text:
Self-Regulatory Organizations; The Options Clearing Corporation; Notice of Filing of Advance Notice Related to the Introduction of a New Liquidation Cost Model in The Options Clearing Corporation's Margin Methodology
A Notice by the Securities and Exchange Commission on 05/21/2019
Agency/Docket Numbers:
Release No. 34-85863
File No. SR-OCC-2019-802
I. Clearing Agency's Statement of the Terms of Substance of the Advance Notice
II. Clearing Agency's Statement of the Purpose of, and Statutory Basis for, the Advance Notice
(A) Clearing Agency's Statement on Comments on the Advance Notice Received From Members, Participants or Others
(B) Advance Notices Filed Pursuant to Section 806(e) of the Payment, Clearing, and Settlement Supervision Act
Description of the Proposed Change
Proposed Changes
1. Portfolio Decomposition and Creation of Sub-Portfolios
2. Creation and Calibration of Liquidation Grids
3. Vega Liquidation Cost
Vega Liquidation Cost Calculation
Minimum Liquidation Cost
4. Delta Liquidation Cost
5. Concentration Charges
6. Volatility Correlations
7. STANS Margin Floor
8. Margin Policy and Stress Testing and Clearing Fund Methodology Description
Clearing Member Outreach
Expected Effect on and Management of Risk
Consistency With the Payment, Clearing and Settlement Supervision Act
III. Date of Effectiveness of the Advance Notice and Timing for Commission Action
IV. Solicitation of Comments
Electronic Comments
Paper Comments
https://www.federalregister.gov/d/2019-10522 https://www.federalregister.gov/d/2019-10522
This PDF is the current document as it appeared on Public Inspection on 05/20/2019 at 8:45 am.
If you are using public inspection listings for legal research, you should verify the contents of the documents against a final, official edition of the Federal Register. Only official editions of the Federal Register provide legal notice to the public and judicial notice to the courts under 44 U.S.C. 1503 & 1507. Learn more here.
Start Preamble May 15, 2019.
Pursuant to Section 806(e)(1) of Title VIII of the Dodd-Frank Wall Street Reform and Consumer Protection Act, entitled Payment, Clearing and Settlement Supervision Act of 2010 ("Clearing Supervision Act") [1] and Rule 19b-4(n)(1)(i) [2] under the Securities Exchange Act of 1934 ("Exchange Act"),[3] notice is hereby given that on April 18, 2019, the Options Clearing Corporation ("OCC") filed with the Securities and Exchange Commission ("Commission") an advance notice ("Advance Notice") as described in Items I, II and III below, which Items have been prepared by OCC. The Commission is publishing this notice to solicit comments on the advance notice from interested persons.
This advance notice is submitted in connection with proposed changes to OCC's Margins Methodology, Margin Policy, and Stress Testing and Clearing Fund Methodology Description to add a risk-based liquidation charge based on bid-ask spreads to adjust the value of positions to account for the costs of liquidating a defaulting Clearing Member's portfolio. The proposed changes to OCC's Margins Methodology, Margin Policy, and Stress Testing and Clearing Fund Methodology Description are contained in confidential Exhibits 5A-5C of the filing. Material proposed to be added is marked by underlining and material proposed to be deleted is marked by strikethrough text. OCC also has included a summary of impact analysis of the proposed model changes in confidential Exhibit 3. The proposed changes are described in detail in Item II below.
The advance notice is available on OCC's website at https://www.theocc.com/about/publications/bylaws.jsp. All terms with initial capitalization that are not otherwise defined herein have the same meaning as set forth in the OCC By-Laws and Rules.[4]
In its filing with the Commission, OCC included statements concerning the purpose of and basis for the advance notice and discussed any comments it received on the advance notice. The text of these statements may be examined at the places specified in Item IV below. Start Printed Page 23091OCC has prepared summaries, set forth in sections A and B below, of the most significant aspects of these statements.
Written comments were not and are not intended to be solicited with respect to the advance notice and none have been received. OCC will notify the Commission of any written comments received by OCC.
OCC's margin methodology, the System for Theoretical Analysis and Numerical Simulations ("STANS"), is OCC's proprietary risk management system that calculates Clearing Member margin requirements.[5] STANS utilizes large-scale Monte Carlo simulations to forecast price and volatility movements in determining a Clearing Member's margin requirement.[6] The STANS margin requirement is calculated at the portfolio level of Clearing Member legal entity marginable net positions tier account (tiers can be customer, firm, or market marker) and consists of an estimate of a 99% 2-day expected shortfall ("99% Expected Shortfall") and an add-on for model risk (the concentration/dependence stress test charge). The STANS methodology is used to measure the exposure of portfolios of options and futures cleared by OCC and cash instruments in margin collateral.
STANS margin requirements are comprised of the sum of several components, each reflecting a different aspect of risk. The base component of the STANS margin requirement for each account is obtained using a risk measure known as 99% Expected Shortfall. Under the 99% Expected Shortfall calculation, an account has a base margin excess (deficit) if its positions in cleared products, plus all existing collateral—whether of types included in the Monte Carlo simulation or of types subjected to traditional "haircuts"—would have a positive (negative) net worth after incurring a loss equal to the average of all losses beyond the 99% value at risk (or "VaR") point. This base component is then adjusted by the addition of a stress test component, which is obtained from consideration of the increases in 99% Expected Shortfall that would arise from market movements that are especially large and/or in which various kinds of risk factors exhibit perfect or zero correlations in place of their correlations estimated from historical data, or from extreme adverse idiosyncratic movements in individual risk factors to which the account is particularly exposed.[7] STANS margin requirements are intended to cover potential losses due to price movements over a two-day risk horizon; however, the base and stress margin components do not cover the potential liquidation costs OCC may incur in closing out a defaulted Clearing Member's portfolio.[8] Closing out positions in a defaulted Clearing Member's portfolio could entail selling longs at bid price and covering shorts at ask price. This means that additional liquidation costs may need to take into account the bid-ask price spreads.
OCC is proposing to enhance its margin methodology by introducing a new model to estimate the liquidation cost for all options and futures, as well as the securities in margin collateral. As noted above, closing out positions of a defaulted Clearing Member in the open market could entail selling longs at bid price and covering shorts at ask price. These closing-out costs are currently not taken into account in STANS for all options (with the exception of long-dated SPX index option series, as noted above).[9] Therefore, the purpose of the proposed change is to add additional financial resources in the form of margin, based on liquidation cost grids calibrated using historical stressed periods, to guard against potential shortfalls in margin requirements that may arise due to the costs of liquidating Clearing Member portfolios in the event of a default. The liquidation cost charge would be applied as an add-on to all accounts incurring a STANS margin charge.
The proposed liquidation cost model calculates liquidation cost based on risk measures, gross contract volumes and market bid-ask spreads. In general, the proposed model would be used to calculate two risk-based liquidation costs for a portfolio, Vega [10] liquidation cost ("Vega LC") and Delta liquidation cost ("Delta LC"), using "Liquidation Grids." [11] Options products will incur both Vega and Delta LCs while Delta-one [12] products such as futures contracts, Treasury securities and equity securities, will have only a Delta charge.
The proposed liquidation cost model described herein would include: (1) The decomposition of the defaulter's portfolio into sub-portfolios by underlying security; (2) the creation and calibration of Liquidation Grids used to determine liquidation costs; (3) the calculation of the Vega LC (including a minimum Vega LC charge) for options products; (4) the calculation of Delta LCs for both options and Delta-one products; (5) the calculation of Vega and Delta concentration factors; (6) the calculation of volatility correlations for Vega LCs; (7) the establishment of a STANS margin floor based on the liquidation cost; and (8) conforming changes to OCC's Margin Policy and Stress Testing and Clearing Fund Methodology Description.
The new liquidation cost model would cover the following cleared products in a Clearing Member's portfolio: Options on indices, equities, Exchange Traded Funds ("ETFs") and futures; FLEX options; future contracts; Treasury securities; and stock loan and collateral securities. The securities not included in STANS margin calculations would not be covered by the new model.
The proposed approach to calculating liquidation costs and the conforming changes to OCC's Margin Policy are described in further detail below.Start Printed Page 23092
For a portfolio consisting of many contracts and underlyings, the proposed model would first divide (or decompose) the portfolio into sub-portfolios by underlying security such that all contracts with the same underlying are grouped into the same sub-portfolio. The Vega LC and Delta LC are first calculated at a sub-portfolio level and then aggregated to derive the final liquidation cost for the total portfolio. All the option positions with the same fundamental underlying would form one sub-portfolio because they share the same risk characteristics. The equity index, index future and index ETFs would all be categorized by the underlying index that is the basis for the index, future, and ETF-underlying securities. The corresponding options on the index, index future, and ETFs would therefore fall into the same sub-portfolio. In addition, FLEX options on the same underlying would be included in the same sub-portfolio of the regular options. Similarly, cash products such as equities and futures would be grouped in the same sub-category based on their underlying symbols. All Treasury security positions would form one sub-portfolio. The calculation of Vega LC and Delta LC for each sub-portfolio is summarized in the next sections.
A key element of the proposed liquidation cost model is the "Liquidation Grids." The calculations of Vega LC and Delta LC involve a number of liquidity-related quantities such as volatility bid-ask spreads, price bid-ask spreads, Vega notional, and Delta notional. The collection of these quantities would be used to create the following Liquidation Grids.
1. Vega Liquidation Grids (or volatility grids): The Vega Liquidation Grids would represent the level of bid-ask spreads on the implied volatility of option contracts for a given underlying. Since the volatility spreads of option contracts vary by the Delta and tenor of the option, OCC would divide the contracts into several Delta buckets by tenor buckets.[13] Each pair (Delta, tenor) is referred to as a Vega bucket. For each bucket, an average volatility spread is estimated and defined as the volatility grid for the bucket. The size of grid would essentially represent the cost for liquidating one unit of Vega risk in the bucket.
2. Vega Notional Grid: The Vega Notional Grid of an underlying security would be the average trading options volume weighted by the Vega of all options on the given underlying. The size of Vega Notional grids would indicate the average daily trading volume in terms of dollar Vegas (i.e., the Vega multiplied by the volume of the option).
3. Delta Liquidation Grid: The Delta liquidation grid would represent an estimated bid-ask price spread (in percentage) on the underlying.[14] It represents the cost of liquidating one dollar unit of the underlying security. The Delta liquidation grid for Treasury securities represents bid-ask yield spreads, expressed in basis points.
4. Delta Notional Grid: The Delta Notional grid of an underlying security would represent the average trading volume in dollars of the security.[15]
Vega Notional Grids are calibrated at the security level; that is, each individual underlying security would have its own Vega Notional. The Delta Notional Grid and both Vega and Delta Liquidation Grids for all underlying securities are estimated at the levels of a fixed number of classes based on their liquidity level.[16] All equity securities would be divided, based on their membership in commonly used market indices (including, but not limited to, the S&P 100 and 500 index) or other market liquidity measurements, into liquidity classes (which may include, but are not limited to, High Liquid Equities, Medium Liquid Equities and Low Liquid Equities). Any new equity security would generally default to the lowest liquidity classification unless otherwise assigned to a higher liquidity classification when deemed necessary. Major indices (e.g., SPX or the Cboe Volatility Index ("VIX")) may form their own index liquidity class, which may cover indices, index ETFs, and index futures. In addition, sector ETFs, ETFs on a major commodity (such as Gold, Crude/Natural Gas, Metals, and Electricity), and Treasury ETFs would generally each form individual classes of their own, subject to the availability of liquidation data. Pursuant to the proposed Margins Methodology, these liquidity classes would be reviewed annually or at a frequency determined by OCC's MRWG and updated as needed, taking into consideration such factors including, but not limited to, changes in membership of the S&P 100 index and S&P 500 index, listing and delisting of securities, and any corporate actions on the existing securities.
Because the bid-ask spreads can change daily, the use of spreads from current market conditions could cause liquidation costs to fluctuate dramatically with market volatility, especially during a stressed market period. To mitigate this procyclicality issue, Liquidation Grids would be calibrated from several historical stressed periods, which are selected based on the history of VIX index levels and would remain unchanged with time until a new stressed period is selected and added to the calibrations in accordance with the requirements of the proposed Margins Methodology.[17]
Vega LC is the main component of the proposed liquidation cost model. For a simple option contract, the Vega LC would be its position Vega multiplied by its respective bucket in the Vega Liquidation Grid. The result is approximately equal to one half of the bid-ask price spread. For a portfolio consisting of many contracts and underlyings, the model first divides the portfolio into sub-portfolios by underlying security such that all contracts with the same underlying are grouped into the same sub-portfolio (as described above). The Vega LCs for sub-portfolios are calculated first and then aggregated to derive the Vega LC for the total portfolio.Start Printed Page 23093
The Vega LC for a sub-portfolio, which consists of all the contracts with the same underlying security, would be calculated in several steps. First, the Liquidation Grids would be calibrated for Vega "buckets" that consist of Delta bins by tenor bins as discussed above. These Vega buckets are used to represent the volatility risk at the different areas on the implied volatility surface. Next, the Vega of each contract position in a given sub-portfolio would be calculated and bucketed into one of the Vega buckets. The Vegas falling into the same Vega bucket would then be netted. The Vega LC for each of the Vega buckets is calculated as the net Vega multiplied by the Vega grid of the buckets. Finally, the total liquidation cost for the sub-portfolio would be aggregated from these bucket Vega LCs by using correlations between the Vega buckets. Since the sub-portfolios are formed by the fundamental equity or index underlying the option, the Vega LCs of closely related but different underlying securities are allowed to net. For example, Vega LCs for SPX and related indices, futures, and ETFs that are based on the S&P 500 index would be allowed 100% netting.
The Vega LC for the total portfolio would be a similar correlation-based sum of Vega LCs of all the sub-portfolios, taking into account correlations between the products' implied volatility.[18]
Because the proposed model allows risk netting across closely related option contracts, it is possible that a well-hedged option strategy could result in a very small or zero liquidation cost. To prevent this from happening, a minimum liquidation cost would be introduced to the Vega liquidation charges. The minimum liquidation cost for a sub-portfolio would be calculated as the gross number of option contracts multiplied by a minimum cost per contract value.[19] The minimum cost amount would be calculated for the entire portfolio and would be used to floor the final total Vega LC. The proposal would not apply a minimum cost for Delta LC due to the immaterial impact a minimum Delta LC would have on the overall liquidation cost charge.
In addition to Vega risk, the model also considers the Delta risk presented in an entire portfolio. If a portfolio has positions in either options, futures, equities, or Treasury securities, it will contain some Delta risk. Under the proposed model, the liquidation cost due to Delta risk in a sub-portfolio (as defined by the underlying) would be approximated by the net dollar Delta of the sub-portfolio multiplied by its respective bucket in the Delta Liquidation Grid.
The proposed model would allow netting of Delta LC if the option contracts, futures, or equity positions belong to or are related to a top index (such as SPX or VIX). For example, in a portfolio, positions in SPX-related options, options on futures, futures, or collateral have their Delta LC netted.
Under the proposed model, U.S. dollar Treasury bonds would form one sub-portfolio. The Delta or DV01 (i.e., dollar value of one basis point) of all the bonds would be calculated and bucketed into six tenor buckets. For each bucket, the liquidation cost would be approximated by the absolute value of the net DV01 of the bucket multiplied by the Liquidation Grid (in basis points) in the corresponding tenor bucket. The total liquidation cost for the Treasury security sub-portfolio would then be a sum of the costs over all the buckets.
The Delta LC for the total portfolio would be simple sum of the Delta LCs over all sub-portfolios.
In addition to Vega and Delta LCs, the proposed model also would incorporate the potential risks involved in closing out large or concentrated positions in a portfolio. The "largeness" of an option position is typically measured in terms of Average Daily Volume ("ADV"). The Vega volume or notional, defined as "Vega-weighted ADV," is also a relevant measure of options trading volume. Closing out large or concentrated positions with one or more Vega notional may either take longer to liquidate or demand wider spreads, and therefore could incur additional cost. To cover this additional risk, the proposed model would use Vega concentration factors ("Vega CF") to scale the Vega LC for option positions. The Vega CFs would be equal to one for small positions that are less than one Vega notional, but may be scaled up for large positions as a function of the size of the positions. Similar to Vega CF, Delta concentration factors ("Delta CF") would be used to scale the Delta LC to account for the concentration risk associated with large Delta positions.
Under the proposed model, the Vega LC for each underlying sub-portfolio is calculated using correlations between the Vega buckets. The correlation matrix from the most liquid product (SPX) would be used as the base and would be scaled for other underlyings based on their liquidity class. These would be calibrated from time periods that overlap the stress periods used to calculate Liquidation Grids.
To aggregate the liquidation cost at the portfolio level, the pair-wise correlations of implied volatilities between different underlyings are needed. OCC would use a single correlation value for all cross-underlying correlations rather than a correlation matrix for all cross-underlying correlations to simplify the calibration of the grids. To account for potential errors that may arise from using a single correlation value, OCC would calculate three single correlations representing the minimum, average, and maximum correlation across the liquidity class to determine three different Vega LCs. The highest of these three Vega LCs would be used as the final Vega LC.
The proposed liquidation costs would be added to the base and stress margin components of STANS that are intended to cover the potential losses due to price movements over a two-day risk horizon. In certain cases, well-hedged portfolios may not experience any loss and the resultant STANS margin requirement is close to zero or may even become positive in some extreme cases. If the STANS requirement is positive, this may result in a credit instead of a charge for the Clearing Member. To account for the risk of potentially liquidating a portfolio at current (instead of two-day ahead) prices, no credit from the margin would be allowed so that the final margin requirement would not be lower than the amount of the liquidation cost.
OCC also would make conforming changes to its Margin Policy and Stress Testing and Clearing Fund Methodology Description to reflect the inclusion of the new liquidation cost charge as an add-on charge to the base STANS margin and how the liquidation cost Start Printed Page 23094charge add-on would be incorporated in Clearing Fund shortfall calculations.[20]
To inform Clearing Members of the proposed change, OCC has provided overviews of its proposed liquidation cost model to the Financial Risk Advisory Council ("FRAC"), a working group comprised of exchanges, Clearing Members and indirect participants of OCC, and the OCC Roundtable, which was established to bring Clearing Members, exchanges and OCC together to discuss industry and operational issues,[21] during 2016 and 2017. OCC has also published Information Memos to all Clearing Members discussing the proposed change.
Under the proposed liquidation cost model, each Clearing Member/account would independently observe different levels of impact based on the composition of their cleared portfolios. Based on OCC's analysis to-date, directional portfolios containing more outright positions, which are more typically associated with customer accounts, are most likely to see the largest impact from the proposed liquidation cost charges, while more well-hedged portfolios, such as market maker accounts, would be less impacted (and are more likely to incur the minimum liquidation cost charge). In the aggregate, OCC expects the proposed liquidation cost charges to make up approximately 5-8% of total risk margin charges, with customer accounts accounting for roughly 60% of the proposed liquidation cost charges, and proprietary accounts and market markers generating approximately 25% and 15% of the proposed liquidation cost charges, respectively.
Given the magnitude of expected changes in margins, OCC expects to conduct an extended parallel implementation for Clearing Members prior to implementation. Additionally, OCC will perform additional outreach to the FRAC upon submission of its regulatory filings to remind Clearing Members of the pending changes and direct outreach with those Clearing Members that would be most impacted by the proposed change and would work closely with such Clearing Members to coordinate the implementation and associated funding for such Clearing Members resulting from the proposed change.[22]
OCC expects to implement the proposed changes no sooner than thirty (30) days and no later than one hundred eighty (180) days from the date that OCC receives all necessary regulatory approvals for the filings. OCC will announce the implementation date of the proposed change by an Information Memo posted to its public website at least two (2) weeks prior to implementation.
OCC believes that the proposed change, which would introduce a new liquidation cost model into OCC's margin methodology, would reduce the overall level of risk to OCC, its Clearing Members, and the markets served by OCC. As described above, STANS margin requirements are comprised of the sum of several components, each reflecting a different aspect of risk. These margins are intended to cover the potential losses due to price movements over a two-day risk horizon; however, the base and stress margin components do not cover the potential liquidation cost OCC may incur in closing out a defaulted Clearing Member's portfolio. Closing out positions in a defaulted portfolio could entail selling longs at bid price and covering shorts at ask price. This means that additional liquidation costs may need to take into account the bid-ask price spreads. The proposed liquidation cost model would calculate liquidation costs for OCC's cleared products based on risk measures, gross contract volumes and market bid-ask spreads. The proposed model is designed to provide additional financial resources in the form of margin, based on liquidation costs and current market prices, to guard against potential shortfalls in margin requirements that may arise due to the costs of liquidating Clearing Member portfolios. OCC uses the margin it collects from a defaulting Clearing Member to protect other Clearing Members from losses they cannot anticipate or control as a result of such a default. As a result, OCC believes the proposed changes would reduce the overall level of risk to OCC, its Clearing Members, and the markets served by OCC.
The stated purpose of the Clearing Supervision Act is to mitigate systemic risk in the financial system and promote financial stability by, among other things, promoting uniform risk management standards for systemically important financial market utilities and strengthening the liquidity of systemically important financial market utilities.[23] Section 805(a)(2) of the Clearing Supervision Act [24] also authorizes the Commission to prescribe risk management standards for the payment, clearing and settlement activities of designated clearing entities, like OCC, for which the Commission is the supervisory agency. Section 805(b) of the Clearing Supervision Act [25] states that the objectives and principles for risk management standards prescribed under Section 805(a) shall be to:
Promote robust risk management;
promote safety and soundness;
reduce systemic risks; and
support the stability of the broader financial system.
OCC believes that the proposed changes described herein would enhance its margin methodology in a manner consistent with the objectives and principles of Section 805(b) of the Clearing Supervision Act [26] and the risk management standards adopted by the Commission in Rule 17Ad-22 under the Act for the reasons set forth below.[27]
OCC believes the proposed changes are consistent with the objectives and principles of Section 805(b) of the Clearing Supervision Act.[28] As described above, STANS margin requirements are comprised of the sum of several components, each reflecting a different aspect of risk. These margins are intended to cover the potential Start Printed Page 23095losses due to price movements over a two-day risk horizon; however, the base and stress margin components do not cover the potential liquidation cost OCC could incur in closing out a defaulted Clearing Member's portfolio. Closing out positions in a defaulted portfolio could entail selling longs at bid price and covering shorts at ask price. This means that additional liquidation costs may need to take into account the bid-ask price spreads. The proposed model is designed to provide additional financial resources in the form of margin to guard against potential shortfalls in margin requirements that may arise due to the costs of liquidating Clearing Member portfolios. OCC uses the margin it collects from a defaulting Clearing Member to protect other Clearing Members from losses as a result of the default. As a result, OCC believes the proposed change would promote robust risk management and safety and soundness while reducing systemic risks and would thereby support the stability of the broader financial system.
Rule 17Ad-22(b)(2) [29] requires, in part, that a registered clearing agency that performs central counterparty services establish, implement, maintain and enforce written policies and procedures reasonably designed to use margin requirements to limit its credit exposures to participants under normal market conditions and use risk-based models and parameters to set margin requirements. As described above, the proposed liquidation cost model is a risk-based model that calculates liquidation cost based on risk measures, gross contract volumes, and market bid-ask spreads. The proposed model is designed to provide additional financial resources in the form of margin, based on liquidation costs and current market prices, to guard against potential shortfalls in margin requirements that may arise due to the costs of liquidating Clearing Member portfolios, which currently are not taken into account in STANS for all of OCC's cleared products. Accordingly, the proposed risk-based model would be used to calculate margin requirements designed to limit OCC's credit exposures to participants under normal market conditions in a manner consistent with Rule 17Ad-22(b)(2).[30]
Rule 17Ad-22(e)(6)(i) [31] further requires a covered clearing agency that provides central counterparty services to establish, implement, maintain and enforce written policies and procedures reasonably designed to cover its credit exposures to its participants by establishing a risk-based margin system that considers, and produces margin levels commensurate with, the risks and particular attributes of each relevant product, portfolio, and market. The proposed liquidation cost model is a risk-based model that would calculate additional margin charges designed to account for potential shortfalls in margin requirements that may arise due to the costs of liquidating Clearing Member portfolios by taking into consideration the risks and attributes associated with relevant products and portfolios cleared by OCC (e.g., volatility bid-ask spreads, price bid-ask spreads, Vega notional, and Delta notional). Accordingly, OCC believes the proposed changes are consistent with Rule 17Ad-22(e)(6)(i).[32]
The proposed change may be implemented if the Commission does not object to the proposed change within 60 days of the later of (i) the date the proposed change was filed with the Commission or (ii) the date any additional information requested by the Commission is received. OCC shall not implement the proposed change if the Commission has any objection to the proposed change.
The Commission may extend the period for review by an additional 60 days if the proposed change raises novel or complex issues, subject to the Commission providing the clearing agency with prompt written notice of the extension. A proposed change may be implemented in less than 60 days from the date the advance notice is filed, or the date further information requested by the Commission is received, if the Commission notifies the clearing agency in writing that it does not object to the proposed change and authorizes the clearing agency to implement the proposed change on an earlier date, subject to any conditions imposed by the Commission.
OCC shall post notice on its website of proposed changes that are implemented. The proposal shall not take effect until all regulatory actions required with respect to the proposal are completed.
Interested persons are invited to submit written data, views, and arguments concerning the foregoing, including whether the advance notice is consistent with the Clearing Supervision Act. Comments may be submitted by any of the following methods:
Use the Commission's internet comment form (http://www.sec.gov/rules/sro.shtml); or
Send an email to rule-comments@sec.gov. Please include File Number SR-OCC-2019-802 on the subject line.
Send paper comments in triplicate to Secretary, Securities and Exchange Commission, 100 F Street NE, Washington, DC 20549.
All submissions should refer to File Number SR-OCC-2019-802. This file number should be included on the subject line if email is used. To help the Commission process and review your comments more efficiently, please use only one method. The Commission will post all comments on the Commission's internet website (http://www.sec.gov/rules/sro.shtml). Copies of the submission, all subsequent amendments, all written statements with respect to the advance notice that are filed with the Commission, and all written communications relating to the advance notice between the Commission and any person, other than those that may be withheld from the public in accordance with the provisions of 5 U.S.C. 552, will be available for website viewing and printing in the Commission's Public Reference Room, 100 F Street NE, Washington, DC 20549 on official business days between the hours of 10:00 a.m. and 3:00 p.m. Copies of the filing also will be available for inspection and copying at the principal office of the self-regulatory organization.
All comments received will be posted without change. Persons submitting comments are cautioned that we do not redact or edit personal identifying information from comment submissions. You should submit only information that you wish to make available publicly.
All submissions should refer to File Number SR-OCC-2019-802 and should be submitted on or before June 5, 2019.
By the Commission.
Eduardo A. Aleman,
Deputy Secretary.
End Signature End Preamble
1. 12 U.S.C. 5465(e)(1).
Back to Citation
2. 17 CFR 240.19b-4(n)(1)(i).
3. 15 U.S.C. 78a et seq.
4. OCC's By-Laws and Rules can be found on OCC's public website: http://optionsclearing.com/about/publications/bylaws.jsp.
5. See Securities Exchange Act Release No. 53322 (February 15, 2006), 71 FR 9403 (February 23, 2006) (SR-OCC-2004-20). A detailed description of the STANS methodology is available at http://optionsclearing.com/risk-management/margins/.
6. See OCC Rule 601.
7. STANS margins may also include other add on charges, which are considerably smaller than the base and stress test components, and many of which affect only a minority of accounts.
8. A liquidation cost model was introduced into STANS in 2012 as part of OCC's OTC clearing initiatives. The model is only applied to long-dated options on the Standard & Poor's ("S&P") 500 index ("SPX") that have a tenor of three-years or greater. See Securities Exchange Act Release No. 34-70719 (October 18, 2013), 78 FR 63548 (October 24, 2013) (SR-OCC-2013-16). The existing liquidation model for long-dated SPX options would be replaced by this new model. OCC currently does not have any open interest in OTC options. OCC does currently clear similar exchange traded long-dated FLEX SPX options; however, these options make up less than 0.5% of SPX options open interest.
9. Id.
10. The Delta and Vega of an option represent the sensitivity of the option price with respect to the price and volatility of the underlying security, respectively.
11. "Liquidation Grids" would be comprised collectively of Vega Liquidation Grids, Vega Notional Grids, Delta Liquidation Grids, and Delta Notional Grids. Liquidation Grids are discussed in more detail below in the Creation and Calibration of Liquidation Grids section.
12. "Delta one products" refer to products for which a change in the value of the underlying asset results in a change of the same, or nearly the same, proportion in the value of the product.
13. Initially, Vega Liquidation Grids would consist of 5 Delta buckets by 5 tenor buckets, with a total of 25 pairs; however, the Vega Liquidation Grids would be reviewed annually or at a frequency determined by OCC's Model Risk Working Group ("MRWG") and updated as needed as determined by the MRWG. The MRWG is responsible for assisting OCC's Management Committee in overseeing and governing OCC's model-related risk issues and includes representatives from OCC's Financial Risk Management department, Quantitative Risk Management department, Model Validation Group, and Enterprise Risk Management department.
14. Delta Liquidation Grids are comprised of several rows representing liquidity categories for the underlying security (initially 14 rows, subject to periodic review and modification) and one column representing the cost of liquidating one dollar unit of the underlying security. The Delta Liquidation Grids would be reviewed annually or at a frequency determined by OCC's MRWG and updated as needed as determined by the MRWG.
15. Delta Notional Grids are comprised of several rows representing liquidity categories for the underlying security (initially 14 rows, subject to periodic review and modification) and one column representing the average trading volume in dollars of the underlying security. The Delta Notional Grids would be reviewed annually or at a frequency determined by OCC's MRWG and updated as needed as determined by the MRWG.
16. Within the same liquidity group, the Vega Notional can vary dramatically from name to name. Moreover, Vega risk can be much greater than Delta risk. As a result, OCC would calculate Vega Notionals at the security level as opposed to the liquidity level.
17. The Liquidation Grids will be reviewed annually or at a frequency determined by the MRWG.
18. See infra, Volatility Correlations section.
19. The minimum cost rate would initially be set as $2 per contract, unless the position is long and the net asset value per contract is less than $2. (For a typical option with a contract size of 100, this would occur if the option was priced below 0.02.) This value would be reviewed annually or at a frequency determined by OCC's MRWG and recalibrated as needed over time.
20. The Stress Testing and Clearing Fund Methodology Description would be revised to note that the shortfall of a portfolio is calculated by offsetting its profit and loss ("PnL") in a stress scenario with its STANS margin assets, which include base margin (i.e., 99% Expected Shortfall), excess net asset value related to long option premium, any non-collateral-in-margins haircut amounts, and various other Add-On Charges such as the proposed liquidation cost charges. Since the cost of liquidation is not considered in stress scenario PnL, a charge for liquidation costs using the same values as calculated for margins is included in shortfall calculations to ensure that the liquidation cost charge is part of the required total credit financial resources.
21. The OCC Roundtable is comprised of representatives of the senior OCC staff, participant exchanges and Clearing Members, representing the diversity of OCC's membership in industry segments, OCC-cleared volume, business type, operational structure and geography.
22. Specifically, OCC will discuss with those Clearing Members how they plan to satisfy any increase in their margin requirements associated with the proposed change.
23. 12 U.S.C. 5461(b).
24. 12 U.S.C. 5464(a)(2).
27. 17 CFR 240.17Ad-22. See Securities Exchange Act Release Nos. 68080 (October 22, 2012), 77 FR 66220 (November 2, 2012) (S7-08-11) ("Clearing Agency Standards"); 78961 (September 28, 2016), 81 FR 70786 (October 13, 2016) (S7-03-14) ("Standards for Covered Clearing Agencies"). OCC is a "covered clearing agency" as defined in Rule 17Ad-22(a)(5) and therefore must comply with the requirements of Rule 17Ad-22(e).
29. 17 CFR 240.17Ad-22(b)(2).
31. 17 CFR 240.17Ad-22(e)(6)(i).
[FR Doc. 2019-10522 Filed 5-20-19; 8:45 am]


Located on the Yakima River. One hundred and seven rooms face the river. We offer free full hot american breakfast and a manager's reception. Complimentary wifi, fitness room, indoor pool and jacuzzi.
off of interstate 82, take exit 33, take a left at the light, 2nd hotel on the left.


METU Blog service utilizes WordPress, which is a freeware, as its base. Comprehensive websites and webpages within those sites can be formed easily with the use of WordPress. For detailed information and more features, you can visit the WordPress homepage.


text:
Cyber Warfare, Classic Heroes, and International Crises
By Jon Land|2018-11-26T09:36:52-04:00November 16th, 2018|Thrillers|
Jon Land is back in action giving you his top picks for November in all things thrilling and suspense. This month's picks feature some classic heroes, cyber warfare, and timely crises at an international scale. Don't miss out on any of his top seven thriller selections to pick up while you're sitting around over the holiday drowsy with Thanksgiving food.
Lee Child is at his best in Past Tense (Delacorte), as is his seminal series hero Jack Reacher.
Reacher isn't looking for trouble when he steps off a bus in Laconia, New Hampshire. The town happens to be the birthplace of his father and his intentions go no deeper than simply wanting to learn more about Stan Reacher's upbringing. Before you know it, the dark knight in not-so-shiny armor is mixing it up alternately with a mob and local strongmen, even as he happens upon the kind of sinister criminal plot he so revels in demolishing.
Past Tense contains all the ingredients that make this unquestionably the finest thriller series going today and one of the best ever. The nomadic Reacher is this era's James Bond, suitably rough around the edges and always there when some sliver of the country needs him. Exceptional storytelling in all respects.
Speaking of exceptional storytelling, and Jack Reacher, David Baldacci may well have created Reacher's female counterpart in Atlee Pine, an FBI agent with an especially haunted past, who visits demons both new and old in Long Road to Mercy (Grand Central).
But don't let the fact that she's with the FBI fool you; Atlee is no stranger to doing whatever it takes to see justice done, a penchant rooted in the kidnapping that stole both her innocence and twin sister from her. In that respect, the book's Grand Canyon setting becomes an appropriate metaphor for the emptiness of her own soul as she takes up a case in which a murderous present collides with her tortured past in the form of a purportedly missing tourist.
The versatile Baldacci pulls no punches in crafting a thriller in which Atlee's pain and angst evoke a keen comparison to James Lee Burke's brilliant Dave Robicheaux as well. Riveting, relentless, and impossible to put down.
On the subject of seminal series heroes, Anthony Horowitz recaptures the original spirit of James Bond as conjured by creator Ian Fleming in Forever and a Day (Harper Collins).
Having grown up on the original books and early films featuring Sean Connery, reading this prequel to Bond's original debut in Casino Royale made me feel the same way I did upon meeting Goldfinger and Oddjob as a kid. Bond may not even have earned his 007 moniker yet, but the story is chock-full of the series staples that make the current films pale by comparison. Dastardly villains, a sinister plot, beautiful women, a few gadgets and Bond as the ruthless killer Fleming originally conceived.
Reading Forever and a Day establishes in nostalgic fashion the template that spawned the likes of Reacher and Atlee Pine. But this is a superb period piece and exceptional spy novel from the school of John le Carre and Len Deighton as well in its own right.
It's been a while since we've heard from the great Frederick Forsyth, whose iconic stature sets the bar incredibly high for The Fox (Putnam). The author of The Day of the Jackal doesn't disappoint, and also adds contemporary color to the Cold War era classics that defined him.
Such contemporary color comes courtesy of a British teenage computer hacker who has apparently penetrated the most secure systems of the Western world, including the U.S. That, of course, make him the quarry of both Cold War-esque villains and British secret agent Adrian Webster, who sees in the young man the opportunity to take down the relentless enemies of the West once and for all.
The moral dilemma that this conflict creates is the driving force behind The Fox which adds a sense of irony and pathos to Forsyth's superb style sheet. He hasn't invented a new formula so much as tweaked an old one and the result is a solid success defined by pitch-perfect storytelling.
Retired Brigadier General Anthony Tata's superb Dark Winter (Kensington) makes for an excellent, albeit far more action-
oriented, companion to The Fox.
That's because the Mahegan here, too, is computer hacking. That said, the approach is far more direct and adversarial, implementing an all-out attack that targets America's missile systems as well as power grids. It's left to series stalwart Jake Mahegan and company to take up the hunt for the perpetrators and prevent Doomsday by short-circuiting the ultimate in villainous plots.
Dark Winter is this generation's Fail Safe, at once both prescient and cautionary, and made all the more terrifying by Tata's up-close and personal view of real-life threat assessments and war rooms. Brad Taylor and Brad Thor may be his equals when it comes to pure action and plotting, but neither has ever crafted the kind of contemporary classic that promises to endure well beyond its literary lifespan.
Computers play a role as well in The Guilty Dead (Crooked Lane), though technology takes a backseat to old-fashioned investigative efforts in this superb crime thriller from P.J. Tracy.
The apparent suicide of a mega-successful Minneapolis businessman Gregory Norwood on the anniversary of his son's equally untimely passing leaves a pair of much seasoned and jaded detectives suspecting murder. Their investigation turns up not only evidence to that fact, but also a number of other suspicious deaths suggesting something, and someone, far more nefarious is at large with more lives hanging in the balance.
The Guilty Dead is crime writing at its level best and a psychological thriller extraordinaire. Reminiscent of John Sandford's superb Lucas Davenport and Michael Connelly's sensational Harry Bosch series in all the right ways, and a must for all genre aficionados.
Gary Grossman's electrifying Executive Force (Diversion) doesn't rely nearly as much on technology for its plot points,
substituting bullets for bytes.
The focus here is on a massive terror campaign from within that makes liberal use of assassination in paralyzing the country in a grip of fear. It's left to Secret Service agent Scott Roarke to sift through the maelstrom in search of the reactionary leaders of the plot, culled from the new polarized atmosphere in which America finds itself.
That may cut a little too close to the truth for some brow-beaten psyches, but no more than James Grady's period-perfect Six Days of the Condor in the wake of Watergate. This is a cautionary tale, not so much ripped from the headlines as conceivably foretelling them. A political thriller of the highest order cut from the cloth of Alan Drury and Richard Condon.
About the Author: Jon Land
Jon Land is the bestselling author over 25 novels. He graduated from Brown University in 1979 Phi Beta Kappa and Magna cum Laude and continues his association with Brown as an alumni advisor.Jon often bases his novels and scripts on extensive travel and research as well as a twenty-five year career in martial arts. He is an associate member of the US Special Forces and frequently volunteers in schools to help young people learn to enjoy the process of writing.Jon is the Vice-President of marketing of the International Thriller Writers (ITW) and is often asked to speak on topics regarding writing and research.In addition to writing suspense/thrillers, Jon is also a screenwriter with his first film credit in 2005.Jon works with many industry professionals and has garnered the respect and friendship of many author-colleagues. He loves storytelling in all its forms.Jon currently lives in Providence, Rhode Island and loves hearing from his readers and aspiring writers.
July 12th, 2019| 0 Comments
How Far Would You Go to Save Your Child?
A Timely Thriller from the Masterful Cristina Alger
July 2nd, 2019| 1 Comment
Exacting Revenge in the City of Love

redpajama_set_name: RedPajamaCommonCrawl


The partisan divide over the government's responsibility to care for the poor has widened and now stands at 35 points.
Just 40% of Republicans agree that "It is the responsibility of the government to take care of people who can't take care of themselves," down 18 points since 2007. Among Democrats, 75% agree with this statement. In 2007, 79% agreed.
On three safety net measures in the 2012 values survey, the percentage of Republicans asserting a government responsibility to aid the poor has fallen in recent years to 25-year lows.


text:
#include "FCTypes.h"

FCHandle FCHandleNew()
{
	static FCHandle s_nextHandle = kFCHandleInvalid;

	s_nextHandle++;

	return s_nextHandle;
}

redpajama_set_name: RedPajamaGithub


text:
You are viewing AANS Neurosurgeon Volume 27, Number 4, 2018. View our current issue, Volume 28, Number 4, 2019
AANS Neurosurgeon | Volume 27, Number 4, 2018
Inside Neurosurgeon
AANS Medical Student
AANS.org
Neurosurgery in Washington
Katie O. Orrico, JD | Inside Neurosurgeon | Washington Watch
AANS Neurosurgeon: Volume 28, Number 3, 2019
Prior Authorization Legislation Introduced in the House
On June 5, H.R. 3107, the Improving Seniors' Timely Access to Care Act, was introduced. Sponsored by Reps. Suzan DelBene (D-Wash.), Mike Kelly (R-Pa.), Roger Marshall, MD, (R-Kan.) and Ami Bera, MD, (D-Calif.), this legislation would protect patients in Medicare Advantage from unnecessary prior authorization practices that limit timely access to medically necessary care. The bill is based on a neurosurgery-supported consensus statement on prior authorization, which was developed by leading national organizations representing physicians, hospitals and health plans. The CNS and the AANS issued a press release in support of the legislation, at which time we simultaneously released the results of our prior authorization survey.
House Energy and Commerce Committee Advances Surprise Billing Legislation
On July 17, the House Energy and Commerce Committee favorably reported H.R. 3630, the No Surprises Act, which would protect patients from unanticipated medical bills in emergency cases and when medical services are rendered by an out-of-network provider at an in-network hospital. Prior to the full committee mark-up, on May 28, the CNS and the AANS submitted comments to committee leaders, offering suggestions on how to improve this bill.
Under the latest version of the legislation, which was incorporated into H.R. 2328, when a billing dispute arises between a provider and insurer, the payment rate is based on the median in-network rate for the area in which the service occurred. The initial payments in 2021 would be based on rates in place in 2019. Rates would be adjusted for inflation each subsequent year. The committee adopted an amendment from Reps. Raul Ruiz, MD, (D-Calif.) and Larry Bucshon, MD, (R-Ind.), allowing providers to appeal the payment rate to an independent dispute resolution (IDR) process for claims over $1,250. The CNS and the AANS supported this amendment and issued a press release expressing our support. Click here to watch the committee mark-up.
Protecting People From Surprise Medical Bills Act Introduced
On June 26, H.R. 3502, the Protecting People Surprise Medical Bills Act, was introduced. Sponsored by Raul Ruiz, MD, (D-Calif.) and Phil Roe, MD, (R-Tenn.), this legislation, endorsed by the CNS and the AANS, is modeled after New York's out-of-network law and would, among other things, establish an independent dispute resolution (IDR) process to resolve billing disputes between insurers and providers. Proponents of H.R. 3502 have pointed to the New York law as an example of a successful approach to surprise billing, which has reduced out-of-network billing by 34% compared to neighboring states. Efforts to gain support for H.R. 3502, the preferred solution for surprise medical bills, are ongoing and action in the House Education and Labor and Ways and Means Committees is expected in the fall.
Comprehensive Medical Liability Reform Legislation Introduced
On July 9, H.R. 3656, the Accessible Care by Curbing Excessive lawSuitS (ACCESS) Act, was introduced by Reps. Richard Hudson (R-N.C.), Roger Marshall, MD (R-Kan.) and Larry Bucshon, MD (R-Ind.). Endorsed by the CNS and the AANS, this comprehensive reform legislation is modeled in part on the laws in California and Texas, which include reasonable limits on noneconomic damages. The bill also includes the following provisions:
Defines who qualifies as an expert witness;
Requires an affidavit of merit before bringing a lawsuit;
Allows a physician to apologize to a patient for an unintended outcome without having the apology count against them in the court of law; and
Requires a 90-day cooling-off period before lawsuits can be filed to facilitate voluntary settlements.
The Congressional Budget Office (CBO) and the staff of the Joint Committee on Taxation (JCT) estimate that the provisions included in the bill would reduce federal spending by about $14 billion over five years and almost $50 billion over 10 years.
Emergency Preparedness Legislation Signed Into Law
On June 24, President Donald J. Trump signed into law S. 1379, the Pandemic and All-Hazards Preparedness and Advancing Innovation Act (PAHPAI). This bill will reauthorize programs within the Department of Health and Human Services (HHS) relating to health emergencies. Championed by the AANS and the CNS, this legislation also addresses medical liability protections for volunteer physicians and other health professionals who have pre-registered with Emergency System for Advance Registration of Volunteer Health Professionals (ESAR-VHP) or the Medical Reserve Corps. Finally, the bill includes H.R. 880, the MISSION Zero Act, which would assist U.S. military health care providers in maintaining a state of readiness by embedding military trauma teams and providers in civilian trauma centers. As part of the Trauma Coalition, the AANS and the CNS sent out a press release applauding passage of this crucial legislation.
Neurosurgery Endorses Legislation to Repeal the Medical Device Excise Tax
On June 17, the AANS and the CNS sent a letter to Sens. Patrick Toomey (R-Pa.) and Amy Klobuchar (D-Minn.), endorsing S. 692, the Protect Medical Innovation Act of 2019, legislation to permanently repeal the medical device tax. The AANS and the CNS also sent a letter to Reps. Ron Kind (D-Wis.), Scott Peters (D-Calif.), Jackie Walorski (R-Ind.) and Richard Hudson (R-N.C.) in support of the House version of the bill, H.R. 2207. Senate Finance Committee chair Chuck Grassley (R-Iowa) and ranking member Ron Wyden (D-Ore.) created a health tax task force to examine the impact of the 2.3 percent medical device excise tax. The AANS and the CNS submitted a letter to health task force chairs, Sens. Patrick Toomey (R-Pa.) and Robert Casey (D-Pa.), and participated in a task force roundtable where we reiterated our support for repealing the tax. Since 2015, Congress has twice enacted two-year moratoria to delay implementation of the tax, which will take effect on Jan. 1, 2020, if Congress does not act.
Concussion Awareness Act Reintroduced
Earlier this year, Rep. Joyce Beatty (D-Ohio) introduced H.R. 280, the Concussion Awareness and Education Act. Endorsed by the AANS and the CNS, this legislation would provide for systemic research, treatment, prevention, awareness and dissemination of information concerning sports-related and other concussions. The bill directs the National Institutes of Health (NIH) to conduct specific research on youth concussions, directs the Centers for Disease Control and Prevention (CDC) to develop and disseminate information to the public, and establishes a Concussion Research Commission to formulate systemic recommendations based on research developed form the legislative directives.
Neurosurgery Endorses the Cerebral Cavernous Malformations Clinical Awareness, Research and Education Act
On June 27, the Cerebral Cavernous Malformations Clinical Awareness, Research and Education Act (H.R. 3573/ S. 2010), was introduced. Sponsored by Rep. Ben Ray Lujan (D-N.M.) in the House, and Sen. Tom Udall (D-N.M.) in the Senate, this legislation would provide crucial insights into cerebral cavernous malformation (CCM) by expanding research at the NIH, CDC and the U.S. Food and Drug Administration (FDA), to increase awareness, treatment and prevention of CCM. The AANS and the CNS endorsed both the House and Senate bills.
Health Care Safety Net Enhancement Act Reintroduced
On July 29, H.R. 3984, the Health Care Safety Net Enhancement Act of 2019 was introduced. Sponsored by Reps. Bill Flores (R-Texas), Roger Marshall, MD, (R-Kan.), and Brian Babin, DDS, (R-Texas), this legislation will help ensure that patients have access to emergency care by extending liability protections to on-call and emergency physicians through the Federal Tort Claims Act. Specifically, the bill would ensure that emergency department and on-call physicians who are providing medical services under the Emergency Medical Treatment and Labor Act (EMTALA) receive the same liability coverage currently extended to employees of Community Health Centers and health professionals who provide Medicaid services at free clinics. The AANS and the CNS have endorsed this bill.
Neurosurgery Comments on Proposed Coverage for Vertebral Augmentation
On July 19, the AANS, the CNS and the AANS/CNS Joint Section on Disorders of the Spine and Peripheral Nerves sent a letter to Noridian, the Medicare Administrative Contractor (MAC) for 12 western states, regarding a proposed Local Coverage Determination (LCD) for Percutaneous Vertebral Augmentation (PVA) for Osteoporotic Vertebral Compression Fracture. In addition to Noridian, three other MACs — Wisconsin Physician Services (WPS), National Government Services (NGS) and Celerian Group Company (CGS) — have issued the same LCD and neurosurgery has also sent letters to those payers. The LCDs resulted from a March 20, multi-jurisdictional MAC Carrier Advisory Committee (CAC) conference call on the issue. Renee Chambers, MD, FAANS, served as a subject matter expert on the call and John K. Ratliff, MD, FAANS, and Philipp M. Lippe, MD, FAANS(L), participated as voting CAC members. More information on the CAC meeting is available here.
Neurosurgery Supports Coverage for MRI Guided Focused Ultrasound (MRgFUS)
On June 3, the AANS, the CNS, and the American Society for Stereotactic and Functional Neurosurgery (ASSFN) sent a letter to Novitas, the MAC for Region JL that includes several Mid-Atlantic States. The letter expressed support for a request by the University of Pennsylvania Medical Center for reconsideration of the Novitas negative Local Coverage Determination (LCD) for MRI Guided Focused Ultrasound (MRgFUS) for Essential Tremor (ET). The letter included a position paper developed by ASSFN entitled "MR-guided Focused Ultrasound for the Management of Essential Tremor," incorporating a robust review of the literature for the procedure. In addition to the letter to Novitas, on July 30, the AANS, the CNS and the ASSFN sent a similar letter to First Coast Service Options, Inc. urging coverage for MRgFUS.
2018 Open Payment Data Released
On June 28, CMS published the 2018 Open Payments program data, along with newly submitted and updated payment records for previous program years. The Open Payments program collects and publicly reports information annually about payments that drug and device companies make to physicians and teaching hospitals for items such as travel, research, gifts, speaking fees and meals. For 2018, device and drug companies reported $3.00 billion in general (i.e., non-research related) payments, $4.93 billion in research payments and $1.42 billion of ownership or investment interests held by physicians or their immediate family members. CMS will refresh the data in January 2020, updating records to reflect the status of disputed payments. Click here to access the data.
Class I Recall for Brainlab Spine and Trauma 3D Navigation System
The FDA has identified a recall of Brainlab's Spine & Trauma 3D Navigation Software as Class I, the most serious. The manufacturer recalled the software because of the potential for incorrect information to display during surgery, which may prevent the surgeon from accurately navigating surgical tools inside the patient. More information is available on the FDA website by clicking here. The FDA reviews manufacturers' responses to reported problems with their devices and can assign one of three classifications of risk to the identified problem:
Class 1, referring to a reasonable chance of serious health threats or death;
Class II, when a temporary health condition can result, or when there is a small risk of serious injury or death; or
Class III, when no health problem or injury is likely.
Dr. Alex Valadka Pens Op-ed on Graduate Medical Education
On June 11, Alex B. Valadka, MD, FAANS, authored an opinion piece for The Hill about the need to expand Medicare's support for residency training to ensure all Americans have access to the care they deserve now and into the future. In the piece, Dr. Valadka wrote, "An appropriate supply of well?educated and trained physicians is essential to ensure timely access to quality health care services for all Americans. America's specialty physicians challenge Congress to meet these needs by adopting legislation to increase the number of Medicare-supported residency positions."
Neurosurgery Joins 'Out of the Middle' Coalition to Address Surprise Medical Bills
Joining several other specialty medicine colleagues, the AANS and the CNS have joined forces to support a public outreach and grassroots campaign on the issue of surprise medical bills. Out of the Middle is a coalition of leading health care provider groups, who are advocating on behalf of the millions of patients they care for every day. In addition to a web-based platform, the group has deployed web-ads on key websites frequented by policymakers. Thus far, the effort has generated thousands of messages to Congress in support of H.R. 3502, the Protecting People From Surprise Medical Bills Act.
For more information on these or other health policy issues, please contact Katie O. Orrico, director of the AANS/CNS Washington Office at korrico@neurosurgery.org.
Katie O. Orrico, JD, is the director of the AANS/CNS Washington Office. She holds a Juris Doctor degree from the George Mason University School of Law and a BA from The Catholic University of America. Orrico has worked for organized neurosurgery for more than 26 years, and is the recipient of both the AANS' and CNS' Distinguished Service Awards. For more information on these or other health-policy issues, contact Katie Orrico at korrico@neurosurgery.org. The author reported no conflicts for disclosure.
Calendar/Courses
Kranzler Chicago Review Course in Neurosurgery
Jan. 24-31, 2020; Chicago
46th Annual Richard Lende Winter Neurosurgery Conference
Jan. 31-Feb. 3, 2020; Snowbird, Utah
Third Annual Cedars Sinai Intracranial Hypotension Symposium
Feb. 8, 2020; Los Angeles
2020 Managing Coding and Reimbursement Challenges
Feb. 14-16, 2020; Las Vegas
13th Annual International Symposium on Stereotactic Body Radiation Therapy and Stereotactic Radiosurgery
Feb. 21-23, 2020; Lake Buena Vista, Fla.
Interactive Calendar
Be the first to reply using the above form.
Neurosurgical Perspective
The Unfiltered Neurosurgeon
Developing the Mind of the Neurosurgery Resident
50 Years Later: Current Management of Tarlov Cyst
A Neurosurgeon's Nightmare: Essential Tremor
Alternative Mind: How Non-traditional Experiences Enrich Neurosurgical Training Part 2
Why Don't We Have a Cure for Spinal Cord Injury?
Most Recent Issues
The Mind of a Neurosurgeon
Hustle, Work, Think, Play: Sports & Neurosurgery
Evolving Practice
Shifting Clinic Culture to Address the Opioid Epidemic
January 15, 2020 — AANS Neurosurgeon
Surgery May Add Months or Years of Survival for Adults with Rare and Deadly Brain Cancers
Backbone of Success
Gut Microbes May Improve Stroke Recovery
Stroke Drug Boosts Stem Cell Therapy for Spinal Cord Injury in Rats
January 9, 2020 — AANS Neurosurgeon
© AANS All Rights Reserved 2020
AANS


It's no wonder that teams like Oakland and Texas have such good records... they each get 18 free wins against Houston this year.
Got MLB tv at the start of the month for 80 bucks. Saw he was pitching a no no and flipped it over. Great investment as I don't have cable and wanted to follow the A's and my fantasy team more closely.
Not related to the current season: I watched Knuckleball! on Netflix this weekend... really interesting documentary - makes me like R.A. Dickey even more, even if he is having a tough season this year.
Missing Ratboy. The Freak was pretty hot last night.
The Cardinals finished up the first half of the season with the best record in baseball. Further, based on their +127 run differential, they have won four fewer games than they should have.
I pretty much want them to stay pat, but there are rumors they may try to acquire Cliff Lee at the trade deadline. They have well-stocked farm system and ton of young players to offer, but I'd prefer to stick roll with the less expensive home grown players. But the idea of rolling into postseason with Lee and Wainright leading the rotation is pretty attractive, too.
Rays with a 9-1 home stand, and 10-1 in their last 11.
Sadly they have the fewest home games after the break. I think I heard 28, and the next lowest team has 38?
And as mentioned recently, Texas and Oakland both get 10 games (read: wins) against Houston, so it will be tough to overtake one of them for the wild card. Although I think we did just move a game (half-game?) ahead of Texas yesterday.
Even Houston is going to win ~55 games this year - those wins have to come against someone. Chances are at least a few more will come against Texas and Oakland. Also, there are two wild cards now, and looking at the standings, I'd think one of them will come out of the East unless all the teams beat each other up over the next few months and Cleveland or Detroit manages to sneak in.
Oakland is going to win the AL West. I think the Rays will pull one WC out of the East. I actually think your Rays could still pull out the division.
Braun, the lying dirtbag, is gone for the remainder of the season.
I assume that he took this road now ("I realize now that I have made some mistakes,") because the alternative was to miss not only the final ~60 games of this season, but also the first ~40 of next season.
Yes, clearly a negotiated deal between Braun, MLB and the MLBPA. The evidence MLB had must have been overwhelming. But honestly, we all already knew he was cheating. He got off on a technicality.
I have zero respect for this guy. Forget his talent, he's a bald-faced liar who threw a perfectly decent guy who was only doing his job (the sample collector) under the bus. Go back and read or watch his statement from February 2012 when he "won" his appeal. In light of what occurred today, it will tell you everything you need to know about Ryan Braun.
I'm really surprised that Braun was given any kind of lenient treatment. Given the way he made a mockery of the system last year I would have thought the commissioner/MLB would have been out to inflict the heaviest punishment they could.
I would imagine the same logic would apply to A-rod for much the same reasons.
I think MLB wanted to send a message, and by negotiating with Braun they could get him to agree not to appeal. That way, the story was clearly about "we'll suspend anyone for PEDs," and not about the union, the appeal process, "did he or didn't he", etc.
As for A-Rod, rumor is he's likely to get harsher treatment because of his efforts to thwart the investigation, But we'll see.
Heyward's game ending catch last night was bananas. Sad about the loss, but hey, gotta tip the cap. In the rain and not in his usual position, no less.
Yea the way I understand it Braun came clean which saved MLB a huge long drawn out headache. He was going to get suspended eventually but he could of appealed through the union for a long long time supposedly.
Its telling that 0 other players have been dinged yet. From a fantasy perspective (how I've been following this) theres productive players still associated that are blowing in the wind (Everth Cabrera, Nelson Cruz, Big Fat Bartolo and Melky). A bunch of other guys also.
The Yankees must be hoping A-Rod gets crucified and them out of their obligations or at the very least he never suits up again.
Do you think that Melky will get dinged again? He's already served 100 games... presumably for this offense.
Not sure thats the confusing part. Big Fat Bartolo also.
A-Rod supposedly is going to get hit the hardest for trying to submarine the whole investigation.
Rangers are kinda screwed here. No more Nelson Cruz I imagine?
What is it with Atlanta, and everything that goes to center field dying..
I think most players will be suspended next season after they go through the entire appeals process and such. Braun was smart to accept it this season because 1) the Brewers aren't contending and 2) he makes more money next year, so it's costing him less to get it out of the way now. I'd expect players on other non-contending teams to attempt to work out a similar deal, but someone like Cruz will ride the whole process out.
As a Orioles fan, I am deathly afraid that the other shoe will drop on Chris Davis considering the stark differences in years he is having between 2012 and 2013. I mean, who has 32 HR all year and then busts more than that before the All Star break?
I just hope it isn't true. And so far, I haven't even heard any rumors.
He's always had huge power. Coming up through the minors he posted a few years with slugging % not too far off what he's doing this year. Chances are the power is real but the number of homeruns is fluky. Here's his HR/FB % by year: 20.5, 19.6, 3.4, 10.0, 25.2, 33.6. Combine that with his groundballs being way down and his flyballs being way up and you've got a recipe for a fluky homerun total.
I mean, who has 32 HR all year and then busts more than that before the All Star break?
It reminds me of Jose Bautista's breakout season (only better).
It feels like the Cardinals are the most boring best team in baseball ever. Hopefully they will continue to roll in Atlanta this weekend.
Stupid rain. Rays could have taken the division lead tonight.
Hopefully the Rays can take the Yankees this weekend and the Orioles give Boston some trouble.
After today's 11-0 drubbing, the Nationals now have more losses than the Mets.
Mind you, that's doesn't make the Mets good, but it does make the Nationals bad.
Here we go again. CC pitching for the Yankees. Rays up 6-0 in the 2nd already.
Seriously, why do they let him pitch against us?
Bust out those brooms Bravos! I'll admit I definitely did not see them sweeping the Cardinals before this series began, especially facing Wainwright and Miller.
I saw it. Pretty much happens every time I post positively about a sports team I care about.


Best VPNs For iPhone 2017-2018 – HowtoUseVPNGuide.com, your VPN Pro!
As internet privacy has become a hot-button issue, people are looking for new ways to protect themselves, their devices, and their personal information from corporations, governments, and even their internet service provider. Using a Virtual Private Network (VPN) for iPhone is one of the best ways that keeps your personal data secure and safe. A virtual private network, commonly referred to as a VPN, is a type of connection you can use over the internet that helps to secure your identity as you surf the web. Find out the best VPNs for iPhone for 2017-2018 and get the complete online browsing solution now.
VPN stands for Virtual Private Network, which is a special kind of network using a public internet connection to get connected to the private network. Surfing the web on a public WiFi can be dangerous because it opens your iPhone up to spying eyes. But if you connect your iPhone to a VPN, all your network traffic will pass through a protected tunnel, therefore nobody can see your traffic or trace your online activities. All your data will be encrypted and protected by the help of VPNs. A VPN also hides your location online, which allows you to access blocked contents and restricted sites such as US Netflix when you are in the UK. Here we will talk you through the best VPNs for iPhone 2017-2018.


Love creepy crawlies? Fascinated with bugs of all kinds? Take a closer look at the miniature world of incredible insects and amazing arachnids with Ultimate Factivity Collection: Bugs. Packed with fun activities and amazing facts about bugs, you'll find everything you want to know about creepy crawlies, such as the migration of the monarch butterfly, which insects have unusual superpowers, and which spider has the deadliest venom. Fascinating!
Packed with fun activities including games, doodle and coloring pages, puzzles, and crafts, plus more than 500 stickers, each book in the Ultimate Factivity Collection contains amazing facts and educational information that encourage learning while at the same time improving social, emotional, cognitive, and language skills. The Ultimate Factivity Collection series will keep kids busy and learning for hours.


text:
package ru.job4j.generic;

import org.junit.Test;

import java.util.Iterator;
import java.util.NoSuchElementException;

import static org.hamcrest.MatcherAssert.assertThat;
import static org.hamcrest.Matchers.is;

public class SimpleArrayTest {
    @Test
    public void whenWeTryToAddACoupleDifferentValuesAndEvrythIsOk() {
        SimpleArray<Integer> array = new SimpleArray<>(4);
        SimpleArray<String> stringSimpleArray = new SimpleArray<>(2);
        array.add(150);
        stringSimpleArray.add("Hello, world!");
        assertThat(array.get(0), is(150));
        assertThat(stringSimpleArray.get(0), is("Hello, world!"));

    }

    @Test
    public void getSomeValueFromOurIntegerAndStringArrays() {
        SimpleArray<String> stringSimpleArray = new SimpleArray<>(4);
        SimpleArray<Integer> integerArr = new SimpleArray<>(4);
        stringSimpleArray.add("Hello");
        stringSimpleArray.add("Beautiful");
        stringSimpleArray.add("World");
        integerArr.add(100);
        integerArr.add(400);
        integerArr.add(500);
        assertThat(integerArr.get(1), is(400));
        assertThat(stringSimpleArray.get(2), is("World"));

    }

    @Test
    public void deleteElementsFromOurArraysByIndex() {
        SimpleArray<String> stringSimpleArray = new SimpleArray<>(4);
        SimpleArray<Integer> integerArr = new SimpleArray<>(4);
        stringSimpleArray.add("Hello");
        stringSimpleArray.add("Beautiful");
        stringSimpleArray.add("World");
        integerArr.add(100);
        integerArr.add(400);
        integerArr.add(500);
        stringSimpleArray.delete(1);
        integerArr.delete(0);
        assertThat(integerArr.get(0), is(400));
        assertThat(stringSimpleArray.get(1), is("World"));
    }
    @Test(expected = NoSuchElementException.class)
    public void iteratorForOurSimpleArray() {
        SimpleArray<Integer> integerSimpleArray = new SimpleArray<>(5);
        integerSimpleArray.add(2);
        integerSimpleArray.add(3);
        integerSimpleArray.add(5);
        integerSimpleArray.add(7);
        integerSimpleArray.add(3571);
        Iterator<Integer> it = integerSimpleArray.iterator();
        assertThat(it.hasNext(), is(true));
        assertThat(it.next(), is(2));
        assertThat(it.hasNext(), is(true));
        assertThat(it.next(), is(3));
        assertThat(it.hasNext(), is(true));
        assertThat(it.next(), is(5));
        assertThat(it.hasNext(), is(true));
        assertThat(it.next(), is(7));
        assertThat(it.hasNext(), is(true));
        assertThat(it.next(), is(3571));
        assertThat(it.hasNext(), is(false));
        it.next();
    }

}


Bryant "B.Y." Jennings was itching for another Heavyweight world title shot. The 34-year-old Philadelphia native had won five consecutive bouts, four by knockout, and was hoping to make an emphatic statement on Friday night when he put his IBF International and NABO Heavyweight belts on the line in a 12-round showdown against the unbeaten NABF champion Oscar "Kaboom" Rivas.
The bout, which took place at Turning Stone Resort Casino in Verona, N.Y., was an exciting Heavyweight clash which saw Rivas score the 12th-round TKO victory over the favored Jennings.
In the 10-round co-feature, undefeated Featherweight sensation and 2016 U.S. Olympic silver medalist Shakur Stevenson took on Jessie Cris Rosales for the vacant International Boxing Federation Inter-Continental Featherweight Title and vacant World Boxing Council Continental Americas Featherweight Title.
Stevenson was impressive in scoring the stoppage win in Round 4 behind a series of hard, straight left hands.
While Rosales did recover and stand up, the referee decided that Rosales was not in any condition to continue the bout.
The TKO victory for Stevenson came at 1:29 of Round 4 as he improves to 10-0, 6 KOs.
Although Stevenson said he wants to follow Top Rank's lead in guiding his career, he said he feels he is ready to step up and fight for a title in 2019.
The 126-pound division is filled with talent, but Stevenson has his eyes set on one particular champion.
Bob Arum also spoke in regards to a possible title shot for Stevenson.
"If he's ready for Warrington I think I can make that fight," said Arum.


Many people perceive America's relationship with Islam and Muslims as a twentieth-century phenomenon. In reality, America's relationship with Islam predates the creation of the United States and reflects America's European, African, and Middle Eastern heritage. Islam was also a key component of Atlantic history in both the eastern and western hemispheres as a rival civilization and a vehicle for religious and political reform. This article will discuss the role of Islam at three crucial turning points in Atlantic history: the Protestant Reformation, the emergence of European nation-states, and the rise of notions of universal human rights.


The all new Bobcat E27z compact excavator model further enhances the excellent performance characteristics of current Bobcat E26 mini excavator. The new Bobcat E27z features the largest cab for this size of machine on the market. As a true Zero House Swing (ZHS) machine (even with the optional heavy counterweight), the Bobcat E27z offers the highest flexibility of movements when working close to walls, coupled with best-in-class 360-degree stability and a low weight for easy transportation. With the optional long arm and a premium cab, the Bobcat E27z offers the digging output and operator comfort of much larger excavators, making it a machine of choice for urban operating construction companies.
For more information about the Bobcat E27z contact Adare Machinery on 061-397777.


text:
Cruel Valentine's Prank
If your boyfriend goes down on one knee with a ring box on Valentine's Day, you'd be forgiven for thinking that he was about to ask the big question. But for poor Jenny Davies, it turned out to be nothing more than a prank which was filmed by her cruel boyfriend Brad Holmes for his viral Facebook page "Brad's Dad". The video which has been viewed over 12 million times since being posted on Valentine's Day actually shows Brad going down on one knee to ask his girlfriend for a cup of tea – the ring box containing nothing more than a teabag. Jenny told the Mail Online afterwards that she was glad the proposal hadn't actually happened in that way as she was in her pyjamas lounging on the sofa. The full video can be watched here.
iPhones Cannot Go Back in Time
It seems to be a good week for online pranksters, but this one is rather more malicious. A photo online prompting users of Apple devices to reset the date on their iPhones to 1st January 1970 in order to get a cool retro design, and looking rather official, is actually a scam which will break your phone. Users were meant to find a special Easter Egg when the date was changed however what they really got was once the phone was turned off, rebooted or ran out of battery, the date stuck and the phone was unable to function again. And even Apple themselves don't seem to have a fix… The company has said that it is working on a software fix that will stop this from happening in the future but it is unlikely those that fell foul of the prank will be able to get into their devices again.
#MakeDinnertimeSpecial
An Australian food company, MasterFoods, has launched a new campaign to make dinnertime special as a reaction to a recent survey that revealed Australians make more of a connection when eating together than doing any other activity. In order to highlight the importance of relationships and mealtimes the company toured around the country interviewing parents and their children asking them "if you could have dinner with anyone alive or dead who would it be?". The adults responses included Jimi Hendrix, Marilyn Monroe and Nelson Mandela. But what will melt your heart are the children's responses – all of whom responded that the people they'd most like to eat with are their parents or family in general.
Twitter Goes Algorithmic
This week Twitter has made a radical change to the way it shows its Home page feed. Since Twitter's launch, its feed of tweets has been purely based on a reverse chronological order system so that the newest tweets always stay at the top. However, this is all set to change as Twitter is set to include an algorithm for its feed which will show roughly the first twelve tweets that are most relevant to you despite how old they are. At the moment, this is only a feature that you can opt yourself into but this will be rolling-out as standard very shortly.
We're heading back to Australia for another story from Google. To celebrate Sydney's Fair Day this Mardi Gras, Google has created a Places of Pride map. The map is a place for the LGBT community to share special places for them to the world, which could be a place of a proposal, first date or just somewhere you've felt the love. The custom rainbow pin has been created as part of the map. The map was set-up by Patrick Hofmann, part of Google Maps Sydney team, who writes in his blog post that "growing up as a rural Canadian farm boy, I hid my homosexuality for years, fearing that I was the 'only gay in the village' and that there was no support from my community." He hopes that the map will celebrate the global reach of the gay community.


text:
Meet Miller Canfield
Miller Canfield Global Strategies
Miller Canfield Consulting
Bankruptcy, Restructuring and Insolvency
Bankruptcy Litigation and Appeals
Creditor and Creditors' Committee
Debtor Representation
Distressed Automotive Supplier
Distressed Transactions and Bankruptcy Sales
International and Cross-Border Insolvency
Loan Enforcement and Restructuring
Corporate and Transactions
Corporate Governance and Compliance
Corporate, Securities and Commercial Transactions
Securities Regulation
Startups and Venture Capital
Tax: Federal
Tax: State and Local
Diversity, Equity and Inclusion Consulting
Governmental and Public Entities
Human Resources Counseling and Training
Renewable Energy Development and Finance
C&I and Asset-Based Finance
Commercial Lending Enforcement, Insolvency and Litigation
Commercial Real Estate Finance
Commercial Real Estate Finance Workout, Foreclosure and Litigation
Loan Syndications and Credits
Receiverships, Real Estate Owned and Loan Portfolio Acquisitions & Dispositions
Registered Investment Advisory
Swaps and Derivatives Structuring
Trade Secrets and Non-Competes
Trademarks and Brands
Doing Business in the United States
Export Controls and Sanctions
International Sales and Commercial Transactions
Class and Collective Actions
Commercial and Corporate Litigation
Criminal Defense Litigation
Franchise, Dealer and Sales Representative Litigation
Governmental Litigation
Litigation Support Services
Product Liability and Torts
Product Warranty Litigation
Professional Liability and Malpractice Litigation
Real Estate and Construction Litigation
Tax Litigation and Consulting
Capital Assets and Infrastructure
Cash Flow and Working Capital
Charter School Finance
Disclosure Counsel Services
Distressed Municipalities and Debt Restructuring
Hospitals and Other Nonprofits
K-12 Education Finance and Election Law
Related Government Services
Governmental Entities
Real Estate Acquisition and Disposition
Client Training
Monterrey (Affiliated)
Windsor (Affiliated)
Controller Joins Miller Canfield
The law firm of Miller, Canfield, Paddock and Stone, P.L.C. announces that Joseph W. Thimm has joined its Detroit office as senior controller. Thimm brings over 20 years' experience in financial analysis and reporting, accounts payable, accounts receivable, billing, and payroll. Most recently, he was controller at the law firm of Bodman, Longley & Dahling LLP.
Thimm's prior experience includes senior financial analyst at MCA Mortgage Corporation in Southfield, and controller, Independence One Mortgage Corporation in Southfield. He is experienced in developing multi-year strategic plans and budgets, designing system controls, and managing the accounting for purchased mortgage servicing rights and non-conforming mortgage loan interest-only pools. He also has experience in high growth and turnaround situations.
He received his M.B.A. in 1993 in finance from Wayne State University, where he also received his B.B.A. in 1981 in business administration and accounting.
A resident of Novi, Thimm is active in the Boy Scouts of America and a member of the finance committee at Church of the Holy Family.
The 300-attorney law firm of Miller, Canfield, Paddock and Stone, P.L.C. was established in Detroit in 1852 and has offices in Ann Arbor, Detroit, Grand Rapids, Howell, Kalamazoo, Lansing, Monroe, and Troy, Michigan. Other offices are located in New York City, Pensacola, Florida, Washington, D.C., Windsor, Ontario, and in Gdynia, Katowice, and Warsaw, Poland.
Virtual Miller Canfield
© 2022 Miller, Canfield, Paddock and Stone, P.L.C. | Site by Firmseek


The beauty of this over-the-counter hunt is that you can do it every year. You don't have to build up points for years and hope to get drawn. Also, with this one tag you can hunt three different times of the year. So if you don't fill your tag during the first season, you will still have two more opportunities. Also, though some may not agree with this, spike bucks are legal. So if you are a new bow hunter or just a meat hunter you can have even more opportunity with deer that are not yet educated.
Also, some of the units in the state hold the elusive Coues Whitetail. You can shoot these deer with the same over-the-counter tag. Check the Arizona Game and Fish regulations to see a map where these deer are present. Units where I have seen them are: 6A, 6B, 8, 36A, 36B, and 36C.
Open Units: 8, 9, 10, 15A, 15B, 15C, 15D 16A (except Mohave County Park lands), 17A, 17B, 18A, 18B 19A, 19B, 20A, 20B, 20C, 21 (except Cave Creek Recreation Area), 22, 23, 24A, 24B, 25M, 27, 28, 29, 30A, 30B, 31, 32, 33, 34A, 34B, 35A (except Fort Huachuca), 35B, 36A, 36B, 36C, 37A, 37B, 38M (including Tucson Mountain Wildlife Area), 39, 40A, 40B, 41, 42, 43A, 43B, 44A, 44B, 45A, 45B, 45C, and 47M.
Units 29, 34A, 34B, 35A, 35B, 36A, 36B, and 36C are great units to hunt this time of year. The desert terrain with rolling hills and buttes in these units make it easier to glass up deer and put stalks on them. Also, the day time temperatures can sometimes get into the 70's, which makes it nice for a winter hunt. But keep in mind that it is winter, and cold fronts can and will come in. Also keep in mind that you CAN hunt and camp in the Buenos Aires National Wildlife Refuge in Units 36A, 36B, and 36C. Also in 36C, is the Santa Margarita Ranch and the Kings Anvil Ranch. These are both private ranches that will let you camp and hunt for free. All that you have to do is sign in at the gate. All three of these areas have great water holes and hold a lot of deer.
This is my favorite time to hunt in Arizona because of the Rut. The Rut normally starts during that last week or two in December and carries on into the second week in January, depending on which area of the state you are in.
During this time of the year I spend the mornings glassing. If I find a buck that I want to pursue, I will bed him down and try to put a stalk together. If you find some does in an area, that don't have bucks with them, you will need to keep checking up on them. Eventually bucks will join the group as the does come into estrus. In the afternoons I like to hunt water. Success on water will depend on the last time it has rained in the area. You can also brush out the fresh tracks around the water hole to see how frequent the deer are coming in. Or, you can set up a trail camera. Try to get into your blind or tree stand at least 4 hours before dark.
Google Earth is a great toolto finder water holes in the area you are planning to hunt. You can also get a book from AZ Game and Fish that shows maps to most of the game and fish maintained water sources.
IMPORTANT, there is a lot of illegal immigration activity in these Units. Although I have never had any problems, I have heard stories of hunters and Game Wardens having issues with drug runners. You just need to be aware of your surroundings. It is LEGAL to carry a side arm in the Southern part of the state while archery hunting.
IMPORTANT , if you are planning on hunting during December (Third Season) and January (First season)make sure you have a 2011 tag for December and a 2012 tag for January.
Open Units: 1, 2A, 2B, 2C, 3A, 3B, 3C, 4A, 4B, 5A, 5B, 6A, 6B (except Camp Navajo), 7,8, 9, 10, 11M, 15A, 15B, 15C, 15D, 16A (except Mohave County Park Lands),17A, 17B, 18A, 18B, 19A, 19B, 20A, 20B, 20C, 21 (except Cave Creek Recreation Area), 22, 23, 24A, 24B, 27, 28, 29, 30A, 30B, 31, 32, 33, 34A,34B, 35A (except Fort Huachuca), 35B, 36A, 36B, and 36C.
This is the time of year when you can find a velvet buck. I like to hunt Units 6A, 6B, 7, 8, 9, 10, 17B, 20A, and 20C. I hunt these Northern units because the summer temperatures don't get too high. I sit a lot of water during this season because of the heat, but spot and stalk opportunities are abundant. I normally start hunting in the most northern of these units, checking water holes for fresh sign. If it has rained recently I will move to the Southerly units where they don't get as much rain. Again, use Google Earth or the Game and Fish book to find these water sources.
If there has been a lot of rain or you just don't want to sit water, there terrain in most of these units is suitable for spot and stalk. I strongly recommend putting your binoculars on a tripod while glassing. I can guarantee that you will see more deer doing this. If you are new to the spot and stalk method, the goal is to glass up a buck and then put a stalk on him. The most common thing to do is to wait for the buck to bed down for the day and then plan your stalk. Keep in mind that the wind will normally blow uphill in the mornings as it warms up. This means you should get above your bedded buck and make a stalk downhill toward him. This is not always the case, so always be aware of the wind direction.
The beginning of this season will be pre-rut. The last week or two will be when the rut will really start to kick off.
I hunt the same units and use the same tactics as the FIRST SEASON (see above).
In whole, the State of Arizona holds a lot of deer. You can go almost anywhere and find them. The key to success is finding water holes that deer are hitting. From there you can hunt the water and/or do some glassing for some spot and stalk action.
To break it down again…. You can hunt the whole month of January and if you don't fill your tag you can hunt from August 19th through September 8th. If you still have not filled your tag you can come back and hunt from December 9th through December 31. After that, you can start again on January 1st with a new tag.
Hunting water is a great technique for putting your tag on an Arizona Mule Deer. The key to finding a good water hole to hunt is to find a lot of them and check them for tracks. I use Google Earth to look for water holes and I also use the Arizona Game and Fish "Water-catchment Map Book" to look for water in the unit I want to hunt. You should find deer sign at most water holes, but that doesn't mean they are good to hunt.
The perfect water hole will be small, so that none of your shots will be over 40 yards. It will also be socked in with brush so that you can make a good blind to conceal yourself, and the deer will have plenty of cover leading them to the water. With more cover, the deer will feel more comfortable coming to water during day light hours. I also try to find water that is not easily accessible to other hunters.
You will find that most non-natural water sources in Arizona will have roads leading to them. I like to find water holes off of roads that are terrible to drive on. Remember, people are lazy, and won't want to travel on a nasty, bumpy road. The road I traveled last year to my water hole took me 45 minutes to cover the 1 mile stretch. I never saw another hunter and had deer coming every afternoon. Try to park your vehicle at least 300 yards from the water hole and make sure that it is concealed in the brush or trees, so that the deer won't be able to see it as they are coming in. The farther you park away, the better.
Once you find a water hole that you want to hunt. You will need to set-up or build a blind. I like to set-up my blind in the brush, and cut some limbs off neighboring trees to cover my blind. This will help break up the "box" shape of your blind. Once set-up, get inside and make sure that your shooting lanes are clear. Now you are ready to hunt.
Deer will hit water at all times of the day, but mostly in the mornings and afternoons. Be sure to get into your blind at least an hour before shooting light in the mornings, and four to five hours before dark in the afternoons.
Glassing is a must-have tool for your bow hunting arsenal. The key to success in the field with your binoculars is simple. The first and most important thing is to put them on a tripod. Having your binoculars on a tripod will improve your glassing tenfold. The reason being, your eyes are designed to pick up movement. If you are just using your hands to stabilize your bino's, you will not be able to see that ear twitch, or a bedded bucks antlers moving in the brush because your arms are moving. By putting your bino's on a tripod, you will be able to find more animals at farther distances, giving you more opportunity to plan a stalk. You will also be able to spend more time glassing and cover more ground because the tripod is holding the weight for you. You can find a tripod adapter for less than $20 online.
Once I spot the buck I want to pursue, I will watch him until he beds down. Once he is bedded, I plan my stalk. When planning your stalk, make sure you take note of the wind direction. Also, try to determine the wind direction where your buck is bedded, by looking for moving grass, brush, or trees. Make sure that you find some natural land marks (large boulder, group of trees etc.) near your bedded buck so that you know when you are getting close. Nothing ever looks the same as it did through your binoculars.
When I get within 300 yards of the bedded buck, I will slow down to a snail's pace. This is the hardest and most important part of the stalk. It will usually take me two hours or more to cover this distance, depending on the available cover. Try to keep a natural object between you and the bedded buck, so that it can block some of your movement. I always keep a close eye on the buck to make sure he is not looking in my direction. When he is sleeping or looking in the other direction, use this to your advantage and cover some ground. The last 100 yards will be the hardest part. Remember all of these tips and remember to SLOW DOWN and have patience.
All the information that the Do-It-Yourself bow hunter needs.
Click on the "Map Locator" button to download free USGS Quad/Topography Maps.
Once you decide what map you need, add it to your "shopping cart". Then, from inside the "shopping cart" click on the map. You will then be able to download the map for free.
This is where I live and hunt. Lots of deer, but LOTS of hunters too. You have to work pretty hard to find the really good bucks, coues and muleys, but it's not impossible.
Mule Deer is my favorite thing to hunt, even though I have been more successful with the elk in Colorado. If time allows this year I and a hunting buddy might shoot down and Take a shot at a over the counter tag in Arizona. Is there a lot of back country away from roads down there? Ya know to back pack in a few miles to hunt away from the crowds?
There are some areas where you can get way back...but we normally have a base camp and hunt out of it everyday.


TSA is an agency of the U.S. Department of Homeland Security that has authority over the security of the traveling public in the United States.
FMC is an independent federal agency, based in Washington, D.C., responsible for the regulation of ocean borne international transportation of the U.S.
IAM is the moving industry's trade association. Our members are auditing, forwarding, shipping and moving companies from around the world.
The TX DOT is a government agency in the Texas USA & responsible for overseeing aviation, rail and public transportation systems in the Texas.
The BBBis a nonprofit organization focused on advancing marketplace trust consisting of 112 independently incorporated local BBB organizations.
global courier delivery Services Company headquartered in Memphis, Tennessee.
DHL Express is a division of the German logistics company Deutsche Post DHL providing international express mail services.
Movers.com is network of the licensed and insured companies in the industry. Members are screened & accredited for moving services.