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MFA submits comments to SEC on FICC GSD rules relating to the adoption of a trade submission requirement

MFA submitted a comment letter to SEC on FICC GSD rules relating to the adoption of a trade submission requirement.

The letter highlights two main concerns with the proposal:

  • The Proposal is anti-competitive and should be withdrawn. The Proposal seeks to prohibit netting members and their customers from clearing and settling transactions with any other SEC registered clearing agency, creating a de facto monopoly for FICC as the only clearing agency for U.S. Treasuries.
  • FICC proposes costly new ongoing membership requirements, which would be costly, unnecessary and will further limit the availability of direct membership.
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