Comments on FICC Rulemaking

Self-Regulatory Organizations; Fixed Income Clearing Corporation; Notice of Filing of Proposed Rule Change to Modify the GSD Rules (i) Regarding the Separate Calculation, Collection and Holding of Margin for Proprietary Transactions and That for Indirect Participant Transactions, and (ii) to Address the Conditions of Note H to Rule 15c3-3a

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Date Received
Date Letter Type Commenter Name
Public Comment Jennifer W. Han, Executive Vice President, Chief Counsel and Head of Global Regulatory Affairs, Managed Funds Association
Meeting with SEC Officials Memorandum from the Office of Commissioner Hester M. Peirce regarding a November 4, 2024, meeting with representatives of the Depository Trust & Clearing Corporation
Public Comment Fixed Income Clearing Corporation
Public Comment Joanna Mallers, Secretary, FIA Principal Traders Group
Meeting with SEC Officials Memorandum from the Office of Public Engagement regarding a July 16, 2024 meeting with representatives of DTCC
Meeting with SEC Officials Memorandum from the Office of Commissioner Hester M. Peirce regarding an August 5, 2024, meeting with representatives of the AIMA
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding an August 19, 2024 meeting with representatives of BlackRock, Inc.
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding an August 23, 2024 meeting with representatives of Pacific Investment Management Company LLC
Meeting with SEC Officials Memorandum from the Office of Public Engagement regarding a July 10, 2024 meeting with representatives of FIA
Public Comment Laura Klimpel, Managing Director, Head of Fixed Income and Financing Solutions, The Depositry Trust & Clearing Corporation
Meeting with SEC Officials Memorandum from the Office of Commissioner Jaime Lizárraga regarding a July 31, 2024 meeting with representatives of DTCC
Public Comment Robert Toomey, Head of Capital Markets, Managing Director/Associate General Counsel, SIFMA
Public Comment Katherine Darras, General Counsel, International Swaps and Derivatives Association
Meeting with SEC Officials Memorandum from the Office of Commissioner Caroline Crenshaw regarding a July 17, 2024,meeting with representatives of the the Alternative Investment Management Association
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding a July 11, 2024 meeting with representatives of the Investment Company Institute and Securities Industry and Financial Markets Association, Asset Management Group
Public Comment Sarah A. Bessin, Deputy General Counsel, Investment Company Institute and Nhan Nguyen, Associate General Counsel, Investment Company Institute
Meeting with SEC Officials Memorandum from the Division of Trading and Marketing regarding a June 18, 2024, meeting with representatives of the Alternative Investment Management Association
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a May 30, 2024 meeting with representatives of the AIMA
Meeting with SEC Officials Memorandum from the Office of Public Engagement regarding a May 17, 2024 meeting with FIA PTG
Public Comment William C. Thum, Managing Director and Assistant General Counsel, SIFMA Asset Management Group
Meeting with SEC Officials Memorandum from the Office of Commissioner Mark T. Uyeda regarding a May 23, 2024, meeting with representatives of the Alternative Investment Management Association
Public Comment Robert Toomey, Head of Capital Markets, Manging Director/Associate General Counsel, Securities Industry and Financial Markets Association
Meeting with SEC Officials Memorandum from the Office of Clearance and Settlement, Division of Trading and Markets regarding an April 24, 2024, meeting with representatives of the Independent Dealer and Trader Association
Public Comment Jiri Krol, Deputy CEO, Global Head of Government Affairs, Alternative Investment Management Association
Public Comment Walt Lukken, President & Chief Executive Officer, The Futures Industry Association
Public Comment Jennifer W. Han, Executive Vice President, Chief Counsel and Head of Global Regulatory Affairs, Managed Funds Association
Public Comment Joanna Mallers, FIA PTG, Futures Industry Association
Public Comment Katherine Darras, General Counsel, International Swaps and Derivatives Association, Inc.
Public Comment Sarah A. Bessin, Deputy General Counsel, and Nhan Nguyen, Associate General Counsel, Investment Company Institute
Public Comment Rob Toomey, SIFMA; William Thum, SIFMA AMG; Sarah Bessin, ICI; Katherine Darras, ISDA; Jiri Krol, AIMA, SIFMA, SIFMA AMG, ICI, ISDA, AIMA

Last Reviewed or Updated: Dec. 18, 2025

File Number
SR-FICC-2024-007
Release Number
34-99844
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