Notice2026-07775

Notice of Request for Exemptive Relief, Pursuant to Section 36(a) of the Securities Exchange Act of 1934, From Certain Aspects of Rule 17ad-22(e)(18)(iv) of the Securities Exchange Act of 1934 and Request for Comment

Primary source

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Published
April 22, 2026

Issuing agencies

Securities and Exchange Commission

Full Text

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<title>Federal Register, Volume 91 Issue 77 (Wednesday, April 22, 2026)</title>
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[Federal Register Volume 91, Number 77 (Wednesday, April 22, 2026)]
[Notices]
[Pages 21533-21537]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-07775]


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SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-105262; File No. S7-2026-11]


Notice of Request for Exemptive Relief, Pursuant to Section 36(a) 
of the Securities Exchange Act of 1934, From Certain Aspects of Rule 
17ad-22(e)(18)(iv) of the Securities Exchange Act of 1934 and Request 
for Comment

April 17, 2026.

I. Introduction

    On December 13, 2023, the Securities and Exchange Commission (the 
``Commission'') adopted,\1\ among other things, Rule 17ad-
22(e)(18)(iv)(A) (the ``Trade Submission Requirement'') \2\ under the 
Securities Exchange Act of 1934 (``Exchange Act''). Under these 
amendments, covered clearing agencies that provide central counterparty 
services for U.S. Treasury securities (``U.S. Treasury securities 
CCAs'') \3\ must establish, implement, maintain, and enforce written 
policies and procedures reasonably designed to establish objective, 
risk-based, and publicly disclosed criteria for participation which 
require that any direct participant of a U.S. Treasury securities CCA 
submit for clearance and settlement all of the eligible secondary 
market transactions to which such direct participant is a counterparty 
and identify and monitor the U.S. Treasury securities CCA's direct 
participants' submission of transactions for clearing pursuant to the 
Trade Submission Requirement. An ``eligible secondary market 
transaction'' is, in turn, defined as (i) a repurchase or reverse 
repurchase agreement collateralized by U.S. Treasury securities, in 
which one of the counterparties is a direct participant (``repo''); or 
(ii) a purchase or sale, between a direct participant and: (A) any 
counterparty, if the direct participant of the covered clearing agency 
brings together multiple buyers and sellers using a trading facility 
(such as a limit order book) and is a counterparty to both the buyer 
and seller in two separate transactions; or (B) a registered broker-
dealer, government securities broker, or government securities 
dealer.\4\
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    \1\ Standards for Covered Clearing Agencies for U.S. Treasury 
Securities and Application of the Broker-Dealer Customer Protection 
Rule With Respect to U.S. Treasury Securities, Securities Exchange 
Act Release No. 99149 (Dec. 13, 2023), 89 FR 2714, 2737 (Jan. 16, 
2024) (``Adopting Release'').
    \2\ 17 CFR 240.17ad-22(e)(iv)(A).
    \3\ The U.S. Treasury securities CCAs are the Fixed Income 
Clearing Corporation (``FICC''), the CME Securities Clearing Corp. 
(``CMESC''), and ICE Clear Credit, LLC (``ICC''). For purposes of 
this notice, the Commission refers generally to U.S. Treasury 
securities CCAs, as the issues raised by SIFMA apply equally to all 
U.S. Treasury securities CCAs, unless otherwise noted.
    \4\ 17 CFR 240.17ad-22(a).
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    An ``eligible secondary market transaction'' does not include any 
repo entered into between a direct participant and an affiliated 
counterparty (the ``Inter-Affiliate Exclusion''), provided that the 
affiliated counterparty submits for clearance and settlement all other 
repos to which the affiliated counterparty is a party (the ``outward-
facing condition'').\5\ An ``affiliated counterparty'' is any 
counterparty which meets the following criteria: (i) the counterparty 
is either a bank (as defined in 15 U.S.C. 78c(6)), broker (as defined 
in 15 U.S.C. 78c(4)), dealer (as defined in 15 U.S.C. 78c(5)), or 
futures commission merchant (as defined in 7 U.S.C. 1a(28)), or any 
entity regulated as a bank, broker, dealer (together with broker, 
``BD''), or futures commission merchant (``FCM'') in its home 
jurisdiction (the ``bank/BD/FCM condition''); (ii) the counterparty 
holds, directly or indirectly, a majority ownership interest in the 
direct participant, or the direct participant, directly or indirectly, 
holds a majority ownership interest in the counterparty, or a third 
party, directly or indirectly, holds a majority ownership interest in 
both the direct participant and the counterparty; and (iii) the 
counterparty, direct participant, or third party referenced in 
paragraph (ii) of this definition as holding the majority ownership 
interest would be required to report its financial statements on a 
consolidated basis under U.S. Generally Accepted Accounting Principles 
or International Financial Reporting Standards, and such consolidated 
financial statements include the financial results of the majority-
owned party or of both majority-owned parties.\6\
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    \5\ Id.
    \6\ Id.
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    On April 10, 2026, a trade association submitted a letter to the 
Commission requesting exemptive relief in two areas related to the 
Trade Submission Requirement. First, the trade association requested 
exemptive relief to expand the Inter-Affiliate Exclusion to the Trade

[[Page 21534]]

Submission Requirement.\7\ Specifically, the trade association 
requested that the definition of an ``affiliated counterparty'' be 
expanded to include all affiliates, except for investment company 
entities.\8\ Second, the trade association requested that the outward-
facing condition not include repo transactions between non-U.S. 
affiliates and non-U.S. counterparties, to the extent that the direct 
participant does not exceed a specific activity level threshold for 
those transactions, as discussed further below.\9\ We are publishing 
this notice to provide interested persons with an opportunity to 
comment on these requests for exemptive relief.
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    \7\ See Letter from Robert Toomey, Head of Capital Markets, 
Managing Director/Associate General Counsel, Securities Industry and 
Financial Markets Association (``SIFMA'' or ``trade association''), 
dated April 10, 2026, available at <a href="https://www.sifma.org/wp-content/uploads/2026/04/SIFMA-Section-36-Exemptive-Relief-Request-for-Interaffiliate-Transactions.pdf">https://www.sifma.org/wp-content/uploads/2026/04/SIFMA-Section-36-Exemptive-Relief-Request-for-Interaffiliate-Transactions.pdf</a> (``SIFMA Letter'').
    \8\ See SIFMA Letter, supra note 7, at 7-8.
    \9\ See id. at 8-9.
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II. Discussion and Requested Relief

    As noted above, the trade association made certain requests for 
exemptive relief from the Inter-Affiliate Exclusion. The trade 
association stated that the relief is needed for critical treasury, 
liquidity, and collateral management reasons.\10\ The trade association 
stated that repo transactions are a critical internal liquidity 
management tool for large financial institutions and allow affiliated 
entities, including non-U.S. affiliates, to hold U.S. dollars in a safe 
and liquid asset.\11\ The trade association further stated that, 
although the Inter-Affiliate Exclusion does provide an exemption for 
the clearing requirement for certain inter-affiliate repos, the 
restrictions on its availability effectively negate its utility, with 
these restrictions being that only a limited number of affiliates are 
permitted to rely on the Inter-Affiliate Exemption, and that, in order 
to use the exemption, an affiliate must centrally clear all outward-
facing repos pursuant to the outward-facing condition.\12\
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    \10\ See id. at 3.
    \11\ See id.
    \12\ See id. at 2.
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    The trade association stated that, because of the limitations of 
the bank/BD/FCM condition and the outward-facing condition, repo 
transactions for treasury, liquidity, and collateral risk management 
(``TLC Repo Transactions'') are potentially subject to a clearing 
requirement with negative consequences for the financial markets.\13\ 
According to the trade association, these consequences would include:
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    \13\ See id. at 4.
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    <bullet> If an affiliate of a direct participant faced an immediate 
liquidity or collateral need after a U.S. Treasury securities CCA 
closes, the direct participant would not be able to get that liquidity 
or collateral to the affiliate via a repo transaction until a covered 
clearing agency opened, posing risk to the affiliate and to its 
customers and the broader financial market.\14\ The trade association 
explained that this problem especially applies to non-U.S. affiliates 
operating in time zones outside of the U.S. Treasury securities 
CCA.\15\
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    \14\ See id. at 5-6. In its letter, SIFMA referred specifically 
to FICC, which is currently the only operational U.S. Treasury 
securities CCA. SIFMA notes that, while it is possible that CMESC 
and ICC will have longer opening hours than FICC, it is not clear if 
any of the U.S. Treasury securities CCAs will offer 24/7/365 
clearing services. See id. at 6.
    \15\ See id. at 6.
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    <bullet> Increased affiliate clearing would create exposures to a 
covered clearing agency for the affiliates on both sides of the 
transaction, unnecessarily grossing up the corporate group's overall 
risk exposure to the covered clearing agency.\16\ This could constrain 
a direct participant's capacity to clear third-party repo activity 
because, when calculating its risk limits, it would need to account for 
this inter-affiliate activity (i.e., balance sheet capacity allocated 
to centrally cleared affiliate transactions that could be used to clear 
third-party repos would instead have to be used to clear affiliate 
repos).\17\
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    \16\ See id.
    \17\ See id.
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    <bullet> Increased affiliate clearing would also make affiliate 
transactions needlessly more expensive, as both affiliates would need 
to post margin to the covered clearing agency, despite the fact that 
the group's overall consolidated exposure would be flat.\18\
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    \18\ See id.
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    <bullet> Increased affiliate clearing would also increase the 
systemic importance of a U.S. Treasury securities CCA and augment the 
complexities that could arise if operational issues or member defaults 
were to occur.\19\
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    \19\ See id.
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    <bullet> TLC Repo Transactions are an important tool for a firm to 
manage its applicable capital and liquidity requirements, as U.S. 
Treasury securities are a low-risk asset with deep liquidity that can 
be moved across the organization quickly as needed.\20\ Imposing a 
clearing requirement on inter-affiliate transactions could lead to 
serious delays and cost increases for organizations for business-as-
usual transactions used to comply with applicable regulations, which 
could increase systemic liquidity risk during market stress.\21\
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    \20\ See id. at 4.
    \21\ See id. at 5. Specifically, SIFMA stated that repos for 
treasury, liquidity, or collateral management assist firms in 
complying with the Basel III Liquidity Coverage Ratio, which 
requires firms to maintain consolidated access to high-quality 
liquid assets, such as U.S. Treasury securities, to meet stress-
period outflows. See id. SIFMA also stated that banks use such repos 
to transfer liquidity to affiliates without facing the restrictions 
of the Federal Reserve Board's Regulation W, which places 
quantitative limits on the extensions of credit a bank may make to 
its affiliates but also exempts an extension of credit (including 
repos) from those limits to the extent they are secured by U.S. 
Treasury securities. See id.
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    <bullet> Given that TLC Repo Transactions are a crucial way to move 
liquidity across an organization quickly, TLC Repo Transactions may be 
relied upon heavily in an insolvency or resolution, and the clearing 
requirement could lead to serious delays when liquidity is needed 
most.\22\
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    \22\ See id.
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    <bullet> The trade association stated that repos are also an 
essential method for non-U.S. affiliates to hold and manage U.S. dollar 
assets, because such non-U.S. affiliates do not generally have direct 
access to Federal Reserve master accounts, making U.S. Treasury 
securities an important way to hold U.S. dollar assets.\23\ In 
addition, a non-U.S. affiliate that holds U.S. dollars may prefer not 
to deposit the dollars with another affiliate, since credit exposure 
regulations in other jurisdictions may treat such a deposit as an 
unsecured exposure to the affiliate and a repo transaction may receive 
more favorable treatment under the applicable credit exposure 
regulations because the transaction is securities.\24\ A clearing 
requirement could make holding Treasuries more expensive for non-U.S. 
affiliates, impeding their ability to hold these essential assets.\25\
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    \23\ See id.
    \24\ See id.
    \25\ See id. SIFMA further explained that repo transactions on 
other U.S. dollar-denominated assets may also be constrained by 
applicable capital and liquidity regulations (e.g., less favorable 
treatment of U.S. agency mortgage-backed securities under the Basel 
III Liquidity Coverage Ratio in foreign jurisdictions). See id.
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    In addition, the trade association stated that the outward-facing 
condition provides no flexibility to firms, imposing a blanket clearing 
requirement regardless of the actual level of risk.\26\ The trade 
association further stated that, currently, a direct participant would 
be required to clear all repos with an affiliate that is not a bank, 
BD, or FCM (together, ``Limited Covered Affiliates''), and with respect 
to affiliates that are banks, BDs, or FCMs, a firm is faced

[[Page 21535]]

with one of two options to comply with the Outward-Facing Condition: 
clear all Repo Transactions between the bank, BD, or FCM affiliate and 
the Direct Participant (i.e., not take advantage of the Inter-Affiliate 
Exemption), or clear all the Limited Covered Affiliate's Outward-Facing 
Repo Transactions (which, as explained in more detail below, may not be 
feasible for non-U.S. affiliates that trade with non-U.S. 
counterparties).\27\
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    \26\ See id. at 7.
    \27\ See id. at 4.
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    The trade association requested exemptive relief in two areas. 
First, the trade association asked that the Commission provide 
exemptive relief to make the Inter-Affiliate Exemption available to all 
affiliates, except ``investment company'' affiliates.\28\ This request 
would expand the list of permitted affiliates with whom direct 
participants of a U.S. Treasury securities CCA could transact and rely 
upon the Inter-Affiliate Exclusion beyond the current set (i.e., banks, 
broker-dealers, futures commission merchants, and their foreign 
equivalents) to include any entity that is not an investment company 
(as defined in section 3 of the Investment Company Act of 1940 (15 
U.S.C. 80a-3)), regardless of whether such investment company is 
registered or required to be registered under that act.\29\ The trade 
association identified other potential types of entities that would 
then be encompassed within the rule as swap dealers, the top-tier bank 
holding company, and intermediate holding company affiliates, and 
stated that many of these affiliates, particularly the holding company 
entities, do not have external activity (i.e., they are not customer-
facing entities).\30\
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    \28\ See id. at 7-8. SIFMA stated this limitation would ensure 
that neither any registered investment company nor any private fund 
(i.e., an issuer that meets the definition of ``investment company'' 
under section 3(a)(1) of that Act, but relies on one of the 
exemptions from registration thereunder) may rely on this proposed 
exemptive relief to enter into uncleared repo transactions with an 
affiliated direct participant. See id. at 8.
    \29\ See id. at 7-8.
    \30\ See id. at 7.
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    The trade association explained that, by allowing additional types 
of affiliated counterparties to be able to use the Inter-Affiliate 
Exclusion, affiliates of direct participants of U.S. Treasury 
securities CCAs would be able to conduct uncleared repo transactions 
with their direct participant, which is essential to allowing 
affiliates to effectively manage liquidity and collateral needs without 
unnecessary costs and delays.\31\ In addition, the trade association 
further explained that by allowing the use of additional types of 
affiliated counterparties, the outward-facing condition would still 
apply, unless another form of relief were available, meaning that a 
firm would still not be able to use ``back-to-back'' repo transactions 
to transfer risk to a direct participant.\32\
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    \31\ See id. at 8.
    \32\ See id.
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    Second, the trade association requested that the Commission provide 
exemptive relief for non-U.S. affiliates, by exempting from the 
outward-facing condition to the Inter-Affiliate Exclusion repo 
transactions between non-U.S. affiliates and non-U.S. counterparties, 
including between two non-U.S. affiliates, to the extent that the 
direct participant is able to meet the following condition: the 
quotient of the following is less than 10 percent: (i) numerator 
transactions: uncleared repo transactions between all non-U.S. 
affiliates of the direct participant and their non-U.S. external 
counterparties,\33\ divided by (ii) denominator transactions: the sum 
of (x) all cleared eligible secondary market transactions that are repo 
transactions of all of a firm's direct participants,\34\ and (y) the 
numerator transactions.\35\ Regarding the denominator transactions, the 
trade association stated that including both all cleared eligible 
secondary market transactions that are repo transactions of a firm's 
direct participants and the numerator transactions would therefore 
encompass repo transactions that are subject to the clearing 
requirement, along with most of the repo transactions benefiting from 
the proposed threshold.
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    \33\ See id. at 8-9. SIFMA clarified that uncleared repo between 
two non-U.S. affiliates should be excluded from the numerator 
because they do not represent market-facing activity. See id. at 9.
    \34\ See id. at 9. SIFMA explained that this portion of the 
calculation refers to all of a firm's direct participants because 
this proposed condition should not be measured on a direct 
participant-by-direct participant basis, but rather across the 
entire organization. See id. at 10. In addition, SIFMA explained 
that cleared eligible secondary market transactions that are repo 
transactions of a firm's direct participant include those repo 
transactions that are subject to the clearing requirement but 
exclude those that are not (e.g., repo transactions between a direct 
participant and natural persons or central banks). See id.
    \35\ See id. at 9. SIFMA stated that this calculation should be 
performed as an average of outstanding daily open notional balances 
over each of the last three quarters, with more weight given to more 
recent quarters. See id. at 10. SIFMA stated that this methodology 
would ensure that short-term fluctuations in a firm's repo 
transaction activity do not unduly affect whether the relief is 
available, providing more predictability and stability. See id. 
Additionally, SIFMA clarified that uncleared repos between two non-
U.S. affiliates also should be excluded from the denominator for the 
same reason they should be excluded from the numerator. See id. at 
10, n. 25.
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    The trade association stated that the outward-facing condition 
would require that two non-U.S. affiliates of a direct participant 
clear a repo transaction between themselves if either affiliate wished 
to enter into an uncleared repo transaction with a direct participant, 
which would impose costs and burdens for this activity, who often use 
repo transactions to conduct treasury, liquidity, and collateral 
management activities.\36\
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    \36\ See id. at 9. SIFMA also stated that non-U.S. affiliates of 
direct participants engage in repos with non-U.S. counterparties who 
do not themselves engage in Repo Transactions at a level that makes 
onboarding them to clear through a U.S. Treasury securities CCA 
feasible. See id. at 6 (noting, as a example, FICC's operating hours 
and the relatively small list of approved jurisdictions for FICC's 
sponsored member service).
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    Specifically, the trade association stated that it would be unduly 
burdensome to effectively require non-U.S. affiliates to become direct 
or indirect participants of a U.S. Treasury securities CCA to use the 
Inter-Affiliate Exclusion, especially because repo transactions between 
non-U.S. affiliates are likely to be rather small in comparison to a 
firm's overall activity in eligible secondary market transactions that 
are repo transactions.\37\ The trade association also stated that, if a 
non-U.S. affiliate needed funding when U.S. Treasury securities CCAs 
are closed, which is particularly likely for non-U.S. affiliates who 
operate in different time zones worldwide, the non-U.S. affiliate would 
effectively be unable to obtain such funding through a repo transaction 
with another non-U.S. affiliate, causing unnecessary liquidity issues 
that could potentially have destabilizing ripple effects.\38\
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    \37\ See id. at 9.
    \38\ See id.
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    The trade association stated that 10 percent was an appropriate 
threshold because it represents a relatively small amount of uncleared 
repo transactions in comparison to a firm's overall activity in cleared 
eligible secondary market transactions, but that it would still be 
useful to non-U.S. affiliates.\39\ The trade association further stated 
that, as a practical matter, firms will almost certainly have to target 
a figure well below any regulatorily determined threshold to avoid 
inadvertently exceeding the threshold, such that making the threshold 
below 10 percent would make the requested relief of little practical 
use to firms, as the actual figure to which firms would need to manage 
would be too small to use in a meaningful way.\40\
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    \39\ See id. at 9.
    \40\ See id. at 10.
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    Finally, the trade association also stated that if a firm finds 
that it has materially exceeded the 10 percent threshold, it should be 
required to

[[Page 21536]]

report this fact to the Commission.\41\ The trade association further 
stated that if a firm reports multiple instances of exceeding the 10 
percent threshold, the Commission may consider imposing a limited 
clearing requirement to address the issue, subject to a sufficient 
timeline for implementation,\42\ and in any event, repos between two 
non-U.S. affiliates should not be subject to a clearing 
requirement.\43\
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    \41\ See id. at 11.
    \42\ See id. The trade association stated that such a clearing 
requirement should only be imposed to the extent needed to ensure 
the firm does not continue to exceed the 10% thresholds and should 
not be a blanket restriction on relying on the 10% non-U.S. 
affiliate relief. See id.
    \43\ See id.
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III. Request for Comment

    We request and encourage any interested person to submit comments 
on the requested relief, including whether the Commission should grant 
exemptive relief. In particular, we solicit comments on the following 
questions:
    1. Is the requested expansion of the types of affiliates that could 
qualify for the Inter-Affiliate Exclusion appropriate? Please explain.
    2. Is the 10 percent threshold appropriate? Please explain why or 
why not, and if possible, provide data to demonstrate why it is or is 
not. Would another threshold be appropriate and why?
    3. Are the calculations for the numerator and denominator 
appropriate? Please explain. Alternatively, should the numerator and 
denominator include repo transactions between two non-U.S. affiliates? 
Please explain.
    4. Should the numerator transactions and denominator transactions 
be calculated as an average of outstanding daily open notional balances 
over each of the last three quarters with more weight given to more 
recent quarters? Please explain why or why not. Would another method or 
period of time be appropriate for the calculation and why?
    5. Should the denominator transactions be measured across a direct 
participant's entire organization, as opposed to on a direct 
participant-by-direct participant basis? Please explain why or why not, 
and whether such an approach would also be appropriate for the 
numerator transaction.
    6. Would the requested relief impact how market participants 
structure their repo transactions or access central clearing (e.g., 
through an affiliated direct participant or by joining a U.S. Treasury 
securities CCA directly)? If so, please describe the impact and how 
this impact would occur.
    7. Would the requested relief impact competition between different 
types of firms or based on the firm's organizational structure or size? 
If so, please describe the impact on competition and how this impact 
would occur.
    8. Would the requested relief have any impact on existing U.S. 
reporting requirements (e.g., FINRA's TRACE reporting or the 
requirements with respect to certain non-centrally cleared bilateral 
repo reporting established by the Office of Financial Research within 
the U.S. Department of the Treasury \44\)? Please explain.
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    \44\ See 12 CFR part 1610.
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    9. Would the requested relief have any impact on liquidity and/or 
overall resiliency of the U.S. Treasury markets? If so, please describe 
the impact on liquidity and overall resiliency and how the impact would 
occur.
    10. Would the requested relief have any impact on foreign 
participation in U.S. Treasury markets? If so, please describe the 
impact on foreign participation and how the impact would occur.
    11. Would the requested relief impact contagion risk \45\ for U.S. 
Treasury securities CCAs, or systemic risk more broadly?
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    \45\ See Adopting Release, supra note 1, 89 FR at 2717, 2741-42.
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    12. Would the requested relief impact any of the benefits that the 
Commission identified as arising from the Trade Submission Requirement, 
such as decreasing counterparty credit risk, decreasing the risk of a 
disorderly member default, increasing multilateral netting? \46\
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    \46\ See id. at 2717-18.
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    13. Would the requested relief impact a U.S. Treasury securities 
CCA's ability to risk manage the transactions of its direct 
participants? If so, please describe the impact on a U.S Treasury 
securities CCA's risk management.
    14. As an alternative to the requested relief, should the 
Commission issue an exemption for a direct participant's inter-
affiliate transactions that are for treasury, liquidity, or collateral 
risk management purposes? If so, how should the Commission define such 
purposes, and what evidence could a direct participant use to 
demonstrate why such transactions are for treasury, liquidity, or 
collateral risk management purposes?
    15. Should the Commission include a self-reporting mechanism to the 
Commission in the event that a particular direct participant materially 
exceeds the 10 percent threshold, or any other threshold the Commission 
may condition the relief upon? If the Commission were to include such a 
mechanism, please describe how that mechanism would work. Should the 
Commission consider providing such a mechanism with reporting to 
another entity, such as the covered clearing agency or agencies of 
which that entity is a direct participant, its regulator, or some other 
entity?
    16. Additionally, what should be considered ``material'' when 
determining whether a firm has materially exceeded the 10 percent 
threshold, or any other threshold the Commission may condition the 
relief upon?
    17. If self-reporting should be made to the covered clearing 
agency, how would this reporting mechanism differ, if at all, from Rule 
17ad-22(e)(18)(iv)(B), which requires a covered clearing agency to 
identify and monitor its direct participants' submission of 
transactions for clearing as required by Rule 17ad-22(e)(18)(iv)(A), 
including how the covered clearing agency would address a failure to 
submit transactions in accordance with Rule 17ad-22(e)(18)(iv)(A)? 
Would some sort of self-reporting mechanism be burdensome to administer 
at one or more U.S. Treasury securities CCAs?
    18. Should the Commission include a limited clearing requirement, 
subject to a sufficient timeline for implementation, for firms who 
report multiple instances of exceeding the 10 percent threshold, or any 
other threshold the Commission may condition the relief upon? If so, 
what should the limited clearing requirement be? What form would such a 
limited clearing requirement take? Should such limited clearing 
requirement necessarily exclude repos between two non-U.S. affiliates? 
What would be a sufficient timeline for implementation?
    19. If the Commission were to grant the requested relief, should we 
modify any of the conditions in the request for exemptive relief? 
Should the Commission condition the requested relief on any additional 
requirements? If so, please describe what those conditions should be 
and why.
    20. How does the relief requested interact, if at all, with the 
relief requested by the Institute for International Bankers (``IIB'')? 
\47\ Are

[[Page 21537]]

there any competitive concerns that could arise if the Commission 
granted the relief, as noticed, in these two contexts? If so, should 
the Commission modify the exemptive relief for either or both requests? 
In what ways should either or both requests for exemptive relief be 
modified? As an example, to address competitive concerns, should the 
Commission impose a percentage threshold relief as a condition to the 
relief sought by IIB? If so, should that percentage threshold and the 
method of calculation be the same or would it need to be different? 
Also, should the Commission include a limited clearing requirement, 
subject to a sufficient timeline for implementation, for firms who 
report multiple instances of exceeding that threshold? Please explain.
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    \47\ See Notice of Request for Exemptive Relief, Pursuant to 
section 36(a) of the Securities Exchange Act of 1934, from Certain 
Aspects of Rule 17ad-22(e)(18)(iv) of the Securities Exchange Act of 
1934 and Request for Comment, Securities Exchange Act Release No. 
104944 (Mar. 6, 2026), 91 FR 12030 (Mar. 11, 2026) (``IIB 
request'').
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    21. Please describe how the requested relief would or would not 
protect investors and the public interest, consistent with sections 17A 
and 36 of the Exchange Act.
    22. Please describe how the requested relief would or would not 
help to facilitate the prompt and accurate clearance and settlement of 
securities transactions as well as the safeguarding of securities and 
funds, consistent with section 17A of the Exchange Act.
    Comments should be received on or before May 29, 2026. Comments may 
be submitted by any of the following methods:

Electronic Comments

    <bullet> Use the Commission's internet comment form (<a href="https://www.sec.gov/rules-regulations/exchange-act-exemptive-notices-orders">https://www.sec.gov/rules-regulations/exchange-act-exemptive-notices-orders</a>)
    or
    <bullet> Send an email to <a href="/cdn-cgi/l/email-protection#5220273e377f313d3f3f373c2621122137317c353d24"><span class="__cf_email__" data-cfemail="bdcfc8d1d890ded2d0d0d8d3c9cefdced8de93dad2cb">[email&#160;protected]</span></a>. Please include 
File Number S7-2026-11 on the subject line.

Paper Comments

    <bullet> Send paper comments to Secretary, Vanessa A. Countryman, 
Securities and Exchange Commission, 100 F Street NE, Washington, DC 
20549-1090.

All submissions should refer to File Number S7-2026-11. This file 
number should be included on the subject line if email is used. To help 
the Commission process and review your comments more efficiently, 
please use only one method. The Commission will post all comments on 
the Commission's internet website (<a href="https://www.sec.gov/rules-regulations/exchange-act-exemptive-notices-orders">https://www.sec.gov/rules-regulations/exchange-act-exemptive-notices-orders</a>). Do not include 
personal identifiable information in submissions; you should submit 
only information that you wish to make available publicly. We may 
redact in part or withhold entirely from publications submitted 
material that is obscene or subject to copyright protection.
    For further information, you may contact Elizabeth Fitzgerald, 
Assistant Director, at (202) 551-6036, or Heather Percival, Senior 
Special Counsel, at (202) 551-3498, in the Division of Trading and 
Markets; U.S. Securities and Exchange Commission, 100 F Street NE, 
Washington, DC 20549.

    By the Commission.

    Dated: April 17, 2026.
Vanessa A. Countryman,
Secretary.
[FR Doc. 2026-07775 Filed 4-21-26; 8:45 am]
BILLING CODE 8011-01-P


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Indexed from Federal Register on April 22, 2026.

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