Eminence 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- The Proposal is anti-competitive and should be withdrawn.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.
