SEC Streamlines Trades: Extending Rule to Cut Global Paperwork
Published Date: 12/16/2025
Notice
Summary
The SEC is asking for feedback on extending a rule that helps banks and traders decide if their deals count as foreign or U.S. transactions. This rule lets parties share info once per trading relationship, saving time and cutting paperwork. No big costs or changes are expected, but folks involved in security-based swaps should keep an eye on this to stay in the know.
Analyzed Economic Effects
3 provisions identified: 1 benefits, 2 costs, 0 mixed.
Costs for ~4,200 non‑U.S. counterparties
The SEC estimates about 4,200 non-U.S. counterparties will provide representations that they are not U.S. persons. The Commission estimates up to 5 hours each to develop disclosures (about 21,000 hours total), outside-professional cost per respondent of about $2,715 (five hours at $543/hour), an annualized labor cost per respondent of $905, and aggregate annualized costs of about $3.8 million (total $11.4 million over three years).
Once‑per‑relationship paperwork rule
If you are a party to security-based swaps, Rule 3a71-3 allows you to make representations once per trading relationship (not for each trade) about whether a deal is through a foreign branch or whether a counterparty is a U.S. person. The rule lets counterparties exchange this language in representation letters or trading documentation to reduce repeated paperwork and operational costs.
Compliance burden on nine U.S. banks
The SEC estimates nine U.S. banks (registered as security-based swap dealers) will incur burdens under this collection. The Commission previously estimated a one-time disclosure development of up to 5 hours and up to $2,000 in outside-professional costs per U.S. bank, and it now estimates an ongoing verification burden of about 10 hours per U.S. bank (about 90 hours total across the nine banks).
Your PRIA Score
Personalized for You
How does this regulation affect your finances?
Sign up for a PRIA Policy Scan to see your personalized alignment score for this federal register document and every other regulation we track. We analyze your financial profile against policy provisions to show you exactly what matters to your wallet.
Key Dates
Department and Agencies
Related Federal Register Documents
2026-10373 — Registered Offering Reform
The SEC wants to make it easier and cheaper for more companies to sell their stocks and bonds to the public. They’re opening up special forms and benefits to more businesses, updating rules to be more modern, and cutting red tape by overriding some state rules. If you’re a company planning to raise money, these changes could speed things up and save you money, with feedback due by July 27, 2026.
2026-10222 — Enhancement of Emerging Growth Company Accommodations and Simplification of Filer Status for Reporting Companies
The SEC is making it easier for companies that report their finances by simplifying their categories into just two groups: big and small filers. Smaller companies, including emerging growth ones, will get more time to file reports and enjoy simpler rules, while big companies keep stricter standards. These changes aim to save time and money, with feedback open until July 20, 2026.
2026-07651 — Concept Release on Consolidated Audit Trail and Other Audit Trails and Data Sources
The SEC wants your thoughts on how it tracks stock market trades using the Consolidated Audit Trail and other data tools. They’re thinking about updating rules to keep up with new tech, privacy, and security needs, and to make sure the system is fair and cost-effective. If you’re involved in the stock market or data tracking, speak up by June 22, 2026!
2026-11810 — Self-Regulatory Organizations; Cboe EDGX Exchange, Inc.; Notice of Filing and Immediate Effectiveness of a Proposed Rule Change To Adopt Fees for Its New Clock Service
Cboe EDGX Exchange just rolled out a new Clock Service that helps users sync their time systems perfectly with the Exchange. Starting May 18, 2026, they’re charging fees for this service but also offering a free trial to get everyone on board. This affects both members and non-members who want precise timing for their trading activities.
2026-11812 — Self-Regulatory Organizations; Cboe EDGA Exchange, Inc.; Notice of Filing and Immediate Effectiveness of a Proposed Rule Change To Adopt Fees for Its New Clock Service
Cboe EDGA Exchange just rolled out a new Clock Service to help traders sync their time systems perfectly. Starting May 18, 2026, users can try it for free, but after that, there will be fees for using this handy tool. This change affects anyone who wants precise timing for trading and keeps things running smoothly.
2026-11809 — Self-Regulatory Organizations; Cboe BZX Exchange, Inc.; Notice of Filing and Immediate Effectiveness of a Proposed Rule Change To Adopt Fees for Its New Clock Service
Cboe BZX Exchange just rolled out a new Clock Service that helps users sync their time systems with the Exchange’s for better accuracy. Starting May 18, 2026, they’re charging fees for this service but offering a free trial to get everyone started. This affects both members and non-members who want precise timing for their trading activities.
Previous / Next Documents
Previous: 2025-22943 — GR Catalyst Two, LLC; Notice of Revised Procedural Schedule
GR Catalyst Two, LLC’s schedule for the Dahowa Hydroelectric Project license is getting a fresh update! Key steps like acceptance, public comments, and environmental reviews now have new target dates in mid-2026. This keeps the project moving smoothly and on track, so everyone involved knows when to expect important decisions and actions.
Next: 2025-22945 — Agency Information Collection Activities; Proposed Collection; Comment Request; Extension: Rule 19b-1
The SEC wants to keep the rules that control how often investment funds can share their long-term profits with investors, making sure everything stays clear and fair. This affects investment companies and unit investment trusts, who must follow notice rules or ask permission for special payouts. The SEC is asking for public comments before extending these rules, with no new costs or big changes planned.