March 9, 2023

Mr. Michael Passante
Chief Counsel
Office of Financial Research
717 14th Street NW
Washington, DC 20220

Re: SIFMA AMG Comment Letter on the OFR Proposed Rule Change Relating to Collection of Non-Centrally Cleared Bilateral Transactions in the U.S. Repurchase Agreement Market; Document 88 FR 1154

Dear Mr. Passante:

The Asset Management Group of the Securities Industry and Financial Markets Association (“SIFMA AMG”)1 appreciates the opportunity to comment on the Office of Financial Research’s (the “OFR”) proposed rule (the “Proposal”) establishing a data collection regime covering non-centrally cleared bilateral transactions in the U.S. repurchase agreement (“Repo”) market.2 SIFMA AMG supports the OFR’s goal of identifying and monitoring risks to financial stability arising in the market for U.S. Treasury securities through data collection and has long recognized the importance of regulators having the information necessary to carry out market supervision functions.

We agree with the general approach of one-sided reporting by sell-side entities with sizeable repo cash borrowings responsible for reporting, provided, however, that large buy-side entities with sizeable repo cash borrowings with entities other than the defined list of reporting sell-side counterparties are also required to report. Our key recommendations include: limit the reporting requirement to repos involving U.S. Treasury securities, expand the list of reporting sell-side entities to include U.S. banks and U.S. branches of foreign banks in addition to U.S. broker-dealers, do not calculate reporting thresholds by aggregating positions held by independent funds with a common investment advisor, and exempt U.S. money market and mutual funds from reporting as they both provide liquidity and rarely borrow cash through the repo markets.

 

1 SIFMA AMG brings the asset management community together to provide views on U.S. and global policy and to create industry best practices. SIFMA AMG’s members represent U.S. and global asset management firms whose combined assets under management exceed $45 trillion. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds.

2 See 88 FR 1154 (January 9, 2023).