We are writing to comment and highlight the proposed 30/30/30 standard. As a board, we are heavily in favor of this standard. This will help reduce operational risk by ensuring trades clear in the proper account in a timely fashion. To be more specific, this will allow for a more real-time account valuation, position monitoring, margining, as well as decrease the risk related to unallocated expiring transactions. As an industry, all participants stand to benefit from this proposed standard. That being said, we would also like to highlight some of the challenges in meeting this goal. Read full comment letter
