BPI, SIFMA and FSF Encourage Fed to Grant Additional Time to Comply with Treasury Securities and Agency Debt and Mortgage-Backed Securities Reporting Requirements

The Bank Policy Institute, the Securities Industry and Financial Markets Association, and the Financial Services Forum (collectively, the Associations)1 are writing to respectfully request that the Federal Reserve take immediate action to provide additional time for full compliance with the Treasury Securities and Agency Debt and Mortgage-Backed Securities Reporting Requirements (FR 2956).

The Associations are supportive of the Federal Reserve’s goal surrounding the development of the FR 2956, which, as indicated in the procedural record, was undertaken to “allow the U.S. official sector a more complete view of Treasury securities trading in the secondary market.”2 However, in light of the expansive scope of the final FR 2956, which was finalized largely as proposed and did not accept the recommendation for more tailored reporting requirements in the earlier BPI/SIFMA comment letter (BPI/SIFMA Comment Letter),3 the Associations have significant concerns around the September 1, 2022 effective date for the full scope of required FR 2956 reporting. Therefore, for the reasons addressed herein, we strongly encourage the Federal Reserve to adopt a phased-in approach for implementation of FR 2956 reporting, beginning with the reporting of transactions conducted by an institution under its government securities dealer (GSD) or government securities broker (GSB) authority, i.e., dealing activity, that are not otherwise currently reported to TRACE by a FINRA-registered broker-dealer as of September 1, 2022 and provide respondents with an additional nine months to comply with FR 2956 reporting for the remaining transactions outside of the dealer market (e.g., buy-side transactions).

To read the full comment letter, please click here.

1 Please refer to Annex 1 for descriptions of the Associations.

2 Federal Reserve, Press Release: Federal Reserve Board announces plans to enter negotiations with FINRA to potentially act as collection agent of U.S. Treasury securities secondary market transactions data (October 21, 2016), available at https://www.federalreserve.gov/newsevents/pressreleases/other20161021a.htm.

3  BPI and SIFMA Letter re: Proposal to implement the Treasury Securities and Agency Debt and Mortgage- Backed Securities Reporting Requirements (FR 2956; OMB No. 7100-NEW) (March 22, 2021).