On April 17, ISDA submitted a comment letter in response to the Fixed Income Clearing Corporation’s (FICC) proposed rule changes published by the Securities and Exchange Commission (SEC) on March 27, 2024. The changes would modify FICC’s government securities division (GSD) rule book so that FICC can facilitate access to clearing and settlement services of all eligible secondary market trades in US Treasury securities, in accordance with the Securities Exchange Act of 1934. The letter also addresses FICC’s advance notice to amend the GSD rules and proposed rule changes on separate and independent calculation, collection and holding of margin, published by the SEC on March 28, 2024.