The Institute of International Bankers (IIB) submitted a comment letter responding to the US Securities and Exchange Commission’s request for comment on proposed exemptive relief, backing a targeted exemption from certain US Treasury clearing requirements for transactions with no meaningful US nexus. The letter argues that extraterritorial application could subject non-US activity to unnecessary clearing obligations and create legal, operational, and cost challenges. IIB recommends exempting eligible secondary market transactions between non-US participants and non-US clients from the Trade Submission Requirement, and supports a broader framework that would also address certain transactions involving foreign affiliates and foreign branches to promote consistent treatment across market structures. It also warns that absent relief, firms may restructure repo activity or withdraw from direct participation in US Treasury clearing, potentially increasing costs, reducing participation, and limiting efficient access to clearing.
Institute of International Bankers 2026-04-14
Institute of International Bankers supports SEC exemption from Treasury trade submission clearing requirement for non-US transactions
The Institute of International Bankers submitted a comment letter to the US Securities and Exchange Commission supporting targeted exemptive relief from certain US Treasury clearing requirements for transactions with no meaningful US nexus. It argues that extraterritorial application would impose unnecessary burdens and recommends exempting eligible secondary market transactions between non-US participants and non-US clients from the Trade Submission Requirement, and addressing certain transactions involving foreign affiliates and branches. The letter warns that absent relief, firms may restructure repo activity or withdraw from direct participation in US Treasury clearing, increasing costs and limiting efficient access to clearing.