May 17, 2022

Comment Deadline Set for FINRA Proposal on TRACE Reporting of Foreign Sovereign Debt Securities Transactions

Comments on a FINRA proposal to require TRACE reporting of transactions in U.S. dollar-denominated foreign sovereign debt securities (see previous coverage) must be submitted by June 7, 2022. The proposal was published in the Federal Register with an effective date to be determined by the SEC within 45 to 90 days.

Under the proposal, these securities would be subject to same-day reporting requirements without public dissemination. FINRA proposed to expand the definition of "Foreign Sovereign Debt Security" as a debt security issued or guaranteed by (i) the government of a foreign country, (ii) any political subdivision of a foreign country (e.g., state, provincial or municipal government) or (iii) a supranational entity (e.g., the World Bank and European Investment Bank).

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