July 5, 2018
Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549–1090
Re:

Proposed Rule Change to Amend FINRA Rule 6730 Relating to ATS Reporting ofTransactions to TRACE in U.S. Treasury Securities (SR-FINRA-2018-023)

Citadel 1 appreciates the opportunity to provide comments to the Securities and Exchange
Commission (the “Commission”) on Financial Industry Regulatory Authority (“FINRA”) Rule
Filing SR-FINRA-2018-023 (the “Rule Proposal”). We support the proposed rule change torequire alternative trading systems (“ATSs”) that report transactions in U.S. Treasury Securities
to the Transaction Reporting and Compliance Engine (“TRACE”) to identify non-FINRA member
subscribers on those transaction reports.
Citadel has consistently supported efforts to modernize the regulatory framework for the US
Treasury markets, including the introduction of real-time public reporting, the registration ofmultilateral trading venues, non-discriminatory access to trading venues, and the expansion ofcentral clearing for both the cash and repo markets. 2 Consistent with our longstanding
commitment to more fair and efficient markets, we believe these changes will enhancetransparency and resiliency in the US Treasury market and provide Treasury market participants
with greater choice among trading venues and counterparties.
We strongly support increasing the amount of U.S. Treasury market data that is readily
available to the official sector. We believe enhanced reporting to the official sector, and the robust
audit trail that is created, will improve general monitoring and surveillance capabilities, including
those designed to detect prohibited trading practices and potential risks to market stability. In
addition, with comprehensive data, regulators and policymakers will be better equipped to identify
specific market trends and to evaluate the expected impact of subsequent policy decisions.
We note that the U.S. Department of Treasury in its October 2017 Capital Market Report3
1Citadel is a global financial firm built around world-class talent, sound risk management, and innovative marketleading technology. For more than a quarter of a century, Citadel’s hedge funds and capital markets platforms havedelivered meaningful and measurable results to top-tier investors and clients around the world. Citadel operates inall major asset classes and financial markets, with offices in the world’s leading financial centers, including
Chicago, New York, San Francisco, Boston, London, Hong Kong, and Shanghai.
2See Citadel’s response to the U.S. Department of Treasury’s Request for Information on the Evolution of U.S.
Treasury Market Structure, available at: https://www.regulations.gov/document?D=TREAS-DO-2015-0013-0045
and Citadel’s response to FINRA’s Proposed Rule Change Relating to the Reporting of U.S. Treasury Securities tothe Trade Reporting and Compliance Engine, available at: https://www.sec.gov/comments/sr-finra-2016027/finra2016027-5.pdf.

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Available at: https://www.treasury.gov/press-center/press-releases/Documents/A-Financial-System-CapitalMarkets-FINAL-FINAL.pdf.

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found that “significant gaps in the data available to regulators and Treasury still exist” andrecommended that “trading platforms operated by FINRA member broker-dealers that facilitatetransactions in Treasury securities … be required to identify customers in their reports of Treasury
security transactions.” The Rule Proposal would effectively implement this well-reasoned
recommendation.
**********

We appreciate the opportunity to provide comments to the Commission on further enhancing
the reporting regime for U.S. Treasuries.
Respectfully,/s/ Stephen John Berger
Managing Director, Government & Regulatory Policy

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