109           Liquid             DIA
                                                                           ETF

                          78462F103           Liquid            SPY        Sf!>D S&P 500 Eil=


                          81369Y605           Liquid            XLF        Financial Select Sector SPDR (ETF)


                          81369Y506           Liquid            XLE        Energy Select Sector SPDR (ETF)


                          464287655           Liquid            IV\,M      iShares Russell 2000 Index (ETF)


                          78462F103       IPO & illiquid        SPY        SPDR S&P 500 ETF



                  •   Select the index ETF CUSIP with the maximum correlation. i.e. ma.x (abs(con·elations))

                  •   If this indexing CUSIP has a correlation value greater or equal to the value of the
                      CutoffCorrelation parameter, then replace the missing return with the return of the index
                      times the SIGN of the correlation between the index and the individual CUSIP. The initial
                      value of the CutoffCorrelation is set to 0.3.

                  •   If this indexing CUSIP has a correlation value of less than the value of CutoffCorrelation
                      parameter, then replace the missing return with a zero.

                  •   This can be expressed as:

                               if max(abs(correlation)) >= CutOffCorrelation
                               then if correlation>=0, then replace it with indexing-CUSIP-return
                                                      else re place it with (-1 * indexing-CUSIP-return)
                               else replace it with 0

                  1.3.2    Illiquid Equity and IPO Haircut Volatility Charge

                  NSCC excludes IPO equities and equities that are Illiquid Securities from the VaR Charge and
                  instead charges a flat percentage of not less than 10.0%. The current haircut rates are shown in
                  the table in Appendix A, and are subject to change from time to time.

                  For IPOs, NSCC currently uses a haircut of 15%. Mathematically,


                                                       chr9(lPO) = 0.15 x (      I
                                                                                vis /PO
                                                                                          lvl)


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                  For Illiquid Securities, NSCC currently uses a haircut of 20%. Mathematically,


                                                   chrg(llliquid )= 0.2        x ( L lvl)
                                                                                 "is Illiquid


                 NSCC calculates the haircut charges on Illiquid Securities and IPO equities at the individual
                 Account level and sums up to the Member level.

                 1.4     Fixed Income Volatil ity Component Calculations

                 NSCC calculates the haircut-based volatility charge on fixed income securities at the individual
                 Account level and sums up to the Member level.

                 1.4.1    Calculation Methodology for Corporate Bonds

                 Corporate bonds are categorized into 36 buckets by Illiquid Security Group Code according to
                 their time to maturity and credit rating. In order to capture the idiosyncratic risk and illiquidity of
                 different bonds within each category, percentiles greater than 99.0% are chosen for haircut
                 calibration. In addition, NSCC uses a 10-year look-back window plus a calendar year of stress
                 period in the haircut rate calibration. For the days that the stress period overlaps the look-back
                 window, the data used for calibration is 10 years plus the non-overlapping days in the stress
                 period. The corporate bond haircut is recalibrated quarterly. Please see Appendix B for a detailed
                 breakdown of the indices and parameters that ar-e currently utilized, as of the publication date of
                 this document.

                 The total volatility charge for positions in corporate bonds is equal to the sum of charges for
                 each category, as described below:
                                                            36

                             chrg(corporate bonds)= L(hr1ong(i) x lv1 0119(i)I + h1shortCO X lvshort(i)I),
                                                            i=I

                 where v1011 9 (i) and Vshon CO are respectively the total market values in USD of long and short
                 positions in bucket i..

                 1.4.2    Calculation Methodology for Municipal Bonds

                 For each Member, the volatility charge for positions in municipal bonds are calculated at the
                 CUSIP-level. Municipal bonds are grouped according to credit rating, remaining time to maturity
                 and separately categorized by municipal sector.

                 NSCC assesses a percentage haircut rate for each group based on (1) the historical returns of
                 applicable benchmark indices, such as tenor-based indices (i.e., based on time to maturity),
                 municipal bond sector-based indices, and high-yield indices; (2) a pre-determined look-back
                 period no shorter than 10 years, plus a calendar year of stress period in the haircut rate calibration;
                 and (3) a pre-determined calibration percentile, no less than 99%. The municipal bond haircut
                 rate is recalibrated quarterly.

                 The charge for a Member is obtained by aggregating the CUSIP-level charge contributions:


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                        Muni Bond Chr9 =      _L   muni borids b ln part.portfolio
                                                                                     hrc(b) x ABS(USD PositionAmount(b))

                  The haircut rate hrcO for a municipal bond is first determined by the remaining time to maturity
                  measured in months, as of the most recent EOD prior to the process date, as shown in the table
                  listed in Appendix C.

                  If the maturity date is unavailable, the haircut rate is set to that of longest tenor category.

                  For municipal bonds that are rated BBB+ or lower, or are not rated, the applicable haircut rate is
                  derived from the maximum of the applicable tenor-based index, municipal bond sector-based
                  indices and a high-yield index.

                  Current sectors include: (1) Utilities; (2) Government: (3) Healthcare; (4) Land Backed; (5)
                  Transportation; (6) Tobacco; (7) Higher Education; and (8) Housing.

                  1.4.3    Calculation Methodology for Other Fixed Income Securities

                  All fixed-income securities that are not classified as corporate bonds or municipal bonds are
                  subject to a single, fixed haircut rate. The haircut rate is currently set to 2% as of the publication
                  date and is subject to change.

                  The total volatility charge is calculated as follows:

                             Non Corp/Non Muni Chr9 = 0.02 x'                                                         lvl
                                                                           Lat! Non-Corporate/Non-Mtmicipa.l /Jonds

                  where v represents the market value for the corresponding non-corporate/non-municipal bond.

                  1.5     Family-Issued Securities Volatility Component Calculation

                  NSCC assesses a haircut-based volatility charge of no less than 80.0% on positions held in a
                  Member's Family-Issued Securities (or "FIS", as defined in the NSCC Rules). The Family-issued
                  Securities Charge is calculated to mitigate specific wrong-way risk to securities issued by
                  Members or their affiliates.

                  NSCC removes all long Net Unsettled Positions in FIS from the VaR Charge calculation and
                  assesses a haircut-based volatility charge on these positions based on the asset class of the
                  security.

                                                            Fixed Income                                     Equity
                                                    Family-Issued Securities                       Family-Issued Securities

                   Long Positions                           80.0% haircut                                100.0% haircut

                   Short Positions                  Not subject to this separate                   Not subject to this separate
                                                         volatility charge.                             volatility charge.




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                  2    Mark to Market Component

                  2.1.1   Start of Day Mark to MarkE!t Charge

                  The mark-to-market ("MTM") compo,nent measures the unrealized profit or loss using the contract
                  price versus the current market pricEi (that is, the price for a security determined daily for purposes
                  of the CNS system; generally that is the prior day's closing price). The MTM component is
                  described in Procedure XV, l(A)(1)(Ib) and (c) and l(A)(2)(b) of the NSCC Rules.

                  The MTM charge is assessed on each Member's rolling two-day portfolio net of unsettled
                  positions, including positions that fail in NSCC's Continuous Net Settlement system. The charge
                  is calculated by taking the differenoe between the contract value of each position in the portfolio
                  and the market value based on the prior day's closing market price.

                  CUSIP MTM credits and debits are first aggregated at the linked family account level. The main
                  account MTM is equal to the sum of the MTM debits across link accounts, separated into three
                  transaction types: regular way, whe,n-issued, and Institutional Delivery Net ("ID Net"). The MTM
                  debits calculated for regular way, ..-men-issued, and ID Net transactions are summed to a total
                  MTM charge.

                  MTM credits do not offset the total MTM charge; in the event the Member has an MTM credit
                  when aggregated at the main accoLint level, the MTM charge will be zero.

                  2.1.2   lntraday Mark to Market Charge

                  NSCC may require an additional llntraday MTM charge should NSCC deem it necessary or
                  appropriate, for example, during times of extreme market volatility. The intraday MTM charge is
                  described in Procedure XV, Section 1(8)(5) of the NSCC Rules.

                  lntraday market moves and positions are tracked in fifteen-minute intervals and an additional
                  MTM charge may be collected if the difference between most recent mark-to-market price of a
                  Member's Net Unsettled Positions and the most recent observed market price exceeds a
                  predetermined threshold.

                  The current threshold is 80% of the Member's volatility charge and may be reduced if NSCC
                  determines that a reduction of the tlhreshold is appropriate to mitigate risk during volatile market
                  conditions.

                  3    Special Charge

                  NSCC may require an additional payment, or Special Charge, from Members in view of price
                  fluctuations in or volatility or lack of liiquidity of any security. NSCC shall make such determination
                  based on the Member, the security 1type and concentration, CRRM or third-party credit ratings, or
                  other factors. The Special Charge is described in Procedure XV, Section l(A)(1)(d) and l(A)(2)(c)
                  of the NSCC Rules.

                 4     CNS Fails Charge Componenit

                  NSCC may be exposed to market risk when a Member fails to pay net settlement proceeds as a
                  result of the non-delivery of securities by settlement date as well as when a Member fails in the
                  delivery of securities on settlement date. To mitigate NSCC's exposure to CNS fails positions,


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                  which could be correlated to a M,ember's credit-worthiness, NSCC assesses the CNS Fails
                  Charge. The CNS Fails Charge is described in Procedure XV, Section l(A)(1)(e) of the NSCC
                  Rules.

                  The CNS Fails Charge is calculat,ed by multiplying the current market value of a Member's
                  aggregate CNS Fails Positions by a percent based on the Member's rating on the Credit Risk
                  Rating Matrix ("CRRM"), as describ1ad below:

                            Member's CRRM Rating                                  CNS Fails Charge Haircut Rate

                                                                        5.0% of the Member's aggregate CNS fails
                                          1-4
                                                                        positions

                                                                        10.0% of the Member's aggregate CNS fails
                                         5-6
                                                                        positions

                                                                        20.0% of the Member's aggregate CNS fails
                                           7
                                                                        positions



                  The Credit Risk Rating Matrix is described in Rule 2B, Section 4 of the NSCC Rules.

                  5    Margin Requirement Differential ("MRD") Component

                  NSCC may be exposed to market risk based on potential portfolio fluctuation as a Member
                  executes trades throughout the da1y. Pursuant to Addendum K of the NSCC Rules, NSCC's
                  general counterparty trade guaranty generally attaches immediately upon trade validation and
                  before NSCC has collected the Member's required deposit. As a result, NSCC may be exposed
                  to large un-margined intraday portfolio fluctuations before NSCC has collected the Member's
                  clearing fund requirement the following morning.

                  The Margin Requirement Differentiail charge ("MRD") is designed to help mitigate the risks posed
                  to NSCC by day-over-day fluctuations in a Member's portfolio by forecasting future changes in a
                  Member's portfolio based on a historical look-back at each Member's portfolio over a given time
                  period. The MRD charge is described in Procedure XV, Section l(A)(1)(f) and 1 (A)(2)(d) of the
                  NSCC Rules.

                  The MRD charge is calculated based on the day-over-day positive changes in the Member's start
                  of day7 ("SOD") volatility charge and MTM charge components, which are calculated based on
                  the overnight or end of day ("EOD") positions. For example, the position referred to by NSCC's
                  system's SOD label on 7/1/2020 refers to the EOD position on 6/30/2020.

                  For any given calculation date, t, thE MRD charge is calculated as follows:

                  1. Calculate the MRDvaR and MRD MrM sub-components.




                  7       Using the NSCC risk system convention.


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                                MRDvan(t) =
                                                 Ir,;0 0 1 x rnax{VaR(t - i,SOD) - VaR(t - (i + l),SOD), O}
                                                                                  99       ;
                                                                                  L..i=O (J

                                                                                                                          (1.2.3.1.1 )
                                  MRDMrn (t)
                                   I?o 0 x ma,"-(CHRGM ru(t - i,SOD) - CHRGuru(t - (i + 1), SOD), OJ
                                         i




                      where
                           ► i represents the number of business days look back relative to the calculation date,
                             currently 100 days; For Etxample, when i = 0, VaR(t- i,SOD) represents the SOD
                             Volatility charge as of the calculation date; when i = 1, VaR(t - i, SOD) represents
                             the SOD volatility chargEi one business day before the calculation date; etc;

                           ► 0 is equal to 0.97 as default;

                           ► VaR(d,SOD) is the SOD volatility charge as of business dated; and

                           ► CHRGuru(d,SOD) is the SOD MTM charge as of business dated.

                  2. Calculate the MRD charge by multiplying the sum of MRDvan and MRDuru sub-components
                     with an MRD coefficient8.

                                         MRD(t) = Coefficient x [ MRDvan(t) + MRDMTu(t)]

                  The MRD charge is calculated at the Member level. There are four special treatments in this
                  calculation.

                  1. On the first day of membership, the differences VaR(t- i,SOD) - VaR(t - (i + 1),SOD) and
                     CHRGMru(t-i,SOD)-CHRGMru(t-(i+l),SOD) in Eqns. 1.2.3.1.1 are replaced with
                     zeros.

                  2. Apart from treatment above, if a member has less than 101 business days of MTM and
                     Volatility charges, the missing values VaR(t) and MTM(t) in Eqns. 1.2.3.1.1 are replaced
                     with zeros.

                  6    Coverage Component ("CC") Charge

                  NSCC is exposed to a Member's u1n-rnargined portfolio as a result of the timing when NSCC's
                  trade guaranty attaches to positions, which is immediately upon trade validation and prior to the
                  collection of margin. Therefore, the Coverage Component ("CC") charge is designed to mitigate
                  the risks associated with a Member's Required Fund Deposit being insufficient to cover projected
                  liquidation losses to the coverage target, currently a 99 percent confidence level, by adjusting a



                  8        Current, as of the time of publication of this document, the MRD coefficient is 1.5; this is subject
                           to change.


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                  Member's Required Fund Deposit towards the target. The CC charge is described in Procedure
                  XV, Section l(A)(1)(g) and l(A)(2)(e}.

                  The CC charge supplements the MRD charge by preemptively increasing a Member's Required
                  Fund Deposit in an amount calculatid to forecast potential deficiencies in the margin coverage of
                  a Member's guaranteed portfolio.

                  The CC charge is calculated by comparing the simulated liquidation profit and loss of a Member's
                  portfolio, using the actual positions and the actual historical returns on the positions, against the
                  sum of each of the following Clearin!g Fund components: (i) volatility charge; (ii) MRD charge; and
                  (iiO illiquid charge. For a given busiiness day, NSCC determines a daily peak deficiency amount
                  for each Member equal to the maxiimum observed deficiency over any of the prior 10 business
                  days. The CC charge is equal to the front-weighted average of the peak deficiencies over the
                  prior 100 business days.

                  The CC charge is calculated as follo'NS:

                      1. For any given business day t, calculate the Peak Deficiency:
                                        Peal,Deficiency(t)
                                                      = MAX0:;;;:;;9 {-min [VaR(t-4-i,SOD)
                                                                                                             Eqn. 1.2.3.2.1
                                                      + Illiquid(t - 4 - i) + MRD(t - 4- - i)
                                                      + P&l(t- 3 - i),O]}
                          where

                               ► i represents the number of business days look back; For example, when i=O,
                                 VaR(t - 4 - i,SOD) represents the SOD Volatility charge as of the business day
                                 oft- 4; when i=1, Vc.rR(t - 4- - i,SOD) represents the SOD Volatility charge as of
                                 the business day t- 5; and etc;
                               ► VaR(d,SOD) is the SOD Volatility charge as of the business day d;
                               ► Illiquid(d) is the illiquid charge as of the business day d;
                               ► MRD(d) is the MRD charge as of the business day d; and
                               ► P&L(d) is the 3-day liquidation profit or loss of the SOD position as of the business
                                 day d;

                      2. Calculate the CC charge

                                                                    i
                                                          : 0 0       x PeakDeficiency(t - i)
                                                CC(t) =                     99 gt
                                                                            L..t=O

                          where
                             ► i represents the number of business days look back as of the calculation day t,
                                For example, when ;,=0, PeakDeficiency(t - i) represents Peak Deficiency as of
                                the calculation day t; when i=1, Pea.kDeficiency(t - i) represents the Peak
                                Deficiency as of the business day before the calculation day; and etc;
                             ► 0 is equal to 0.97 as default.


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                  The CC charge is calculated at the NSCC Member level only. The P&L and relevant charges in
                  the above calculation are the sum of the Member's subaccounts. The following special treatment
                  is applied:
                  1. When there is less than 10 days of history for the Peak Deficiency calculation in Eqn.
                     1.2.3.2.1, actual number of history observations is used.
                  2. In case the history of peak deficiencies is shorter than 100 days for any Member, all the
                     missing peak deficiencies are default to zeros.
                  7    Illiquid Charge Component

                  An Illiquid Charge can be assessed on Members in view of price fluctuations in or volatility, or
                  lack of liquidity of any security. The Illiquid Charge is described in Procedure XV, Section
                  l(A)(1)(h) and l(A)(2)(f). The Illiquid Charge may be imposed based on:

                               •    Size of the position in an Illiquid Security

                               •   Average daily volume in the Illiquid Security in the position

                               •    Price of the Illiquid Security in the position

                               •    Member's rating on the CRRM

                               •    Member's Excess Net Capital ("ENC')

                  Using the current CRRM rating Illiquid Charge criteria, which is set forth in Appendix E and is
                  subject to change, the Illiquid Charge is equal to:

                  (1) for buy positions in sub-penny Illiquid Securities, the aggregate shares in such positions
                  multiplied by $0.01, or

                  (2) for sell positions, the Illiquid Charge can be determined by the following:

                           (a) if the share quantity in the Illiquid Securities' position is less than 100 percent and
                           greater than or equal to 25 percent of the average daily volume ("ADV'), the calculation
                           shall use the lesser of the one month high price or the current market price of the Illiquid
                           Securities (rounded up to the next $0.50, if applicable); and

                           (b) if the share quantity in the Illiquid Securities' position is greater than or equal to 100
                           percent of the ADV, the calculation shall use the greater of the one-month high price or
                           the current market price of the Illiquid Securities (rounded up to the next $0.50, if
                           applicable).

                  NSCC Members can email eguityrisk@dtcc.com to obtain a flow chart detailing the applicable
                  Illiquid Charge calculation based on their CRRM rating and capital levels as of the date of the
                  request.




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                  8    Other Transactions Charge

                  Art additional charge for transactions other than CNS transactions is based on the 20-day rolling
                  average of the summed value of non-guaranteed settlement activities. This "Other Transactions"
                  charge is described in Procedure XV, Section l(A)(3) of the NSCC Rules.

                  Daily Other Transactions charges range between 2.5% and 10.0% of the net debits and credits.
                  Each of the current Non-CNS codes is described in Appendix D.

                  Currently, for Members with a CRRM rating of 1 through 6, the charge takes the greater of the
                  following, based on a 20-day rolling average of activity:

                               2.5% of the absolute value of debits+ the absolute value of credits

                               5.0% of the absolute value of debits

                  Currently, for Members with a CRRM rating of 7, the charge is calculated by taking the 20-day
                  rolling average of activity based on 10.0% of the absolute value of debits and the absolute value
                  of credits.

                  9    Mutual Fund Transactions Charge

                  An additional charge is calculated for mutual fund transactions, referred to as the Fund/Serv
                  charge. This charge is described in Procedure XV, Section l(A)(4) of the NSCC Rules.

                  The Fund/Serv charge is derived from a Member's daily settlement debits related to mutual fund
                  activities and is tiered as follows:

                           A. $5,000 if daily mutual fund services settlement debits of no more than $100,000 with
                           respect to any one fund Member.

                           B. $10,000 if daily mutual fund services s,ettlement debits of no more than $500,000 with
                           respect to any one fund Member.

                           C. $20,000 if daily mutual fund services debits of more than $500,000 with respect to any
                           one fund Member.

                  A daily monitoring 'snapshot' is performed at 12:00PM EST. When mutual fund settlement
                  debits are greater than or equal to $500 million, NSCC generally will confirm the amount with
                  the Member.

                  10 Excess Capital Premium ("CF Premium") Charge

                  NSCC may assess a CF Premium charge to mitigate risk presented by highly leveraged Members.
                  The charge may be imposed when a Member's applicable Required Fund Deposit (the aggregate
                  unadjusted Required Fund Deposit minus any Illiquid Charge, MRD charge, CC charge, and
                  special charges) exceeds their excess net capital ("ENC'') for broker-dealers, or equity capital for
                  bank Members. The CF Premium charge is described in Procedure XV, Section 1(8)(2).




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                  The CF Premium charge may be assessed based on the amount by which a Member's applicable
                  Required Fund Deposit exceeds its most recently reported regulatory capital balance (ENC or
                  equity capital).

                  If the ratio of the Required Fund Deposit over the excess capital balance (the "excess capital
                  ratio") exceeds 1.0, a CF Premium charge may be calculated by multiplying the excess capital
                  ratio by the amount by which the Reiquired Fund Deposit exceeds the excess capital balance.

                 When the excess capital ratio exce:eds 1.0, NSCC may calculate and assess the CF Premium
                  charge as part of the Member's start-of-day reciuirement.

                                                                                          Additional Clearing Fund
                    Excess Capital Ratio                 NSCC Action                             Calculation

                                                                                   Multiply the amount of the CFR that is
                    Excess Capital Ratio         An excess capital                 in excess of the reported capital
                               1.0              premium may be imposed.           balance by the Member's excess
                                                                                   capital ratio



                 11 Backtesting Charge

                 NSCC may require a Member to make an additional deposit in the form of a Backtesting Charge
                 to mitigate exposures that may not be adequately captured by the volatility model as needed to
                 achieve a 99 percent back testing coverage target. The charge may be assessed at the start of
                 the day or on an intraday basis, as needed. The Backtesting Charge is described in Procedure
                 XV, Section 1(8)(3) of the NSCC Rules.

                 NSCC incorporates daily backtestiing to ensure that the calculated Clearing Fund Required
                 Deposit is sufficient to cover the potential loss the clearing corporation may be subject to in the
                 event of a Member default. In order to calculate this charge, NSCC takes end-of-day, 11 :ODAM
                 EST, and 2:00PM EST portfolio snapshots, then compares the Member's Required Fund Deposit
                 to the profit and loss over a simulated three-day liquidation horizon; a deficiency occurs when a
                 Member's Required Fund Deposit does not sufficiently cover the simulated loss on a portfolio.

                 NSCC routinely calculates the rollin! 12-month coverage ratio of the Member for both the end-of­
                 day and intraday backtests. Coverage is calculated as the percentage of non-deficiency backtest
                 observations out of the number of backtest observations the Member has during the period.
                 NSCC seeks to maintain 99.0% coverage at the Member-level.

                 Should the coverage ratio decline below 99.0% for either or both backtest types, NSCC may
                 assess a backtest charge component such that, if applied retroactively, the Member would not
                 have incurred enough deficiencies for the coverage ratio to decline below the 99.0% coverage
                 target. Typically, the amount of the, backtest charge component will be equal to the Member's
                 third-largest end-of-day backtest deificiency and fifth-largest intraday backtest deficiency during
                 the rolling twelve-month period.

                 NSCC may adjust the calculation and/or application of the charge in order to achieve its
                 backtesting coverage target.



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                  12 Bank Holiday Charge

                  NSCC does not collect margin or settle securities on a bank holiday, as Columbus Day and
                  Veterans Day, when the equities markets are open for trading, but the Board of Governors of the
                  Federal Reserve observes a holidav and banks are closed. To address exposure from Members'
                  trading activity on a bank holiday, N:SCC may require its Members to make an additional Clearing
                  Fund deposit (the "Bank Holiday Charge'). The Bank Holiday Charge is based on NSCC's
                  assessment of market conditions ait the time the charge is calculated and is assessed on the
                  business day immediately prior k> the bank holiday. NSCC communicates in advance to
                  Members, via an Important NotiC19, the day on which the charge will apply, including the
                  methodology 9 it will use to calculate the Bank Holiday Charge. The Bank Holiday Charge is
                  described in Procedure XV, Section 1(8)(4) of the NSCC Rules.



                  13 Appendices

                  The information provided in thes1e Appendices is current as of the publication date of this
                  document. This information may change from time to time following publication, without
                  notice and without updates to this document. Notwithstanding anything stated in this
                  document, NSCC retains any discretion provided to it in the Rules in calculating the
                  charges described therein.



                  Appendix A

                  Haircut Table

                           Asset Type                         IF actor                                Haircut Rate

                    Non-NASDAQ, OTC BB
                                                                N/A                20.0% of the absolute value of the position
                         or OTC Link

                                IPO                             NIA                 15.0% of the absolute value of the position

                      Non-Corporate/Non-
                                                                N/A                 2.0% of the absolute value of the position
                       Municipal Bonds




                  9 A methodology might include time scaling of the volatility charge or a using a stress scenario that reflects potential
                  market price volatility on that holiday.

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                  Appendix B

                  Corporate Bond Mapping Table


                                              Merrill
                     Illiquid Security        Lynch                                                 Percentile
                        Group Code            Index             Description of the Security Group          (%)

                                         1 C1A1          0-1 year/ AAA/ Aaa                         99.5

                                         2   C1A2        0-1 year/AA+/AA/AA-/1/Aa2/Aa3             99.5

                                         3   C1A3        0-1 year/A+/A/A-/A1/A2/A3                  99.5

                                         4   C1A4        0-1 year/BBB+/BBB/BBB-/Baa 1/Baa2/Baa3     99.5

                                         5   H0AO        0-1 year/BB & Lower                        99.9

                                         6 C1A1          1-3 years/AAA/a                           99.5

                                         7 C1A2          1-3 years/AA+/AA/AA-/Aa1/2/3             99.5

                                         8   C1A3        1-3 years/A+/A/A-/A1/A2/A3                 99.5

                                         9 C1A4          1-3, years/BBB+/BBB/BBB-/Baa1/Baa2/Baa3    99.5

                                       10    H0AO        1-3, years/BB & Lower                      99.9

                                       11    C2A1        3-5, years/AAA/a                          99.5

                                       12    C2A2        3-5, years/AA+/AA/AA-/Aa1/2/3            99.5

                                       13    C2A3        3-5, years/ A+/A/ A-/A1/ A2/A3             99.5

                                       14    C2A4        3-5' years/BBB+/BBB/BBB-/Baa1/Baa2/Baa3    99.5

                                       15    H0AO        3-5, years/BB & Lower                      99.9

                                       16 C3A1           5-7 years/AAA/a                           99.5

                                       17    C3A2         5-7 years/AA+/AA/AA-/Aa1/2/3            99.5

                                       18    C3A3        5-7 years/A+/A/A-/A1/A2/A3                 99.5

                                       19 C3A4            5-7 years/BBB+/BBB/BBB-/Baa 1/Baa2/Baa3   99.5

                                       20    H0AO         5-7 years/BB & Lower                      99.9

                                       21    C4A1        7-10 years/AAA/Aaa                         99.5



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                                              Merrill
                     Illiquid Security        Lynch                                                    Percentile
                        Group Code            Index             Description of the Security Group             (%)

                                       22 C4A2           7-10 years/AA+/AA/AA-/Aa1/Aa2/Aa3            99.5

                                       23    C4A3        7-10 years/A+/A/A-/A1/A2/A3                  99.5

                                       24 C4A4           7-1 0 years/BBB+/BBB/BBB-/Baa 1 /Baa2/Baa3   99.5

                                       25    H0A0        7-10 years/BB & Lower                        99.9

                                       26 C7A1            10-15 years/AAA/Aaa                         99.5

                                       27    C7A2         10-15 years/AA+/AA/AA-/Aa1/Aa2/Aa3          99.5

                                       28 C7A3            10-15 years/A+/A/A-/A1/A2/A3                99.5

                                       29    C7A4         10.. 15 years/BBB+/BBB/BBB-/Baa 1 /Baa2/Baa3 99.5

                                       30    H0A0         10-15 years/BB & Lower                      99.9

                                       31 C8A1            15, years/AAA/Aaa                          99.5

                                       32 C8A2            15+ years/AA+/AA/AA-/Aa1/Aa2/Aa3            99.5

                                       33 C8A3           15+ years/A+/A/A-/A1/A2/A3                   99.5

                                       34 C8A4            15+ years/BBB+/BBB/BBB-/Baa1 /Baa2/Baa3     99.5

                                       35    H0A0         15, years/BB & Lower                       99.9

                                       36 H0A0           All others/Not Rated                         99.9




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                 AppendixC

                  Municipal Bond Haircut Table

                        Market            Asset Type                  Factor                      Haircut Rate

                                                            (Mnths to Mat) s 36

                                                            37<(Mnths to Mat) ::5 84

                                                            85<(Mnths to Mat) s        Calibrated at 99.5% level based on
                                           Investment                                  tenor-based indices.
                                                            144
                                             Grade
                                                            145<(Mnths to Mat) s
                                                            264

                                                            264<(Mnths to Mat)

                                                            (Mnths to Mat) s 36
                       Municipal
                        Bonds                               37<(Mnths to Mat) s 84

                                              Non-          85<(Mnths to Mat) s        Calibrated at 99.9% level based on
                                           Investment       144                        tenor and sector-based indices.
                                             Grade
                                                            145<(Mnths to Mat) s
                                                            264

                                                            264<(Mnths to Mat)

                                             Specific                                  During period of extraordinary
                                              Issuer        All                        market conditions, NSCC may
                                                                                       apply the highest blended rate.



                  Appendix D

                  Non-CNS Codes

                       Code                        Data Giroup                                 Description

                          1         OTC Settlement                              OTC BROAD MONEY SETTLEMENT

                         2          Clearance Cash Adjustment                   CLEARANCE CASH ADJUSTMENT

                         5          ACATS                                       ACATS INTERFACE REJECTS

                         8          ACATS                                       ACATS NEXT DAY SETTLEMENT


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                       Code                         Data Giroup                              Description

                          11         Envelope                                     DIVIDEND SETTLMENT SERV.

                         12          Envelope                                     FUNDS ONLY SETTLEMENT

                          13         Envelope                                     DSS RECLAMATIONS

                          1e         CNS Reorganizations                          CNS REORG MARK - DEBIT

                          17         CNS Reorganizations                          CNS REORG MARK - CREDIT

                         20          ow                                           RECAPS CASH ADJUSTMENTS

                         30          CDS Dividends                                OTC CANADIAN DIVIDENDS

                         31          CDS Dividends                                CNS CANADIAN DIVIDENDS

                         32          CDS Dividends                                DSS CANADIAN DIVIDENDS

                         35          OTHER                                        OCC COLLATERAL PLEDGE

                         45          Fees                                         NASDAQ BX TRAN FEES

                         46          Fees                                         NASO REG-FEES

                         47          Fees                                         PSA REGULATORY FEES

                         48          Fees                                         NSE TRANSACTION FEES

                         49          Fees                                         CSE REGULATORY FEES

                         50          Fees                                         NYSE REGULATORY FEES

                         51          Fees                                         AMEX REGULATORY FEES

                         52          Fees                                         NASO REGULATORY FEES

                         53          Fees                                         PSE REGULATORY FEES

                         54          ETF                                          STAN OARD BASKETS

                         55          ETF                                          CUSTOMIZED STANDARD BASKETS

                         68          Tax                                          NYS TRANSFER TAX

                         70          Tax                                          NYS QUARTERLY TAX

                         71          Tax                                          NYS QUARTERLY TAX REFUND



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                       Code                         Data Giroup                                     Description

                         74          OTHER                                         CLEARING FUND COUPON INT

                         80          Fees                                          NSCC MONTHLY BILLING

                         81          Floor Broker                                  NYSE COMMISSION BILLS

                         83          Fully Pid                                    FULLY PAID DEBIT$

                         84          Fully Paid                                    FULLY PAID CREDITS

                         85          Floor Broker                                  AMEX COMMISSION BILLS

                         91          OTHER                                         GCN CHARGES

                         96          OTHER                                         OPTIONAL SETTL SERVICE

                         97          OTHER                                         SUSPENSE

                         98          OTHER                                         PAYMENTS (FUNDS TRANSFER)

                        101          OTHER                                         RIO-OTC INTERFACE

                        111          Insurance                                     INSURANCE COMMISSIONS

                        112          Insurance                                     INSURANCE PREMIUMS

                        113          Insurance                                     LICENSING & APPT DETAIL

                        181          Floor Broker                                  NYSE COMM BILL CHARGES

                        185          Floor Broker                                  AMEX COMM BILL CHARGES

                        198          OTHER                                         OTC/CNS CREDITS




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                 Appendix E

                  Illiquid Charge Calculation Tables

                   Net Buy Illiquid Positions

                                                                                               OTC
                    CRRM                                                                    Inventory
                    Rating           %ADV                 EIUYQTY                 ENC        Off$et     Pricing Calculation

                                                                                                          Per share times
                      1-4               N/A              X > 100MM                N/A         N/A
                                                                                                               $0.01

                                                                                                          Per share times
                      5-7               N/A               X > 10MM                N/A         N/A
                                                                                                               $0.01

                   Net Sell Illiquid Positions

                                                                                              OTC
                    CRRM                                                                    Inventory     Pricing Scheme
                    Rating           %ADV                 SELL QTY              ENC($)        Offset    (See Tables Below)

                      1-4         25 sx < 100           X =:: 1,000,000           N/A          y              Lesser

                      1-4             100SX             X =:: 1,000,000           N/A          y             Greater

                      5-6             100:;;x            X::: 500,000           10MM < X       y             Greater

                      5-6             100SX              X::: 100,000           10MM::: X      y             Greater

                      5-6         25 :s X < 100          X::: 500,000           10MM < X       y              Lesser

                      5-6         25:;; X < 100          X::: 100,000           10MM::: X      y              Lesser

                       7              100:;;x            X::: 500,000           10MM < X       N             Greater

                       7              100SX              X::: 100,000           10MM::: X      N             Greater

                       7          25 sx < 100            X::: 500,000           10MM < X       N              Lesser

                       7          25:;; X < 100          X::: 100,000           10MM::: X      N              Lesser




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                  Illiquid Pricing Scheme (Lesser)

                                   Pricing Scheme ($)                                Charge Calculation                Price Min($)

                    Market Price               <          .011                Lesser of 1 month high price and       .01
                                                                              Market price times 10

                    Market Price               <          .Oi                 Lesser of 1 month high price and      .05
                                                                               market price times 10

                    Market Price               <          .10                  Lesser of 1 month high price and
                                                                               market price times 10

                    Market Price               <          .20                  Lesser of 1 month high price and
                                                                               market price times 5

                    Market Price               <          1.00                 Lesser of 1 month high price and
                                                                               market price times 2

                    Market Price               >          1.00                 Lesser of 1 month high price and
                                                                               $.50 price increment


                  Illiquid Pricing Scheme (Greater)

                    Pricing Scheme ($)                                        Charge Calculation                     Price Min ($)

                    Market Price               <          .01                 Greater of 1 month high price and      .01
                                                                              market price times 10

                    Market Price               <          .05                 Greater of 1 month high price and      .05
                                                                              market price times 10

                    Market Price               <          .10!                Greater of 1 month high price and
                                                                              market price times 10

                    Market Price               <          .201                Greater of 1 month high price and
                                                                              market price times 5

                    Market Price               <          1.0I0               Greater of 1 month high price and
                                                                              market price times 2

                    Market Price               >         1.0I0                Greater of 1 month high price and
                                                                              $.50 price increment




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