ICMA submits response to SEC’s Notice of Request for Exemptive Relief
10 April 2026 ICMA has submitted its response to the SEC Notice of Request for Exemptive Relief concerning the extraterritorial scope of the U.S. Treasury clearing mandate. The Notice seeks feedback on whether certain offshore transactions in U.S. Treasury between non-U.S. counterparties should be exempt from the Trade Submission Requirement. In its response, ICMA supports the proposed relief in principle, noting that it would help address unintended extraterritorial effects and reduce legal uncertainty, operational complexity, and compliance burdens for international market participants. ICMA also acknowledges concerns raised by some market participants regarding potential level playing field implications, particularly in relation to the treatment of non-U.S. branches and subsidiaries of U.S. firms. The response notes that further consideration may be warranted in this area and suggests that the SEC may consider appropriate mitigants, alongside monitoring the use of the exemption.
