Policy Positions

Citadel believes that fair, open, competitive, and transparent markets best serve the needs of all participants.

OTC Derivatives – US

Citadel is a firm supporter of the G-20 reforms to the OTC derivatives markets, including the central clearing and trading requirements. These reforms have already begun and will continue to reduce interconnectedness and systemic risk, improve pre- and post-trade transparency, and foster an open, level, competitive playing field.

Oct 11 2022

Comment Letter to CFTC on Clearing Agency Governance

Oct 7 2022

Comment Letter to SEC on Clearing Agency Governance

Jun 30 2022

Comment Letter to CFTC on Amending the Swap Clearing Requirement To Account for the Transition From LIBOR to RFRs

Jun 10 2022

Comment Letter to SEC on Rules Relating to Security-Based Swap Execution and Registration and Regulation of SBSEFs

Jan 1 2022

Comment Letter to SEC on SBS Large Position Disclosure

Mar 15 2019

Citadel Response to the SEF Rule Proposal

Sep 7 2018

Response to Global Regulators’ Consultation on Incentives to Centrally Clear OTC Derivatives

Sep 5 2018

Letter to the SEC on Advancing the Implementation of Security-Based Swap Rules

Sep 30 2017

Comment Letter to the CFTC on Project KISS

Aug 21 2017

Comment Letter to the CFTC on Review of Swap Reporting Rules

Dec 19 2016

Comment Letter to the CFTC on the Cross-Border Proposal

Jul 25 2016

Comment Letter to the CFTC on Additional Clearing Submissions

Jul 18 2016

Comment Letter to the CFTC on the Expansion of the Clearing Mandate for IRS

Mar 7 2016

Comment Letter to the CFTC on Data Quality

Feb 2 2016

Comment Letter to the SEC on the Single-Name CDS Markets

Jul 13 2015

Comment Letter to the SEC on the Cross-Border Proposal

Dec 6 2013

Comment Letter to the CFTC on CME Rule 538 (Exchange for Related Positions)

Nov 29 2013

Comment Letter to the CFTC on SEF MAT Determinations

Aug 21 2013

Comment Letter to the SEC on the Cross-Border Proposal

Jul 22 2013

Comment Letter to the SEC on Clearing Implementation & Straight-Through-Processing

Feb 6 2013

Comment Letter to the CFTC on the Cross-Border Guidance

Sep 6 2012

Comment Letter to the CFTC on the Clearing Determination

Aug 13 2012

Comment Letter to the SEC on the Implementation Roadmap for Swaps Rules

Dec 22 2011

Comment Letter to the CFTC on the ICE Clear Credit Portfolio Margining Petition

Nov 4 2011

Comment Letter to the CFTC on the Implementation Schedule for Swaps Rules

Sep 30 2011

Comment Letter to the CFTC on the Timing of Acceptance for Clearing and Client Clearing Documentation

Jun 3 2011

Comment Letter to the CFTC on the Requirements for Processing, Clearing and Transfer of Customer Positions

Jun 3 2011

Comment Letter to the CFTC on Governance Requirements Regarding Conflicts of Interest

Jun 3 2011

Comment Letter to the CFTC on DCO Core Principles & Risk Management

Jun 3 2011

Comment Letter to the CFTC and SEC on Implementation Timelines for Swaps Rules

Comment Letter to CFTC on Clearing Agency Governance

Oct 11 2022

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Comment Letter to SEC on Clearing Agency Governance

Oct 7 2022

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Comment Letter to CFTC on Amending the Swap Clearing Requirement To Account for the Transition From LIBOR to RFRs

Jun 30 2022

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Comment Letter to SEC on Rules Relating to Security-Based Swap Execution and Registration and Regulation of SBSEFs

Jun 10 2022

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Comment Letter to SEC on SBS Large Position Disclosure

Jan 1 2022

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Citadel Response to the SEF Rule Proposal

Mar 15 2019

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OTC Derivatives – Europe

Citadel is a firm supporter of the G-20 reforms to the OTC derivatives markets, including the central clearing and trading requirements. These reforms have already begun and will continue to reduce interconnectedness and systemic risk, improve pre- and post-trade transparency, and foster an open, level, competitive playing field.

Sep 30 2022

Response to ESMA Consultation on Updating the Clearing Obligation & Trading Obligation to Reflect RFRs

Jul 21 2022

Response to BoE Consultation on Modifying the Clearing Obligation to Reflect RFRs

Nov 6 2018

Citadel Feedback on the ESMA EU Derivatives Market Report

Apr 23 2018

Citadel Letter to ESMA on TRV Report

Feb 7 2018

Citadel Letter to EC and ESMA on MiFID II Implementation

Aug 31 2017

Response to French AMF Public Consultation on Implementing MiFID 2 Pre- and Post-Trade Transparency Requirements

July 31, 2017

Response to ESMA Consultation Paper on the Trading Obligation

July 18, 2017

Response to the European Commission on the EMIR Refit Proposal

Nov 21 2016

Response to ESMA Discussion Paper on the Trading Obligation

Sep 2 2016

Response to ESMA Consultation Paper on the Clearing Obligation for Category 3 Entities

Mar 23 2016

Response to ESMA Consultation Paper on OTC Derivatives Transaction Reporting

Mar 8 2016

Response to FCA Consultation Paper on MiFID 2 Implementation

Jul 15 2015

Response to ESMA Consultation Paper on the Clearing Obligation Under EMIR (No. 4)

Jun 18 2015

Response to HMT Consultation Paper on MiFID II (Non-Discriminatory Access)

Mar 2 2015

Response to ESMA Consultation Paper on MiFID II (STP & Impartial Access)

Sep 12 2013

Response to ESMA Discussion Paper on the Clearing Obligation Under EMIR

Aug 5 2012

Response to ESMA Consultation Paper on EMIR Draft Regulatory Technical Standards (STP)

Response to ESMA Consultation on Updating the Clearing Obligation & Trading Obligation to Reflect RFRs

Sep 30 2022

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Response to BoE Consultation on Modifying the Clearing Obligation to Reflect RFRs

Jul 21 2022

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Citadel Feedback on the ESMA EU Derivatives Market Report

Nov 6 2018

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Citadel Letter to ESMA on TRV Report

Apr 23 2018

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Citadel Letter to EC and ESMA on MiFID II Implementation

Feb 7 2018

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Response to French AMF Public Consultation on Implementing MiFID 2 Pre- and Post-Trade Transparency Requirements

Aug 31 2017

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OTC Derivatives – APAC

Citadel is a firm supporter of the G-20 reforms to the OTC derivatives markets, including the central clearing and trading requirements. These reforms have already begun and will continue to reduce interconnectedness and systemic risk, improve pre- and post-trade transparency, and foster an open, level, competitive playing field.

Apr 27 2018

Comment Letter to the HKMA and HK SFC on the Clearing Obligation and Platform Trading Obligation

Mar 23 2018

Response to the Singapore MAS Consultation on Mandatory Trading of Derivatives Contracts

Mar 14 2018

Comment Letter to HK SFC on Client Clearing Services & Straight-Through-Processing

Comment Letter to the HKMA and HK SFC on the Clearing Obligation and Platform Trading Obligation

Apr 27 2018

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Response to the Singapore MAS Consultation on Mandatory Trading of Derivatives Contracts

Mar 23 2018

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Comment Letter to HK SFC on Client Clearing Services & Straight-Through-Processing

Mar 14 2018

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US Treasuries

Citadel supports efforts to modernize the regulatory framework for the US Treasury markets, including the introduction of real-time public reporting, the registration of multilateral trading venues, non-discriminatory access to trading venues, and the expansion of repo clearing. Consistent with our longstanding commitment to more fair and efficient markets, we believe these changes will enhance transparency and resiliency in the US Treasury market and provide Treasury market participants with greater choice among trading venues and counterparties.

Aug 8 2022

Response to the Treasury “Request for Information” on Additional Transparency for Secondary Market Transactions of Treasury Securities

Jul 21 2022

Comment Letter to SEC on FINRA’s Proposal to Publish Aggregated Transaction Information More Frequently

Mar 30 2019

Citadel Comment Letter on FICC Sponsoring Member Program

Sep 10 2018

Comment Letter to OFR on the Reporting of Repo Transactions

Jul 5 2018

Comment Letter to the SEC on the FINRA Proposal Relating to ATS Reporting of US Treasury Transactions to TRACE

Aug 15 2016

Comment Letter to the SEC on FINRA’s Treasury TRACE Reporting

Apr 22 2016

Response to the Treasury “Request for Information” on the Evolution of U.S. Treasury Market Structure

Nov 20 2015

Ken Griffin’s Keynote Address at the 2015 Roundtable on Treasury Markets and Debt Management

Response to the Treasury “Request for Information” on Additional Transparency for Secondary Market Transactions of Treasury Securities

Aug 8 2022

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Comment Letter to SEC on FINRA’s Proposal to Publish Aggregated Transaction Information More Frequently

Jul 21 2022

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Citadel Comment Letter on FICC Sponsoring Member Program

Mar 30 2019

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Comment Letter to OFR on the Reporting of Repo Transactions

Sep 10 2018

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Comment Letter to the SEC on the FINRA Proposal Relating to ATS Reporting of US Treasury Transactions to TRACE

Jul 5 2018

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Comment Letter to the SEC on FINRA’s Treasury TRACE Reporting

Aug 15 2016

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Other Financial Regulatory Policy Positions

Citadel believes that investors play an essential and beneficial role in financial markets, engaging in fundamental research and enhancing price discovery and market efficiency.

May 2 2022

Comment Letter to SEC on Private Fund Adviser Proposal

Apr 4 2022

Comment Letter to SEC on Reporting of Securities Loans

Sep 30 2017

Comment Letter to the CFTC on Project KISS

Mar 16 2016

Comment Letter to the CFTC on Regulation Automated Trading (Reg AT)

Aug 4 2014

Comment Letter to the CFTC on Position Limits (No. 2)

Jul 7 2014

Comment Letter to the EIA on the Monthly Natural Gas Production Report

Feb 10 2014

Comment Letter to the CFTC on Position Limits (No. 1)

Dec 13 2013

Comment Letter to the CFTC on the Concept Release on Automated Trading

Comment Letter to SEC on Private Fund Adviser Proposal

May 2 2022

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Comment Letter to SEC on Reporting of Securities Loans

Apr 4 2022

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Comment Letter to the CFTC on Project KISS

Sep 30 2017

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Comment Letter to the CFTC on Regulation Automated Trading (Reg AT)

Mar 16 2016

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Comment Letter to the CFTC on Position Limits (No. 2)

Aug 4 2014

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Comment Letter to the EIA on the Monthly Natural Gas Production Report

Jul 7 2014

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Foreign Exchange

Citadel supports the FX Global Code’s objectives of promoting a robust, fair, liquid, open, and appropriately transparent foreign exchange market, and believes that realizing these objectives requires a transition to fully firm pricing and the elimination of “last look” practices.