April 6, 2015
Northern Trust is supportive of Bloomberg's request for exemption from registration as a clearing agency pursuant to Section 17A of the Exchange Act. We believe the introduction of additional vendors in the U.S. trade confirmation and matching space is of benefit to the industry and will promote innovation and process efficiency while enhancing investor protection and overall integrity of the securities markets. The addition of vendors will also reduce concentration risk, specifically the risk of failure of a single provider.
We believe the conditions of interoperability and oversight, as detailed in the request, are adequate and appropriate. We believe full interoperability across all aspects of the post trade confirmation and matching process is critical given the number of institutions active in this space and the use of competing products. We also believe interoperability must be a mandatory requirement, understanding this may result in increased implementation costs to current and future matching services.
Best regards,
Russell Stamey
Senior Vice President
The Northern Trust Co.