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The Importance of Compliance for OCC

By Richard Wallace, OCC Senior Vice President and Chief Compliance Officer
July 19, 2016

Companies around the world recognize and value the importance of a strong compliance function as part of their value proposition for customers. This is particularly true for OCC.

As the world's largest equity derivatives clearing organization, we must do everything we can to ensure confidence in the financial markets and the broader economy. It is our responsibility as a Systemically Important Financial Market Utility (SIFMU) to promote stability and market integrity through effective and efficient clearance, settlement and risk management services.

And in my role as chief compliance officer, it is my job, along with my colleagues, to make sure OCC remains in compliance with all regulatory requirements in our role as a SIFMU, and has the right strategy in place to stay ahead of the regulatory curve.

OCC serves 14 options exchanges, four futures exchanges, one stock loan alternative trading system, and approximately 115 clearing firms. If any of those firms do not honor the trade responsibilities they have to market participants, OCC moves in to make sure those trade guarantees are covered. Due to our role in financial markets, the services OCC provides every day are important and relied upon by many. If we are unable to fulfill that responsibility, a huge systemic problem could develop.

With that high level of responsibility comes an equally high level of expectations in terms of risk management and governance. As a SIFMU, OCC is subject to an extremely high review process, which includes the U.S. Securities and Exchange Commission, the U.S. Commodity Futures Trading Commission, and the Federal Reserve.

When I joined OCC, it was clear the company was committed to doing the right thing and getting to where our regulators felt we should be as a clearing organization. It also was clear that we had a steep learning curve as we tried to keep pace with current regulatory demands.

We knew that we had to get ahead of the regulatory curve in order to perform our role as market participants expected. The first thing we did was to build a strong compliance system that could verify the improvements my colleagues put in place met the regulatory requirements we faced. This became an effective way for us to identify and catch problems at an earlier stage in the process. It also became a powerful educational tool so our employees could better understand the heightened regulatory standards we had to meet.

We also strengthened the foundation for what we needed to do to enhance controls across the enterprise. We had to provide a better understanding of our old processes, documenting who was in charge of what, mapping them to our requirements, building out an enterprise-wide system that houses our compliance, audit and enterprise risk management needs, and then make sure we could link them all together.

This created some positive momentum that we turned into a company-wide initiative where we examined every aspect of OCC to identify areas where we could improve on performance and bring our compliance practices to a new level that was higher than what was expected by our regulators.

What sets the OCC compliance team apart from others is our continuous focus on risk. The regulations for clearing houses require policies and procedures for the credit, market, as well as for modeling risk in general and default risk in particular.

This includes having sophisticated methods in place to deal with the challenge when a clearing member either defaults or has a serious trading disruption. The regulations under the Dodd-Frank legislation requires us to make sure we have the plans in place to deal with either scenario. The stress testing model that we use for clearing members is organized and systemic, similar to how it uses models to set margin requirements and how much financial resources the company must have on hand.

Last year, OCC continued to strengthen its business process, internal controls and infrastructure resiliency across the company and continued to make progress towards implementing critical risk management objectives. We accelerated the closure of more than 90 percent of legacy regulatory examination findings.

We are proud of the changes we have made at OCC since our designation as a SIFMU and we are honored to continue contributing to reduced systemic risk in our financial markets. We understand the need to appropriately incentive users to help safeguard our markets and contribute to maintaining equilibrium in a mutualized system. Without that balance, we run the risk of becoming less secure or diverting activity away from central counterparties like OCC, in contravention of the goals established by domestic and international policy makers in dealing with the 2008 financial crisis.

Categories: Compliance, Regulation