For Your Review by Noon Friday 12/15: ICI Draft Letter on FINRA Proposal to Disseminate Transaction-Level Data for US Treasury Securities

[35543]

December 13, 2023

TO: Fixed-Income Advisory Committee
Money Market Funds Advisory Committee
SEC Rules Committee RE: For Your Review by Noon Friday 12/15: ICI Draft Letter on FINRA Proposal to Disseminate Transaction-Level Data for US Treasury Securities

 

Attached for your review is ICI's draft comment letter to FINRA's proposed rule change to disseminate transaction-level data in US Treasury securities that are On-the-Run Nominal Coupons on an end-of-the-day basis. ICI plans on filing the letter to the SEC by COB this Friday, December 15.  Please provide me with any feedback or comments by email at nhan.nguyen@ici.org no later than noon on Friday.

ICI's letter, which is largely consistent with the comments provided to the US Treasury Department to its 2022 Request for Information, expresses support for FINRA's proposal. This support is based in part on measures that FINRA has incorporated to address information leakage concerns, including limits on the scope of Treasury securities to On-the-Run Nominal Coupons, delayed reporting until the end of the day, and dissemination cap levels for larger-sized transactions. However, the letter also urges FINRA to share more detail as to how it developed this framework, including the methods and/or metrics for setting the cap levels. The letter states that this information would help market participants assess whether changes in liquidity conditions should warrant recalibrating dissemination requirements in the future and evaluate any further regulatory enhancements to transaction-level reporting.

Please let me know if you have any questions or concerns.

 

Nhan Nguyen
Assistant General Counsel, Securities Regulation