To: All members Ref: 17/203 Classification: Trading Date: 12 June 2017 Subject: CONSOLIDATED NOTICE FOR TRADED OPTIONS PROCEDURES Summary 1. The LME is issuing a consolidated Notice to set out the procedures for LME Traded Options which are intended to provide clarity and ease of reference for market participants. The procedures include: a) tradable Strike Price gradations in denominated clearing currencies; b) useful information for premiums; c) the declaration process; d) the process for reporting Traded Options through the LME market data feed, LMEselectMD; and e) the procedures and methodology used for the determination of the Closing Prices. 2. This Notice consolidates and replaces the following Notices: a) Notice No. 07/358 : A:351, dated 17 December 2007 Price Information for Traded Options; b) Notice No. 08/199 : A193, dated 25 June 2008 Amended Options Strike Gradations for all Metals Denominated in US Dollars and Euros; c) Notice No. 08/387 : A374, dated 21 November 2008 LME Traded Options Volatilities; d) Notice No. 11/097 : A094, dated 13 April 2011 Consultation on Impact of Volatility Wings for LME TAPOs; e) Notice No. 11/188 : A182, dated 20 July 2011 Implementation of Volatility Wings for LME TAPOs and Traded Options; f) Notice No. 14/290 : A282, dated 22 September 2014 LME Traded Options Declaration Process; THE LONDON METAL LME S 10 Finsbury Square, London EC2A 1AJ Tel +44 (0)20 7113 8888 Registered in England no 2128666. Registered office as above. LME.COM
g) Notice No. 15/200 : A196, dated 6 July 2015 Mandatory use of the LMEsmart Volatility Data Field to Enhance the Valuation Procedure for Traded Options; h) Notice No. 15/219 : A214, dated 17 July 2015 Launch of LMEprism; i) Notice No. 15/305 : A297, dated 2 October 2015 Enhancing Post Trade Transparency for Traded Options; j) Notice No. 16/240 : A234, dated 5 July 2016 Changes to Publication of Traded Options; k) Notice No. 16/307 : A301, dated 13 September 2016 Consultation on Enhancements to the Determination of the Closing Prices for traded Options; l) Notice No. 16/337 : R007, dated 27 October 2016 Decision Notice - Introduction of Enhancements to the Determination of the Closing Prices for Traded Options; and m) Notice No. 17/029, dated 20 January 2017 Decision Notice - Consultation on Enhancements to the Real-Time Reporting of Transactions. 3. This Notice also makes reference to Part 5 of the LME Rulebook on the Traded Options Regulations, and Notice No. 16/031 : A/031, dated 28 January 2016 LME Enforcement Process: Transitional Arrangements & Further Guidance Regarding Business Processing & Reporting Rule Breaches. Capitalised Terms 4. Capitalised terms not otherwise defined in this Notice shall have the meaning ascribed to them in the LME s Rules and Regulations (the Rules ) 1. Background 5. The LME has from time to time issued relevant Notices when there have been changes to the LME Traded Options market around Strike Price gradations in denominated clearing currencies, premiums, the declaration process, the reporting of matched trades, including the deferred publication for large in scale transactions, and the procedures and methodology used for the determination of the Closing Prices. In some cases, where appropriate, the LME Rulebook has been amended to reflect such changes. In the majority of instances, however, 1 The version which took effect from 5 June 2017 see LME Notice 17 116 dated 4 April 2017 2
these have been communicated to Members in the form of an LME Notice relevant to each amendment. 6. The LME would now like to consolidate all relevant information for Traded Options into one Notice to provide clarity and ease of reference. The LME may update and issue a revised version of this Notice as and when procedures change or it is considered useful to include other information relevant to the LME Traded Options market. European Benchmarks Regulation 7. Regulation EU 2016/1011 of the European Parliament and of the Council of 8 June 2016 on indices used as benchmarks in financial instruments and financial contracts or to measure the performance of investment funds and amending Directives 2008/48/EC and 2014/17/EU and Regulation (EU) No 596/2014 (the EBR ) takes effect on 3 January 2018. The LME is currently undertaking a full assessment of (a) which of its prices, if any, will constitute benchmarks for the purposes of the EBR, (b) any mitigating action which the LME may need to take to ensure that relevant prices are out of scope of the EBR, and (c) any changes to rules, Notices, policies and procedures for any prices which may be in scope for the purposes of the EBR. The LME intends to issue further communication on this in due course. This may require changes to the LME s rules relating to Traded Options. Nevertheless, the LME considers that it is helpful for the market to issue this Notice at the current time, to set out in one place all the requirements relating to Traded Options as they stand pre-implementation of the EBR. It will therefore be more straightforward to make any changes which may be required for the EBR. Tradable Strike Prices for Clearing Currencies 8. The tradable Strike Price gradations have traditionally been set to reflect the underlying price of the metal in its clearing currency. Current Strike Price gradations for each clearing currency are set out as follows: a) USD/EUR All Metals USD/EUR 25 gradations for strikes between USD/EUR 25 up to USD/EUR 9975 USD/EUR 50 gradations for strikes between USD/EUR 10000 up to USD/EUR19950 USD/EUR 100 gradations for all strikes over USD/EUR 20000 3
b) Sterling (GBP) Aluminium, Aluminium Alloy, Copper and NASAAC GBP 25 gradations for all strikes Nickel and Tin GBP 50 gradations for all strikes Lead and Zinc GBP 20 gradations for all strikes c) YEN Aluminium, Aluminium Alloy, Copper, NASAAC and Zinc YEN 10000 gradations for strikes between YEN 10000 up to YEN 390000 YEN 20000 gradations for strikes over YEN 400000 Nickel and Tin YEN 20000 gradations for all strikes over YEN 20000 Lead YEN 5000 gradations for all strikes between YEN 5000 up to YEN 245000 YEN 10000 gradations for all strikes over YEN 250000 9. LME Traded Average Price Options (TAPOs) are only clearable in USD and have Strike Price gradations of USD 1.00. Premiums 10. The minimum permitted spread between buyers' and sellers' premiums bid or offered in respect of Metal Options, and the minimum fluctuation in such premiums, is USD 0.01 per tonne, EUR 0.01 per tonne. GBP 0.01 per tonne and YEN 0.01 per tonne. For TAPOs, this is USD 0.01 per tonne. However, the LME may from time to time change the prescribed levels according to the currency in which the Metal Option and TAPO is denominated. 11. The amount of the premium payable on opening every Metal Option or TAPO shall be determined between Granter and Taker. 12. Payment of the premium by the Taker of a Metal Option or TAPO to the Granter shall be effected through the payment system, in accordance with the Clearing 4
House Rules, prior to 12.00 hours on the next Business Day following the day on which the Metal Option or TAPO is traded. Declaration Process 13. The declaration process for Metal Options and TAPOs is set out in Part 5 of the LME Rulebook which is available at https://www.lme.com/engb/regulation/rules/rulebook/. 14. The Clearing House (LME Clear) will partially auto-exercise overnight the deep in the money Metal Options up to two Strike Prices above and below the at-themoney Strike Prices, based on publicly available LME Closing Prices (for the third Wednesday Prompts Dates) established at the end of the day before the Last Declaration Day. The partial auto-exercise by LME Clear is designed to assist the expiry process and to provide maximum flexibility for managing pin risks from market movements on floating third Wednesday Prompt Date prices that are prevailing on Declaration Day. 15. Metal Options are therefore only partially automatically exercised based on Closing Prices established the day before Declaration Day. Clearing Members have until 11.15 hours the following morning (on the first Wednesday of the expiry month) to decide how to deal with those Metal Options around the prevailing at-the-money Strike Prices. LME Clear s clearing system (LMEmercury) allows Clearing Members to exercise Metal Options that had been abandoned and/or to abandon Metal Options that had been previously auto- exercised. The decision whether to exercise or abandon a Metal Option close to the prevailing at-the-money Strike Price is a trading decision that should normally be taken by trading staff or should be based on instructions taken from Clients. This must be done in good time to ensure that the declarations are executed correctly and on time by the 11.15 hours deadline. Each Clearing Member needs to have in place appropriate staff that understand the operational functionalities of the system and have procedures that will ensure that they can handle Metal Option declarations efficiently. 16. The Clearing Member is solely responsible and liable for submitting correct exercise instructions to LME Clear: neither the LME nor LME Clear shall have any liability for errors in exercise instructions or failure to exercise. Nevertheless, LME Clear s staff will generally try to help Members spot any manifest errors before the declaration deadline of 11.15 hours. The Metal Options assignment report is run at precisely 11.15 hours in order that the assignments can be reported as soon as possible after 11.15 hours and no later than 11.30 hours. Once the assignment report is published, it is final and the only way to correct an error is for the participant to seek and negotiate bilaterally with counterparties in the market on the other side to trade out of the positions. 5
Reporting of Matched Trades 17. In a consultation in May 2016 the LME proposed to amend the reporting threshold for the deferred publication of Metal Options. 18. The LME took into consideration the Market in Financial Instruments Directive 2 (MiFID II) proposals with regard to exemptions for large in scale transactions. Exemptions from certain post-trade transparency requirements would be considered only for those trades that represent 20% of the total number of trades, and this level was used to inform discussions with both market participants and the Traded Options Committee. 19. Following feedback from the consultation the implementation of the revised thresholds took effect from Monday 15 August 2016 in accordance with the following reporting levels: Metal From To Primary Aluminium 100 lots or more Over 1000 lots Copper 100 lots or more Over 500 lots Zinc 100 lots or more Over 500 lots Lead 100 lots or more Over 500 lots Nickel 100 lots or more Over 500 lots Aluminium Alloy 100 lots or more Over 500 lots NASAAC 100 lots or more Over 500 lots Tin 100 lots or more Over 100 lots 20. The LME will review these threshold levels from time to time with market participants and the Traded Options Committee, consulting members and other interested parties on any proposed changes in the future where it deems necessary. 21. In a subsequent consultation in November 2016, the LME consulted on the following five proposals aimed at strengthening and enhancing the procedure of reporting Traded Options market data, encourage growth of the Traded Options 6
market more generally, and delivering a consistent approach to the real-time reporting of transactions for both Metal Futures and Traded Options: a) Introduce the real time reporting of Traded Options on the real time market data feed LMEselectMD; b) Removing the large trade deferral of 2 business days for volume reports and trades published on LMEselectMD; c) Decommissioning the batched options matched trades reports; d) Reporting options open interest on the next business day; and e) Introduce the reporting of Client Futures matched trades. 22. Having reviewed and analysed the feedback received in respect of the five proposals, the LME announced in January 2017 that it would be implementing the following: a) Introduce the real time reporting of Traded Options on the real time market data feed LMEselectMD The reporting of Traded Options will change to real time reporting on the market data feed LMEselectMD from Monday 15 May 2017. b) Removing the large trade deferral of 2 business days for volume reports and trades published on LMEselectMD The LME will not be removing this facility, and it will therefore continue with the current approach to the reporting of large trades. Further, it will apply to the Financial Conduct Authority ( FCA ) for a deferral, as provided for by the Market in Financial Instrument Regulation (MiFID II), with a view that the deferral in publication of large trades continues after MiFID II comes into effect in January 2018. It should be noted the granting of any deferral cannot be guaranteed, but the LME will provide further details on this process in due course. c) Decommissioning the batched options matched trades reports Batched options matched trade reporting will be decommissioned and matched trades, excluding large deferred trades, will be published real time via the LMEselectMD data feed from Monday 15 May 2017. 7
d) Reporting Options Open Interest on the next business day The LME is keen to keep the reporting of open interest in line with matched trades, therefore any changes will be subject to the outcome of the deferred large trade waiver application to the FCA, noted above in (b). Therefore, there will be no change to the current process until such time as the deferred large trade publication waiver would come into effect i.e. January 2018 with the introduction of MiFID II. Should a waiver be granted by the FCA in respect of the above, the LME will move the publication of options open interest to ensure it stays aligned with the publication of large deferred trades. This may be the subject of future consultation with Members. e) Introduce the reporting of Client Futures matched trades The LME will introduce the reporting of Client Futures matched trades to ensure consistency in data dissemination across both futures and options. This will occur in the second half of 2017, with further details being provided in due course. Procedures and Methodology Traded Options 23. In September 2008 the LME consulted on proposals to define the at-the-money delta and require options volatilities contributions to include option strikes away from the money (wings) in addition to the at-the-money strikes. The LME believes publishing the wing volatilities data provides better price transparency to reflect the volatility skews that may be present in each of these series. 24. After collating responses the LME announced in October 2008 that the at-themoney should be defined as 50 delta instead of the forward price being the strike. The reason to use 50 delta was that it is centred in between the -/+ 25 deltas and for long dated options, the strikes for the underlying forward may be too close to 25 delta or even cross it. Therefore if interpolations (whether linear or non-linear) are being applied to derive volatility skews, 50 delta in the middle for the at-the-money would ensure we will obtain better results. 8
25. The additional four deltas -/+ 10 and -/+25 proposed were approved as they are the most commonly quoted on the LME, with active options trading members already quoting and marking to a volatility surface. 26. In July 2015, resulting from a review on its methodology used for determining the Closing Prices for the Traded Options market, the LME set out an enhancement to strengthen and support the procedure for the establishment of the Closing Prices by requiring members to complete the Traded Volatility field in LMEsmart for Exchange Option Contracts 2. The requirement subsequently became mandatory with effect from 26 October 2015. 27. Consequently, since 26 October 2015 Members have been required to input the traded volatility into the Traded Volatility field in LMEsmart (Tag 5678 in the LMEsmart Fix Specification) when matching or registering Cleared Option Contracts transacted in US dollars. 28. The futures hedge (F) should be input to the Traded Volatility field before the traded volatility (V) without any decimal points or punctuation marks. The traded volatility should be input immediately after the futures hedge expressed as a four digit percentage with a decimal point after the first two digits. For example, a Cleared Option Contract that has traded with a volatility of 18.50% with a corresponding futures hedge of US dollar 5,675 should be input and registered as 567518.50 (i.e. FFFFVV.VV); or a traded volatility of 16.00% with a corresponding futures hedge of US dollar 12750.75 should be input and registered as 127507516.00 (i.e. FFFFFFFVV.VV). 29. The data field used for the traded volatility and the futures hedge is not a mandatory matching field for Cleared Option Contracts and each Member will only be able to see the information relevant to its own company. The input of this data is mandatory for the purpose of supplying traded information to the LME Trading Operations department and will be used to assist the valuation procedure. The LME Matching Operations and Market Surveillance teams will also have access to the information in this data field. 2 i.e. what now constitute Cleared Options Contracts pursuant to the version of the Rules which takes effect on 22 May 2017 - see LME Notice 17 116 dated 4 April 2017 9
30. The LME believes that the use of traded data for Cleared Option Contracts will enhance the quality of the volatility surface used by Trading Operations when analysing Member submissions. This will also provide the LME with additional price transparency and clarity for Member-to-Member transactions that have been traded throughout the day. 31. In a consultation in September 2016, the LME consulted on the following four proposals aimed at widening the reach of participation and ensuring the pricing procedures remain as robust as possible to take into account overall levels of market activity: a) the introduction of Client volatility contributions; b) the introduction of a wider window for volatility contributions; c) the introduction of a mandatory requirement for Members who are active in options to submit additional data for all delta points for the front three months for the relevant Metal Option series; and d) clarification of the sources used to reference market activity. 32. Having reviewed and analysed the feedback received in respect of the four proposals, the LME announced in October 2016 that it would be implementing the following: a) Voluntary Client contributions Clients who are active in the Traded Options market are invited by the LME to contribute volatilities on a daily basis. These contributions could be for any of the five delta points that the LME collects (i.e.-10,-25, +50, +25, and 10) in any Metal Options series for which the Client is active. Any Client who is invited by the LME to contribute volatilities may result in a Member acting on behalf of that Client being granted a waiver. This will be at the absolute discretion of the LME. b) Widening the submission window for volatility contributions The contribution window in LMEprism will be amended to open from 9.00 am in the morning and close at 5.15 pm after the PM Kerb. The LME will look to publish the provisional Closing Prices at around 5.25 pm after it has reviewed and validated all contributions. The formal review or objection period for Members and Clients will remain open until 5.45 pm. 10
The LME will make the relevant system changes to LMEprism, and other in-house systems, to allow for the widening of the submission window for volatility contributions, advising Members of the date of this change in due course. c) The mandatory requirement for members to contribute volatility quotes across the five designated delta points for the front three months for the relevant Option series Members who are obliged to contribute volatilities for Copper, Primary Aluminium or Zinc Metal Options by reaching the 1% threshold shall be obliged to submit volatility quotes for each of the five designated delta points for the front three months. Failure to comply with this obligation may result in that Member being subject to LME disciplinary procedures. Any Client who is invited to submit, but whose submissions are not used by the LME because they are deemed to be unreflective of prevailing volatilities in the market, will not result in any disciplinary procedures being taken against the Client and the Member acting on their behalf. This new obligation took effect from Monday 12 December 2016. The LME will review the effectiveness of this requirement and if appropriate, extend this to other Metal Option Contracts. d) Clarification of the sources used to reference market activity The LME has formalised the existing process to use quotes and trades from all LME trading venues as the source used to reference current market activity. 33. The current procedures used for the determination of the Closing Prices for Traded Options are as follows: a) In accordance with the LME Rulebook, if a Member is active in a particular Metal Option at any time as determined by the LME, it shall be obliged to submit closing volatilities to the LME for the purpose of the clearing house valuations, if requested; b) The LME reviews trading activity on a quarterly basis and if a Member trades 1% or more of total volume for a particular metal then it will formally request the Member to participate in the valuation process; 11
c) Volatility contributions from Members are collected by LMEprism (launched on Monday 2 November 2015 to replace LMEcvrs) between 3.30 pm and 4.45 pm. These contributions are collected in delta space across five points, i.e. -10, -25, +50, +25, +10, for each Metal Option series; d) A Member is not required to contribute volatility quotes for all tradeable months for the relevant Metal Option if it feels it is unable to supply a full and/or accurate set of data; e) Voluntary contributions can be accepted from Members, at the discretion of the LME, if the LME feels that this would lead to an improved set of data; f) Members who are obliged to contribute under the 1% rule but feel they are not qualified because of the nature of their business may ask the LME for a waiver; g) When all Member contributions have been collected in LMEprism, the system will calculate an average volatility value for each delta point for each Metal Option series; h) The LME will remove any data errors, outliers or stale data using its absolute discretion to ensure the contributions are representative of current market levels; i) The LME will also validate volatility contributions against the mandatory input of traded data in the Traded Volatility field for Cleared Option Contracts in LMEsmart; j) The calculated report for the provisional Closing Prices is published to contributing Members in LMEprism at approximately 5.00 pm; k) When Members have viewed the published provisional report, they have until 5.30 pm to object by selecting the Metal Option series and individual month and inserting a comment that provides the grounds for an 12
objection. The Exchange will circulate any objections to Members for feedback and the objection is then accepted or rejected by the Exchange; and l) The Exchange will transmit the final Closing Prices to LME Clear at around 5.50 pm so they can be used for daily margining calculations. LME Traded Average Price Options (TAPOs) 34. LME TAPOs are monthly options based on daily averaged futures, with the volatility surface based on the Traded Options volatility surface. Traded Options expire on the first Wednesday of each month, whilst TAPOs expire on the last business day of the month. Due to these differences the LME bases the TAPOs closing volatilities on the Traded Options volatility surface subject to a date weighted adjustment applied to Traded Options volatilities for use within the LME TAPO model. 35. Following positive feedback from a Member consultation in April 2011, in Q1 2012 the LME began to calculate and publish TAPO wing volatilities (-10, -25, 50, +25 +10 deltas), their raw ungraded strikes and premiums in line with Traded Options through its new pricing system LMEprice. 36. The LME adopted the same pricing model used by LCH.Clearnet at the time, but split the calculation into two transparent steps instead of a black box. Whilst both approaches produce the same results, the advantage of split steps is that numbers in the output of the TAPO volatility from the pre-processor will be visible making the process easier to operate, manage and verify. 37. Once calculated the LME pass the resulting set of TAPO strikes for each of the TAPO series to LME Clear for its daily margin calculations. Financial Penalties 38. On 6 January 2016 the LME released a Guidance Notice regarding financial penalties for business processing and reporting arrangements which would come into effect from June 2016 (see Notice 16 006 A006). 39. The Guidance Notice sets out the following indicative fines for reporting of options volatilities: 5 errors or more in a calendar month: 1,000 for first offence, 13
2,000 for a second offence, and 5,000 for each offence thereafter within a 24 month rolling period. An offence may include a failure to report as well as errors in what has been reported. 40. Significant or persistent breaches of the reporting requirements will be considered to be a disciplinary offence and Members who are found to be in violation of the requirements may be subject to the LME s disciplinary process. 41. This might include (without limitation) submitting volatilities that are significantly away from the market or which are otherwise erroneous. Peter Childs Head of Trading Operations cc: Board directors Trading Options Committee Trading Committee 14