Portfolio Security Operations

This page includes ICI memos, comment letters, white papers, and other resources related to regulatory and industry initiatives affecting portfolio securities operations, derivatives, and trading and markets.

Derivatives

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ICI Comment Letter to SEC on Re-Proposal Regarding ABS Conflicts of Interest (pdf)

Board Oversight of Derivatives (pdf)

Joint Comment Letter Responding to PRA/FCA Consultation (pdf)

Portfolio Securities Clearance and Settlement

ICI Comment Letter to CFTC and SEC on Portfolio Margining (pdf)

ICI Comment Letter on SEC Proposed Exemptive Order on Portfolio Margining (pdf)

ICI Comment Letter in Response to Swap Data Repository Rulebook (pdf)

Trading and Markets (Domestic)

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ICI: SEC’s Safeguarding Proposal Would Upend Decades of Established Practice

ICI President and CEO Eric Pan released the following statement regarding the Securities and...

ICI Comment Letter to SEC on Re-Proposal Regarding ABS Conflicts of Interest (pdf)

December 28, 2022

Memo #34737

FINRA Adopts and Proposes Amendments to TRACE Reporting

Over the last month, FINRA has proposed or adopted three separate reporting requirement changes to the Trade Reporting and Compliance Engine (TRACE). On December 13, 2022, FINRA adopted amendments to require the reporting of transactions in US dollar...