Nov. 7, 2023
Hello my comments are below, I am a retail trader who wants to be more informed in SEC rule making and I do think this rule is great for transparency by utilizing central clearing for Treasury securities. It was noted that 13% of Treasuries are cleared centrally and about 19% are cleared dually. Sources: https://www.dallasfed.org/research/economics/2022/1223#:~:text=Outright%2C%20or%20cash%2C%20Treasury%20transactions,trillion%20on%20a%20typical%20day. I do believe expanding on the central clearing will improved safety and soundness of the US Treasury securities market, reduced counterparty risk: having a CCP guarantees settlement even if one of the CCP fails to meet on their obligation, increased market efficiency through netting out trades and settling them on a multilateral basis and most importantly, enhanced transparency in a market of ambiguity. Central clearing of US Treasury securities would provide centralized reporting of all cleared trades which should make it easier for regulators (like you all) to monitor the market and identify potential risks. I do know the proposed rule will apply the broker-dealer customer protection rule to US Treasury securities fund advisers which is great for consumer protection as well. Overall I am in great support of this proposed rule, and I hope CCP, ISDA, as well as broker-dealers will adjust accordingly when the rule is accepted and implemented.