SECURITIES AND EXCHANGE COMMISSION

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SECURITIES AND EXCHANGE COMMISSION

[Release No. 34-106200; File No. 600-40]

LSEG Post Trade Services Limited; Notice of Filing of Application for Exemption from

Registration as a Clearing Agency Under Section 17A of the Securities Exchange Act of 1934

August 26, 2026.

I.

Introduction

On August 8, 2024, Schvey, Inc. (d/b/a Axoni, “Axoni”) filed with the Securities and

Exchange Commission (“Commission”) an application on Form CA-1 seeking an exemption from

registration as a clearing agency pursuant to Section 17A of the Securities Exchange Act of 1934

(“Exchange Act”) and Rule 17Ab2-1 thereunder. 1 On November 22, 2024, LSEG Post Trade

Services Limited (“LSEG”) amended the application to reflect its acquisition in October 2024 of

the Veris platform (“Application”). 2 This Application concerns the Veris platform, a post-trade

reconciliation and lifecycle management platform for transactions in equity security-based swaps

(“SBS”), that provides trade matching services by facilitating SBS contract management. 3

The Commission is publishing this notice to solicit comments from interested persons on

the Application. 4 The Commission will consider any comments it receives in making its

determination whether to grant LSEG’s request for an exemption from registration as a clearing

1

See 15 U.S.C. 78q-1; 17 CFR 240.17ab2-1 (“Rule 17Ab2-1”).

2

See Application, Exhibit J, at J-1. Prior to LSEG’s acquisition of the Veris platform, Axoni amended the

Application on August 12, September 19, October 3, and October 7. LSEG subsequently amended the

Application in 2024 on November 26 and December 4, in 2025 on February 20, and in 2026 on February 4

and February 11.

3

See Application, Exhibit J, at J-1 (“[t]he Veris platform reduces the effort needed to reconcile post trade data

and prevent cash flow breaks by enabling counterparties to share and compare data associated with equity

SBS deals, positions, trades, and related cash flows throughout the post-trade lifecycle”); see also Application,

Exhibit S, at S-2.

4

The non-confidential exhibits of the Application are available for viewing on the Commission’s website at

https://www.sec.gov/rules-regulations/commission-orders-notices/other-commission-orders-noticesinformation.

1

agency. 5

II.

Background

LSEG, through its predecessor Axoni, has been providing the services described in Part III of

this notice pursuant to a temporary, class-based exemption issued by the Commission in 2011 (“2011

Temporary Exemption”).6 Specifically, the 2011 Temporary Exemption provided exemptive relief to

entities performing (non-central counterparty) post-trade services for SBS that otherwise would have

to register as a clearing agency or obtain an exemption from registration.7 In adopting Regulation SE

in 2023, the Commission terminated the 2011 Temporary Exemption, while extending its exemptive

relief to entities that applied for registration or an exemption from registration as a clearing agency.8

Pursuant to the terms set forth in the Regulation SE adopting release, LSEG has continued to provide

the services described below.9

5

Because the Application seeks an exemption from registration, the timing requirements in Section 19(a) of the

Exchange Act do not apply. See 15 U.S.C. 78q-1(b)(2) (applying the provisions of Section 19(a) to

applications for registration but not applications for an exemption from registration).

6

See Order Pursuant to Section 36 of the Securities Exchange Act of 1934 Granting Temporary Exemptions

from Clearing Agency Registration Requirements under Section 17A(b) of the Exchange Act for Entities

Providing Certain Clearing Services for Security-Based Swaps, Release No. 34-64796 (July 1, 2011), 76 FR

39963 (July 7, 2011).

7

See 2011 Temporary Exemption, 76 FR at 39964; see also Confirmation and Affirmation of Securities Trades;

Matching, Release No.34-39829 (Apr. 6, 1998), 63 FR 17943, 17946 (Apr. 13, 1998) (the “Matching

Release”) (stating “an intermediary that captures trade information from a buyer and a seller of securities and

performs an independent reconciliation or matching of that information” must register as a clearing agency or

receive an exemption from such registration).

8

See Security-Based Swap Execution and Registration and Regulation of Security-Based Swap Execution

Facilities, Release No. 34-98845 (Nov. 2, 2023), 88 FR 87156, 87229 (Dec. 15, 2023) (“Regulation SE”)

(stating that “[f]or any entity currently relying on the 2011 Clearing Agency Exemption that becomes required

to register as a clearing agency, the exemptive relief will terminate 180 days after the Effective Date of

Regulation SE, which will be 60 days after the date of publication in the Federal Register, except that (1) with

respect to an entity that has filed an application to register as a clearing agency with the Commission on Form

CA-1 within 180 days of the Effective Date of Regulation SE, the relief will terminate 240 days after the

Effective Date of Regulation SE; and (2) with respect to an entity that has filed an application on Form CA-1

within 180 days after the Effective Date of Regulation SE and whose application on Form CA-1 is complete

(having responded to requests by the Commission’s staff for revisions or amendments) within 240 days after

the effective date, the exemptive relief will terminate 30 days after the Commission acts to approve or

disapprove the application on Form CA-1.”).

9

See Regulation SE, 88 FR at 87229; Exhibit J at J-1.

2

III.

Summary of the Applicant’s Organization and Services

A.

Organization

LSEG is organized under the laws of England and Wales and is incorporated as a private

limited company with the United Kingdom Companies House.10 LSEG is governed by a five-person

board of directors.11 LSEG’s ultimate parent is London Stock Exchange Group plc.12

B.

Description of Services in Application

The Application explains that, in 2020, Axoni began offering the Veris platform to a select

number of customers. 13 As explained above, in October 2024, LSEG purchased the Veris platform

from Axoni. 14 LSEG explains in its Application that the Veris platform, a post-trade pairing

reconciliation and lifecycle management platform for equity SBS, reduces the effort needed to

reconcile post-trade data and prevent cash flow breaks by enabling counterparties to share and

compare data associated with equity SBS deals, positions, trades, and related cash flows throughout

the post-trade lifecycle. 15 LSEG states that the Veris platform provides “real-time transparency” to

both counterparties on reconciliation exceptions and reduces operational risks including settlement

delays. 16 LSEG also states that all equity SBS transactions are executed and settled outside of the

Veris platform, and that post-execution, counterparties transmit to the Veris platform their postexecution swap data. 17

10

See Application, Exhibit C, at C-1.

11

LSEG describes three directors as a “Common Director.” See Application, Exhibit A, at A-1.

12

See Application, Exhibit D, at D-1.

13

See Application, Exhibit J, at J-1.

14

See id.

15

See id.

16

See id.

17

See id.

3

LSEG states that the Veris platform has onboarded “regulated financial institutions” such as

broker-dealers, banks, registered investment companies and private funds. 18 LSEG indicates that it

does not limit the types of persons that may use the Veris platform, provided: (i) the entity is

registered, and in good standing, with a regulatory authority; and (ii) the entity has the operational

and technological capacity to connect to the Veris platform. 19 LSEG states that each Veris platform

customer entered into a software agreement with Axoni (now assigned to LSEG). 20 LSEG also

states that this software agreement governs each customer’s access and use of the Veris platform. 21

The Application further explains that, in 2026, the contract terms that govern each customer’s use

of the Veris platform will migrate to a standard uniform rulebook. 22

In the Application, LSEG describes the Veris platform’s functionality and workflow, as well

as three features planned for release in 2026. 23 As more fully described below, LSEG identifies 15

specific elements of the Veris platform’s functionality in the Application. 24

1.

Data Capture. The Veris platform ingests data through an Application Programming

Interface (“API”) or Financial Information Exchange (“FIX”) engine from

customers. The software subsequently creates, updates, or cancels the actioning

customer’s data records representing the equity SBS transactions. 25

2.

Post-Trade Data Pairing. Using the key terms entered into by both counterparties

18

See Application, Exhibit O, at O-1.

19

See id.

20

See Application, Exhibit P, at P-1.

21

See id.

22

See id.

23

See Application, Exhibit J, at J-1–J-4.

24

See id. at J-1–J-2.

25

See id. at J-1.

4

(party A and party B) comprising a data record (equity SBS), the Veris platform

compares to identify which records from party A correspond to party B’s version of

those records. Once a pair is identified, the Veris platform creates a paired record. 26

3.

Data Reconciliation. The Veris platform compares pairs records on specific

fields/terms relevant to the equity SBS. The platform marks as exceptions

counterparty data differences outside any thresholds. 27

4.

Data Enrichment. The Veris platform defaults/enriches certain data fields from

higher hierarchical levels to lower data levels. For example, it will automatically

enrich transactional data with higher level data to streamline the user experience

(e.g., “unwind methodology” can be provided at the deal level). 28

5.

Amendments. The Veris platform enables a party to update or amend its data. 29

6.

Cancellation. The Veris platform enables customers to cancel data records.

Cancelled data may be replaced with a newer version of the record. 30

7.

User Interface (“UI”). LSEG explains that the Veris platform is connected to a UI to

facilitate customer access to their data and provides exporting, audit history,

affirmation, and search functions. 31

8.

Affirmation. The Veris platform allows parties to affirm update/create their side of a

paired record with the values of their counterparty. 32

26

See id.

27

See id. at J-2.

28

See id.

29

See id.

30

See id.

31

See id.

32

See id.

5

9.

Account Mapping. The Veris platform allows customers to provide linkage between

their transactional data and deal-level data based on account and market

preferences. 33

10.

Trade Ordering. The Veris platform orders trades based on execution date and time,

and subsequently, determines the type of trade activity (e.g., determining if a trade

type is a buildup, unwind, or full unwind). 34

11.

Position Calculation. The Veris platform independently calculates the quantity and

number of securities on the position level based on the transactional records

received for a given position. 35

12.

Corporate Action Outturn Position Updates. The Veris platform determines the net

effect on a position (e.g., number of securities on a stock split) from corporate action

transactions received from customers. 36

13.

Single-Sided Flow. The Veris platform reconciles allocation instructions against risk

bookings for a single party. 37

14.

Electronic Master Confirm Agreement. The Veris platform allows creation and

storage of an electronic representation of a “Master Confirmation Agreement”

(“MCA”). 38

15.

33

See id.

34

See id.

35

See id.

36

See id.

37

See id.

38

See id.

Authentication and Permissions. The Veris platform manages permissions by

6

allowing customers to authenticate themselves. Upon authentication, the platform

grants customers the ability to access, create, and update their data for transactions

to which they are a party. 39

In its Application, LSEG also described three features to be released during 2026, as follows:

1.

Data normalization, which will allow clients to deliver data to the platform in the

client’s proprietary formats. Veris will then “transform” the data into the data

models required by the platform. 40

2.

Asset cross-referencing, which will allow clients to submit different identifier types

on their trade information. To link trades submitted by counterparties with different

identifier types, Veris will introduce the capability to cross-reference between

identifiers such as RIC, SEDOL, CUSIP, and ISIN. 41

3.

Cashflow matching, which will offer the capability to match cashflows resulting

from SBS transactions. Cashflow matching would be delivered in a phased approach

with “increasing granularity,” offering clients the ability to match or affirm

cashflows at a net level or per transaction. The Application explains that settlements

will continue to occur on a bilateral basis outside of the Veris platform. 42

As described further below, LSEG states that the Veris platform does not provide the

following functionality: (i) execution; (ii) settlement; or (iii) clearing. 43

1.

Execution. LSEG states that the Veris platform does not allow customers to execute

39

See id.

40

See id. at J-2–J-3.

41

See id. at J-3.

42

See id.

43

See id. at J-2.

7

equity SBS transactions or transactions in the securities underlying the equity

SBS. 44

2.

Settlement. LSEG states that the Veris platform does not settle equity SBS

transactions or transactions in the securities underlying the equity SBS. 45

3.

Clearing. LSEG states that the Veris platform does not clear equity SBS transactions

or transactions in the securities underlying the equity SBS.46

Additionally, LSEG explains the Veris platform’s workflow in ten steps:

1.

As part of the client onboarding process, any customer permissions, reference data,

and documentation (e.g., MCA) are established in the system. 47

2.

The equity SBS execution occurs outside of the Veris platform. 48

3.

Workflows managing the processing of the underlying equity asset (execution,

clearance, and settlement) occur outside of the Veris platform through normal

business channels. 49

4.

Parties transmit their post allocation swap data records to the Veris platform for

Data Capture via API, FIX, or UI Affirmation. 50

5.

The Veris platform processes the data to pair and reconcile any differences relative

to counterparty submissions of their records. 51

44

See id. at J-3.

45

See id.

46

See id.

47

See id.

48

See id.

49

See id.

50

See id.

51

See id.

8

6.

The Veris platform communicates the results of the reconciliation to parties via API

and/or UI. 52

7.

Each customer sends its version of all lifecycle data, including the following: (i)

amendments (e.g., financing re-rates); (ii) position accruals; (iii) cash flows; and (iv)

corporate action outturns. 53

8.

The Veris platform continuously reconciles all lifecycle data throughout the life of

the swap, highlighting exceptions to customers, while storing a unified record of

paired data. 54

9.

Customers investigate and remediate exceptions identified by the Veris platform by

updating their submissions upstream from the Veris platform to ensure swap data is

in alignment with their counterparty’s systems. 55

10.

IV.

Parties settle cash flows outside of the Veris platform. 56

Statutory Standard

Section 17A(b)(1) of the Exchange Act requires any clearing agency to register with the

Commission before performing the functions of a clearing agency with respect to any security

(other than an exempted security). 57 Section 17A(b)(1) of the Exchange Act also provides that, by

rule or order, upon its own motion or upon application, the Commission may conditionally or

unconditionally exempt a clearing agency from any provisions of Section 17A or the rules or

52

See id.

53

See id. at J-3–J-4.

54

See id. at J-4.

55

See id.

56

See id.

57

See 15 U.S.C. 78q-1(b)(1); 17 CFR 240.17ab2-1.

9

regulations thereunder if the Commission finds that such exemption is consistent with the public

interest, the protection of investors, and the purposes of Section 17A, including the prompt and

accurate clearance and settlement of securities transactions and the safeguarding of securities and

funds. 58

In the Matching Release, the Commission stated that an entity that limited its clearing

agency functions to providing matching services might not have to be subject to the full range of

clearing agency regulation, consistent with the exemptive authority provided in Section

17A(b)(1). 59 The Commission stated that a conditional exemption would exempt an entity from

clearing agency registration under “appropriate conditions.” 60 The Commission anticipated that an

entity seeking an exemption from clearing agency registration for matching would be required to:

(1) provide the Commission with information on its matching services and notice of material

changes to its matching services; (2) establish an electronic link to a registered clearing agency that

provides for the settlement of its matched trades; (3) allow the Commission to inspect its facilities

and records; and (4) make periodic disclosures to the Commission regarding its operations. 61

V.

Request for Exemption

In its Application, LSEG requests that the Commission grant a conditional exemption to

permit it to operate the services described in Part III above without registering as a clearing agency,

as explained further below.

A.

Application of Statutory Standard

LSEG requests an exemption from clearing agency registration in connection with its Veris

58

See 15 U.S.C. 78q-1(b)(1).

59

See Matching Release, supra note 7, 63 FR at 17947.

60

See id.

61

See id., n.28.

10

post-trade pairing, reconciliation, and lifecycle management service for equity SBS, which it

describes as the “Equity SBS Post-Trade Services.” LSEG explains that the Veris platform includes

a limited set of services that fall within the Commission’s definition of “trade matching,” such as

capturing an equity SBS transaction’s trade information to perform an independent comparison of

such information. 62 LSEG states that it does not perform comparison of trade data to reduce the

number of settlements or to allocate settlement responsibilities, or provide any other execution or

settlement services. 63 Citing its belief that Veris performs only a limited number of services that

would require registration as a clearing agency, LSEG states the conditions proposed in its

Application, and reproduced in Part V.B below, will provide the appropriate level of protection

against risk related to custody, clearance, and settlement. 64

In the Application, LSEG also states that exempting the Veris platform from registration,

subject to the specified conditions set forth below, will: (i) produce substantial U.S. public benefit;

(ii) provide U.S. investors and the U.S. national clearance and settlement system with substantially

the same level of protection against risk related to custody, clearance, and settlement that full

registration would provide; and (iii) advance the purposes of Section 17A of the Exchange Act. 65

In identifying a “substantial U.S. public benefit,” LSEG states that the Veris platform will improve

the speed, accuracy, and reliability of post-trade equity SBS pairing and reconciliation, including

reconciliation of cash flow amounts. 66 LSEG also states that these improvements should: (i) reduce

operational and settlement risk for equity SBS transactions; (ii) decrease overall costs to equity

62

See Application, Exhibit S at S-3.

63

See id. at S-3–S-4.

64

See id. at S-4.

65

See id. at S-2.

66

See id. at S-3.

11

SBS market participants; and (iii) increase the potential for developments of new and enhanced

functionality related to equity SBS transactions. 67

In addition, LSEG represents that it will not engage in any activity inconsistent with the

purposes of Section 17A(a)(2) of the Exchange Act, which directs the Commission to facilitate the

establishment of linked or coordinated facilities for clearance and settlement of transactions in

securities. 68 Because equity SBS transactions are not centrally cleared in the U.S., LSEG states that

interoperability requirements would be inappropriate at this time. 69 LSEG represents that, in any

event, it will not engage in activities that would prevent other services from operating a matching

service independent of LSEG’s services. 70

B.

Conditions to Exemption

In its Application, LSEG states that Regulation Systems Compliance and Integrity

(“Regulation SCI”), adopted in 2014, would not apply to the Equity SBS Post-Trade Services and

also believes it is not necessary for the Commission to impose compliance with Regulation SCI to

fulfill the purposes of the Exchange Act because (i) the Equity SBS Post-Trade Services are limited

in nature, and (ii) LSEG agrees to comply with operational risk conditions relating to systems

compliance and integrity. The conditions, described in its Application, 71 are reproduced and

renumbered as Parts B.1 and B.2 of this notice. References to the “Applicant” have been replaced

with “LSEG.”

67

See id.

68

See id. at S-5; see also 15 U.S.C. 78q-1(a)(2).

69

See Application, Exhibit S, at S-5. Cf. Release Nos. 34-44188 (Apr. 17, 2001), 66 FR 20494 (Apr. 23, 2001);

34-76514 (Nov. 25, 2015), 80 FR 75387 (Dec. 1, 2015) (setting forth conditions related to interoperability for

central matching service providers in the U.S. equity and fixed income markets).

70

See Application, Exhibit S, at S-5.

71

See id. at S-5–S-8.

12

B.1.

Operational Risk Conditions

LSEG proposes the following operational risk conditions as part of its request for an

exemption from registration as a clearing agency:

(1) LSEG shall demonstrate to the Commission or its designee no later than 120 days after

the Commission grants an order 72 exempting LSEG from registration as a clearing agency (the

“Exemption Order”), that LSEG maintains written policies and procedures applicable to those

systems that support or are integrally related to the Equity SBS Post-Trade Services (the

“Systems”) that, on an ongoing basis, are reasonably designed to:

a.

establish a robust operational risk-management framework applicable to the

Systems with appropriate systems, policies, procedures, and controls to identify,

monitor, and manage operational risks; 73

b.

clearly define the roles and responsibilities of LSEG personnel for addressing

operational risk; 74

c.

review, in accordance with the LSEG Policy Governance Framework, operational

policies, procedures, and controls applicable to the Systems;

d.

audit the Systems, and test the Systems periodically and at implementation of

significant changes; 75

e.

clearly define operational reliability objectives for the Systems;

f.

ensure that the Systems have scalable capacity adequate to handle increasing stress

72

The Application states “this order” rather than “an order.” Id. at S-5.

73

Id. at S-5–S-6.

74

Id. at S-6.

75

Id.

13

volumes and achieve the Systems service-level objectives; 76

g.

establish comprehensive physical and information security policies that address all

known potential vulnerabilities and threats to the Systems; 77

h.

establish a business continuity plan for the Systems that addresses events posing a

significant risk of disrupting the Systems’ operations, including events that could

cause a wide-scale or major disruption in the provision of the Equity SBS PostTrade Services; 78

i.

incorporate the use of a secondary site in LSEG’s business continuity plan that is

designed to ensure that all critical Systems can resume operations within two hours

following disruptive events; 79

j.

regularly test or otherwise validate LSEG’s business continuity plans; 80 and

k.

identify, monitor, and manage the risks that key participants, other financial market

infrastructures and service and utility providers might pose to the Systems’

operations in relation to the Equity SBS Post-Trade Services. 81

(2) For purposes of condition V.B.1(1), such policies and procedures shall be consistent

with current information technology industry standards, which shall be comprised of information

technology practices that are widely available to information technology professionals in the

financial sector and issued by a widely recognized organization. LSEG shall inform the

76

Id.

77

Id.

78

Id.

79

Id.

80

Id.

81

Id.

14

Commission or its designee of the information technology industry standards that LSEG has

chosen to use, affirm that choice on an annual basis, and provide advance notice of the use of

different standards as soon as practicable. 82

(3) LSEG shall provide the Commission or its designee with an annual update on the

status of the items set forth in condition V.B.1(1). 83

(4) LSEG shall establish, implement, maintain, and enforce written policies and

procedures reasonably designed to ensure that the Systems operate on an ongoing basis in a manner

that complies with the conditions applicable to the Systems and with LSEG’s rules and governing

documents applicable to the Equity SBS Post Trade Services. 84

(5) LSEG shall report all material critical systems’ outages to the Commission within 24

hours following confirmation of the incident. 85

(6) LSEG shall, within 30 calendar days after the end of each quarter, submit to the

Commission or its designee a report describing completed, ongoing and planned material changes

to the Systems that support or are related to the Equity SBS Post-Trade Services during the prior,

current, and subsequent calendar quarters, including the dates or expected dates of commencement

and completion. (LSEG shall establish reasonable written criteria for identifying a change to the

Systems as material and report such changes in accordance with such criteria.) 86

(7) LSEG shall, on an annual basis, provide the Commission or its designee with the

82

Id.

83

Exhibit S at S-7.

84

Id.

85

Id. With respect to “material critical systems,” the Application explains the term “critical system” refers to a

system for which the availability of an alternative is significantly limited or non-existent and without which

there would be a material impact on fair and orderly markets.

86

Id.

15

audited control report including internationally recognized certifications, as appropriate. 87

(8) LSEG shall make, keep, and preserve at least one copy of all documents relating to its

compliance with the operational risk conditions; keep all such documents for a period of not less

than five years, the first two years in an easily accessible place; and upon request of the

Commission, promptly furnish to the possession of the Commission or its designee copies of any

such documents. 88

B.2.

Additional Conditions

LSEG proposes the following additional conditions as part of its request for an exemption

from registration as a clearing agency:

(1) LSEG shall provide to the Commission or its designee its annual audited financial

statements prepared by competent independent audit personnel. 89

(2) LSEG shall notify the Commission or its designee of any material changes to any

service agreement between LSEG and any other entity that is performing any portion of the Equity

SBS Post-Trade Services on behalf of LSEG if such changes are reasonably expected to materially

affect the Equity SBS Post-Trade Services. 90

(3) LSEG shall preserve a copy or record of post-execution pairing and reconciliation data

pertaining to the operation of the Equity SBS Post-Trade Services. LSEG shall retain these records

for a period of not less than five years, the first two years in an easily accessible place. 91

(4) LSEG shall respond to a request from the Commission for additional information

87

Id.

88

Id.

89

Id.

90

Id.

91

Exhibit S at S-7–S-8.

16

relating to the Equity SBS Post-Trade Services and provide the Commission or its designee with

access to LSEG’s facilities (including automated systems and systems environment), records, and

personnel related to the Equity SBS Post-Trade Services. The request for information shall be

made and the inspections shall be conducted solely for the purpose of reviewing the Equity SBS

Post-Trade Services’ operations and compliance with the federal securities laws and the terms and

conditions in any Exemption Order. 92

(5) LSEG shall file with the Commission amendments to its application for exemption on

Form CA-1 if it makes any material change to the Equity SBS Post-Trade Services or any change

materially affecting the Equity SBS Post-Trade Services as summarized in any Exemption Order or

LSEG’s Form CA-1 that would make such previously provided information incomplete or

inaccurate. 93

(6) The Commission may modify by order the terms, scope or conditions of any

Exemption Order if it determines that such modification is necessary or appropriate in the public

interest, the protection of investors, or otherwise in furtherance of the purposes of the Exchange Act.

Furthermore, the Commission may limit, suspend, or revoke the exemption if it finds that LSEG

has violated or is unable to comply with any of the provisions set forth in any Exemption Order if

such action is necessary or appropriate in the public interest, for the protection of investors or

otherwise in furtherance of the purposes of the Exchange Act. 94

VI.

Request for Written Comments

Interested persons are invited to provide written data, views, and arguments concerning the

Application, including whether the proposed exemption is consistent with the public interest, the

92

Exhibit S at S-8. The Application states “the Exemption Order” rather than “any Exemption Order.” Id.

93

Id. The Application states “the Exemption Order” rather than “any Exemption Order.” Id.

94

Id. In each instance, the Application states “the Exemption Order” rather than “any Exemption Order.” Id.

17

protection of investors, and the purposes of Section 17A of the Exchange Act. To the extent

possible, commenters are requested to provide empirical data and other factual support for their

views. In addition, the Commission seeks comment generally on the following questions relevant

to the consideration of the Application:

1.

Since the Commission issued the 2011 Temporary Exemption, has LSEG provided

matching services and operated consistent with the public interest, the protection of investors, and

the purposes of the Exchange Act? Why or why not? To what extent has LSEG’s provision of

matching services affected the ongoing development of the national system for clearance and

settlement?

2.

What operational or other risks, if any, do the services described in the Application

pose to LSEG’s customers or to clearing agencies with which they interact? Do LSEG’s proposed

conditions sufficiently address any such risks? Please explain.

3.

Are LSEG’s proposed conditions consistent with the public interest, the protection

of investors, and the purposes of Section 17A of the Exchange Act, including the prompt and

accurate clearance and settlement of securities transactions and the safeguarding of securities and

funds? Would any revisions to the proposed conditions better promote the purposes of Section 17A

of the Exchange Act? Why or why not? If so, which conditions should be modified? Should any

conditions be added? Why or why not?

4.

Are LSEG’s proposed conditions designed to promote innovation and to facilitate

competition among matching services?

5.

Are there any aspects of the services provided by LSEG, or other aspects of its

Application, that support modifying or revising the interpretations provided by the Commission in

the Matching Release? If so, in what ways or how?

6.

Are there any aspects of the services provided by LSEG, or other aspects of its

18

Application, that support applying Commission rules such as Regulation SCI, the rules for central

matching service providers under 17 CFR 240.17ad-27, or the recordkeeping requirements for

registered clearing agencies under 17 CFR 240.17a-1? If so, which rules and why?

Comments may be submitted by any of the following methods:

Electronic comments:

•

Use the Commission’s Internet comment form (https://www.sec.gov/rules-

regulations/how-submit-comment); or

•

Send an e-mail to rule-comments@sec.gov. Please include File Number 600-40 on

the subject line.

Paper comments:

•

Send paper comments to Secretary, Securities and Exchange Commission, 100 F

Street, N.E., Washington, DC 20549-1090. All submissions should refer to File Number 600-40.

To help the Commission process and review your comments more efficiently, please use

only one method of submission. The Commission will post all comments on the Commission’s

Internet website (https://www.sec.gov/rules-regulations/commission-orders-notices/othercommission-orders-notices-information). Do not include personal identifiable information in

submissions; you should submit only information that you wish to make available publicly. We

may redact in part or withhold entirely from publication submitted material that is obscene or

19

subject to copyright protection. All submissions should refer to File Number 600-40 and should be

submitted on or before [INSERT DATE 45 DAYS FROM THE DATE OF PUBLICATION IN

THE FEDERAL REGISTER].

For the Commission, by the Division of Trading and Markets, pursuant to delegated

authority. 95

Sherry R. Haywood,

Assistant Secretary.

95

17 CFR 200.30-3(a)(16).

20

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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