The Institute of International Bankers proposed a framework to exempt certain qualifying non-US transactions from the Securities and Exchange Commission’s Treasury securities Trade Submission Requirement. It maintains that these transactions should not face activity or volume limits because they lack a meaningful US nexus and would present operational, logistical and legal enforceability challenges if submitted for clearing. If the SEC nevertheless imposes a limit, firms would be able to apply the greater of a firm-specific cap or a market-wide measure to qualifying repo and reverse repo transactions. The framework would phase in any percentage cap starting at 25%, weight each quarter in an assessment period equally and recalibrate the market-wide measure annually. Firms could exceed the cap by up to 20% for one assessment period without an adverse consequence. The market-wide alternative is intended to accommodate internationally headquartered firms that provide Treasury market access to local non-US clients. The institute argued that relying solely on firm-specific limits could prompt firms to leave Treasury securities covered clearing agencies or lead non-US clients to reduce Treasury investments.
2026-09-01Institute of International Bankers
US Institute of International Bankers proposes flexible exemption framework for clearing non-US Treasury trades
The Institute of International Bankers proposed a flexible exemption for qualifying non-US transactions from the SEC’s Treasury trade submission requirement. If a volume condition is imposed, firms could use the greater of a firm-specific cap or a market-wide measure, with any cap phased in from 25% and limited tolerance for a temporary breach.