The U.S. Securities & Exchange Commission published for public comment a request from the Securities Industry and Financial Markets Association for exemptive relief that would modify the Treasury Clearing Rule’s inter-affiliate exemption, and it reopened the comment period on the Institute of International Bankers’ earlier request addressing the extraterritorial application of the Trade Submission Requirement. SIFMA’s request would expand the set of affiliates eligible to rely on the inter-affiliate exemption and add a tailored activity-based threshold for certain non-U.S. affiliate transactions, with a focus on inter-affiliate repo activity used for internal liquidity, treasury, and collateral management where clearing agencies do not operate on a 24-hour basis. The reopened IIB request focuses on transactions executed entirely outside the United States between non-U.S. institutions, with cited concerns including operational challenges, uncertainty over enforceability of netting arrangements, and time-zone constraints. The SEC invited data-driven feedback on liquidity, competition, and how the two potential exemptions could interact in practice. The update sits alongside earlier SEC actions supporting implementation, including approvals enabling customer cross-margining of cleared U.S. Treasury cash and futures positions, registration of new clearing agencies for Treasury securities, and Fixed Income Clearing Corporation changes intended to broaden client access to clearing. SEC staff continue to assess treatment of failed trades, clearing agency outages, and customer protection issues ahead of the Treasury Clearing Rule compliance dates of 31 December 2026 for eligible cash market transactions and 30 June 2027 for eligible repo market transactions.
U.S. Securities & Exchange Commission 2026-04-20
U.S. Securities & Exchange Commission seeks comment on SIFMA inter-affiliate exemption relief and reopens IIB extraterritorial request for the Treasury clearing mandate
The U.S. Securities & Exchange Commission published for comment a Securities Industry and Financial Markets Association request for exemptive relief to modify the Treasury Clearing Rule’s inter-affiliate exemption and reopened the comment period on an Institute of International Bankers request on the extraterritorial application of the Trade Submission Requirement. The SIFMA request would broaden affiliates eligible for the exemption and add an activity-based threshold for certain non-U.S. affiliate repo transactions, while the IIB request targets trades executed entirely outside the United States between non-U.S. institutions. The SEC is seeking data-driven feedback on liquidity, competition and how the potential exemptions interact ahead of the Treasury Clearing Rule compliance dates.