Policy Positions

Read the Citadel Securities White Paper on Enhancing Competition, Transparency and Resiliency in U.S. Financial Markets - Policy Recommendations for the U.S. Securities and Exchange Commission.

May 2021

Enhancing Competition, Transparency and Resiliency in U.S. Financial Markets
Enhancing Competition, Transparency and Resiliency in U.S. Financial Markets

May 2021

Equities & Options

The U.S. equity markets are the fairest, most transparent, resilient, and competitive markets in the world. Citadel Securities believes that competition and innovation have markedly improved conditions for all investors, who benefit from dramatically lower trading costs, improved market transparency and liquidity, and increased competition. We support regulatory efforts to ensure that U.S. equity markets continue to best serve the interests of all investors.

Feb 23 2021

CAT Limitation of Liability

Nov 30 2020

CAT Data Security

Aug 14 2020

IEX D-Limit

Aug 12 2020

AIM Auctions for SPX

July 9 2020

AIM Auctions for SPX

July 2 2020

IEX D-Limit

June 12 2020

NYSE Wireless Data Proposal

June 1 2020

CAT Data Security

May 26 2020

Market Data Infrastructure

April 23 2020

IEX D-Limit

Feb 18 2020

NYSE Direct Listings

Nov 17 2019

SIP Odd Lots Proposal

Oct 19 2019

EDGA Asymmetric Speedbump

Aug 1 2019

OTC Trading Volume Transparency

July 17, 2019

EDGA Asymmetric Speedbump

June 11 2019

TRACE Corporate Bond Pilot Proposal

April 26 2019

EDGX Retail Order Priority

Mar 1 2019

Citadel Securities Canada Comment Letter on the Proposed Fee Rebate Pilot

Nov 28 2018

Citadel Securities Comment Letter on NYSE Rule 104

Nov 12 2018

Citadel Securities Letter on the FINRA Proposal to Increase OTC Equity Transparency

Oct 23 2018

Citadel Securities Supplemental Comment Letter on Proposed Rule 606 Modifications

May 25 2018

Comment Letter to the SEC on the Proposed Transaction Fee Pilot for NMS Stocks

Dec 8 2017

Statement in Support of the SEC Review of the CHX Liquidity Enhancing Access Delay

Aug 30 2017

Comment Letter to the SEC on NASDAQ Midpoint Extended Life Order (MELO)

Jun 16 2017

Comment Letter to the SEC on CHX Liquidity Enhancing Access Delay (No. 2)

Apr 28 2017

Comment Letter to the SEC on NYSE MKT Delay Mechanism

Apr 7 2017

Comment Letter to the SEC on FINRA Tick Size Pilot Data Publication (No. 2)

Mar 30 2017

Comment Letter to the SEC on Nasdaq's Extended Life Order Attribute (No.2)

Mar 17 2017

Comment Letter to the SEC on CHX Liquidity Enhancing Access Delay

Mar 15 2017

Comment Letter to the SEC on NYSE DMM Prohibited Transactions

Dec 27 2016

Comment Letter to the SEC on NASDAQ Data Fees

Dec 27 2016

Comment Letter to the SEC on Nasdaq's Extended Life Order Attribute

Dec 21 2016

Comment Letter to the SEC on FINRA Tick Size Pilot Data Publication (No. 1)

Dec 12 2016

Comment Letter to the SEC on NYSE Data Fees

Oct 13 2016

Comment Letter to the SEC on CHX's Liquidity Taking Access Delay Filing

Oct 13 2016

Comment Letter to the SEC on Disclosure of Order Handling Information

Jul 6 2016

Comment Letter to the SEC on NYSE MKT’s CUBE Auction Fees

Apr 20 2016

Comment Letter to the SEC on NYSE Arca’s Discretionary Pegged Order

APR 14 2016

Comment Letter to the SEC on the IEX Exchange Application (No. 5)

Apr 14 2016

Interpretation Regarding Automated Quotations

Apr 14 2016

Comment Letter to the SEC on the Proposed Interpretation Regarding Automated Quotations

MAR 1 2016

Comment Letter to the SEC on Reg ATS

FEB 23 2016

Comment Letter to the SEC on the IEX Exchange Application (No. 4)

DEC 7 2015

Comment Letter to the SEC on the IEX Exchange Application (No. 3)

NOV 30 2015

Comment Letter to the SEC on the IEX Exchange Application (No. 2)

NOV 6 2015

Comment Letter to the SEC on the IEX Exchange Application (No. 1)

JAN 5 2015

Comment Letter to the SEC on the Tick Size Pilot

Jul 21 2014

Comment Letter to the SEC on Equity Market Structure Recommendations

Jul 8 2014

Ken Griffin's Testimony to the Senate Banking Committee on Equity Market Structure and Electronic Trading

APR 24 2014

Comment Letter to the SEC on OCC Clearing Fees (No. 2)

MAR 26 2014

Comment Letter to the SEC on OCC Clearing Fees (No. 1)

MAR 17 2014

Comment Letter to the SEC on NASDAQ’s Kill Switch

DEC 18 2013

Comment Letter to the SEC on PHLX Customer Rebates

OCT 15 2013

Comment Letter to the SEC on NYSE Arca Penny Quoting

SEP 5 2013

Comment Letter to the SEC on NSCC Supplemental Liquidity Deposits (No. 4)

AUG 5 2013

Comment Letter to the SEC on NSCC Supplemental Liquidity Deposits (No. 3)

JUN 13 2013

Comment Letter to the SEC on NSCC Supplemental Liquidity Deposits (No. 2)

APR 22 2013

SEC Petition for Rulemaking on Option Floor Crosses

APR 18 2013

Comment Letter to the SEC on NSCC Supplemental Liquidity Deposits (No. 1)

OCT 1 2012

Comment Letter to the SEC in advance of the Technology & Trading Roundtable

MAY 9 2012

Comment Letter to the SEC on BATS Fee Schedule

APR 23 2012

Comment Letter to the CFTC and SEC on NYPC and FICC’s Portfolio Margining Petition
CAT Limitation of Liability

Feb 23 2021

CAT Data Security

Nov 30 2020

IEX D-Limit

Aug 14 2020

AIM Auctions for SPX

Aug 12 2020

NYSE Wireless Data Proposal

June 12 2020

Market Data Infrastructure

May 26 2020

OTC Derivatives Reform – US

Citadel Securities 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

Dec 7 2020

Portfolio Margining of Uncleared Swaps and SBS

May 22 2020

Real-time Public Reporting of Blocks

May 22 2020

Codification of SEF No-Action Letters

April 21 2020

Post-trade Name Give-up

March 9, 2020

CFTC Cross-Border

March 3 2020

Swap Dealer Capital

March 2 2020

Post-trade Name Give-up

Dec 3 2019

Applying Certain ORC Derivative Market Reforms to SOFR Derivatives

Nov 22 2019

Exempt DCOs

Nov 18 2019

Alternative Compliance Framework for Non-US DCOs

July 23 2019

Cross-Border Amendments

Mar 15 2019

Citadel Response to the SEF Rule Proposal

Mar 15 2019

Citadel Securities Comment Letter on SEC Capital and Margin Rules

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

May 15 2017

Comment Letter to the SEC on Security-Based Swap Dealer Capital Rules

May 15 2017

Comment Letter to the CFTC on Swap Dealer Capital 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

Comment Letter to SEC on Clearing Agency Governance

Oct 7 2022

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

Jun 30 2022

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

Jun 10 2022

Portfolio Margining of Uncleared Swaps and SBS

Dec 7 2020

Real-time Public Reporting of Blocks

May 22 2020

OTC Derivatives Reform – Europe

Citadel Securities 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 are expected 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

Jan 11 2021

Feedback on ESMA Market Data Guidelines

Dec 7 2020

ESMA Transaction Reporting and Reference Data

June 15 2020

ESMA Post-trade Risk Reduction Services

June 14 2020

MiFID II Non-Equity Transparency

Nov 21 2019

EMIR FRANDT

Nov 20 2019

Alignment of the CO and DTO

Sept 6 2019

MiFID II Transparency and CTP

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

Comment Letter to the FCA - 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

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

Jul 21 2022

Feedback on ESMA Market Data Guidelines

Jan 11 2021

ESMA Transaction Reporting and Reference Data

Dec 7 2020

ESMA Post-trade Risk Reduction Services

June 15 2020

MiFID II Non-Equity Transparency

June 14 2020

OTC Derivatives – APAC

Citadel Securities 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

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

Mar 23 2018

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

Mar 14 2018

U.S. Treasuries

Citadel Securities supports efforts to modernize the regulatory framework for the U.S. 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 U.S. Treasury market and provide Treasury market participants with greater choice among trading venues and counterparties.

Aug 31 2022

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

Apr 18 2022

Comment Letter to SEC on Applying Regulation ATS & SCI for ATSs that Trade U.S. Government Securities

March 1 2021

SEC Reg ATS Proposal

Feb 22 2021

FINRA Regulatory Reporting Proposal

Jan 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
Request for Information on Additional Transparency for Secondary Market Transactions of Treasury Securities

Aug 31 2022

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

Jul 21 2022

Comment Letter to SEC on Applying Regulation ATS & SCI for ATSs that Trade U.S. Government Securities

Apr 18 2022

SEC Reg ATS Proposal

March 1 2021

FINRA Regulatory Reporting Proposal

Feb 22 2021

Citadel Comment Letter on FICC Sponsoring Member Program

Jan 30 2019

Commodity Futures

Citadel Securities believes that investors play an essential and beneficial role in the commodities markets. Investors’ research and analysis leads to greater transparency, facilitating more efficient economic decisions by commodity producers and consumers and optimizing resource allocation across the real economy. At the same time, investors’ market activity enhances liquidity and facilitates the price discovery process for all market participants.

March 15 2020

CFTC Position Limits

Mar 15 2019

Comment Letter on the ICE Asymmetric Speed Bump

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

Dec 13 2013

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

Feb 10 2013

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

March 15 2020

Comment Letter on the ICE Asymmetric Speed Bump

Mar 15 2019

Comment Letter to the CFTC on Project KISS

Sep 30 2017

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

Mar 16 2016

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

Aug 4 2014

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

Jul 7 2014

Other FICC Asset Classes

Jul 08 2022

Response to IOSCO Consultation Paper on Corporate Bond Liquidity During March 2020

Sept 6 2019

FINRA Proposal to Publish Bond ATS Data

June 11 2019

TRACE Corporate Bond Pilot Proposal

Sep 21 2017

Comment Letter to the Global Foreign Exchange Committee on Last Look
Response to IOSCO Consultation Paper on Corporate Bond Liquidity During March 2020

Jul 08 2022

FINRA Proposal to Publish Bond ATS Data

Sept 6 2019

TRACE Corporate Bond Pilot Proposal

June 11 2019

Comment Letter to the Global Foreign Exchange Committee on Last Look

Sep 21 2017