Confirmation Letter Related to the UST Clearing Working Group’s Accounting Treatment for UST Repo Transactions Cleared Through FICC White Paper

SIFMA provided comments to the U.S Securities and Exchange Commission (SEC) to confirm their discussion on July 29, 2025 with the Staff of the Office of the Chief Accountant of the Securities and Exchange Commission that the Staff would not object to the conclusion reached by the Working Group that the Fixed Income Clearing Corporation ("FICC") is the principal counterparty to the Agent Clearing Member's ("ACM") customer's repurchase agreement transaction ("repo") upon novation to FICC, and that upon such novation, the ACM is not counterparty to the customer's repo, but rather has provided FICC with a financial guarantee of the ACM's customer's obligations to FICC.