BPI and SIFMA Comment on Proposed Change to Collection of Non-Centrally Cleared Bilateral Transactions in the U.S. Repurchase Agreement Market

Dear Mr. Passante:

The Securities Industry and Financial Markets Association (“SIFMA”)[1] and the Bank
Policy Institute[2] (“BPI” and, collectively with SIFMA, the “Associations”) appreciate the
opportunity to comment on the Office of Financial Research’s (“OFR”) proposed rule change
(the “Proposal”) establishing a data collection covering non-centrally cleared bilateral
transactions in the U.S. repurchase agreement (“Repo”) market.[3] The Associations support
OFR’s proposal to collect data on the non-centrally cleared bilateral Repo market and its goal of
identifying and monitoring risks to financial stability through data collection. The Associations
have long recognized the importance of the official sector having the information necessary to
carry out its market supervision function and believes the Proposal furthers this objective.

To read the full comment letter, please click here, or click on the download button below.

[1]SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s one million employees, we advocate on legislation, regulation and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the

[2] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group, representing the nation’s leading banks and their customers. Our members include universal banks, regional banks and the major foreign banks doing business in the United States. Collectively, they employ almost 2 million Americans, make nearly half of the nation’s small business loans, and are an engine for financial innovation and economic growth.

[3] See 88 FR 1154 (January 9, 2023).

[4]See SIFMA, SIFMA AMG, IIB, ABASA letter to U.S. Department of Treasury, August 26, 2022, available here. Also see SIFMA letter to the OFR, September 10, 2018 on repo data collection in the cleared repo market, available here.