SEC Seeks Comments on Easing Treasury Trade Reporting Rules
Published Date: 3/11/2026
Notice
Summary
The SEC is considering a request to ease some rules for foreign financial firms about reporting certain U.S. Treasury trades. This change would affect clearing agencies and their participants by possibly reducing paperwork and speeding up processes without impacting safety. The SEC wants your thoughts before deciding, with no immediate cost changes expected.
Analyzed Economic Effects
5 provisions identified: 2 benefits, 3 costs, 0 mixed.
Possible hit to Treasury liquidity and borrowing
The association warns that if foreign investors move away from U.S. Treasuries because of clearing requirements, it could materially increase the U.S. government's borrowing costs and harm Treasury market liquidity and resiliency; the association also said reduced cleared repo activity could affect SOFR.
Exemption targets Non‑U.S. Participant trades
The association requests an exemption so that an "eligible secondary market transaction" between a Non-U.S. Participant and a Non-U.S. Client would not have to be submitted for clearing under the Trade Submission Requirement. The notice defines a Non-U.S. Participant as a direct participant that is not a U.S. person, not a U.S. branch of a non-U.S. person, and not a non-U.S. person whose obligations are guaranteed by a U.S. person.
Foreign legal and timing hurdles for firms
The association says foreign direct participants face legal uncertainty about enforceability of netting in some jurisdictions and may face foreign broker-registration questions. It also notes operational issues because no U.S. Treasury clearing agency currently operates 24 hours, which can prevent timely submission for trades in other time zones.
Less clearing choice could raise access costs
The association warns that if some foreign firms withdraw as direct participants or if non-U.S. counterparties avoid U.S. clearing, market participants accessing clearing indirectly could lose choice of clearing firms and face higher costs to access clearing services.
Request could reduce clearing paperwork
The SEC is considering an exemption that would let certain foreign-to-foreign U.S. Treasury trades avoid the Rule 17ad-22(e)(18)(iv) trade-submission requirement. If granted, clearing agencies and their direct participants could see reduced paperwork and faster processing; the SEC is asking for comments by April 10, 2026.
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