Independent Dealer and Trader Association Publishes Its First SEC Comment Letter

The Independent Dealer and Trader Association (“IDTA” or “Association”) ¹ submits this letter in response to your request for comment on the Fixed Income Clearing Corporation’s (“FICC”) filing with the Securities and Exchange Commission (“SEC”) of the proposed rule change SR-FICC-2018-001 (the “Proposed Rule Change”) to amend the FICC Government Securities Division (“GSD”) Rulebook (the “GSD Rules”) to make changes to GSD’s method of calculating GSD members’ (“Members”) margin, referred to in the GSD Rules as the Required Fund Deposit (“RFD”) amount.²

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https://www.sec.gov/comments/sr-ficc-2018-001/ficc2018001-3361899-162097.pdf}