SIFMA and EY Publish U.S. Treasury Clearing Compliance Considerations Report to Guide Industry Transition to Central Clearing

New York, NY, November 13, 2024 - SIFMA and Ernst & Young LLP (EY US) today published "U.S. Treasury Central Clearing - Industry Considerations Report," designed to capture and organize the various considerations and activities market participants should evaluate while assessing and completing preparations for the upcoming U.S. Securities and Exchange Commission (SEC) Treasury Clearing Rule compliance dates. It is intended to be utilized as a guide by sell-side and buy-side market participants alike as they implement changes in response to new U.S. Treasury clearing requirements.

"Treasury securities play a key role in the U.S. and world economies. SIFMA has long supported efforts to make the Treasury market more resilient. At the same time, we recognize the need to ensure liquidity is not negatively impacted," said Joe Seidel, SIFMA Chief Operating Officer. "As we transition to central clearing in compliance with the new SEC rules, it is important that the industry focuses on preparedness efforts to ensure as little market disruption as possible. The report is designed to offer a roadmap of considerations and actions firms need to take now to be ready for the coming deadlines. This is also part of SIFMA's broader efforts, including the development of standard clearing documentation, to coordinate a smooth transition with the industry."

Clearing transactions involves a clearing agency stepping in between a buyer and seller to handle certain elements of transaction processing, manage risk and pay down obligations. In December 2023, the SEC approved a final rule which mandates the clearing of certain eligible secondary market transactions in U.S. Treasury securities. It triggered a significant structural change to the U.S. Treasury market and will have significant impacts on broker-dealers, institutional investors, asset managers, hedge funds, interdealer brokers, principal trading firms, banks, and covered clearing agencies (CCAs). The first compliance date is March 31, 2025, by which time CCAs must implement enhanced practices as outlined in the respective rulebook of each CCA, which include risk management, margin, customer asset protection, and access to clearance and settlement services. The second compliance date is December 31, 2025, by which time direct participants of CCAs must comply with the requirements to clear eligible cash secondary market transactions. The third compliance date is June 30, 2026, by which time direct participants of CCAs must be compliant with the requirements to clear eligible Treasury repo transactions.

"The SEC's new Treasury clearing requirements represent a pivotal shift for the U.S. Treasury market, and firms must act quickly to meet the upcoming compliance deadlines," said Brendan Maher, Managing Director, Financial Services Consulting, EY. "This report offers market participants a practical framework to navigate this complex transition, highlighting key considerations and actions. At EY, we are committed to helping our clients adapt to these new regulations by providing actionable insights and strategic guidance to ensure a seamless and efficient transition to central clearing."

The SEC Rule will drive a number of changes to the overall U.S. Treasury market structure and require the integration of market participants who will now be mandated to centrally clear transactions for the first time. New CCAs may also emerge, and market participants may decide to connect to one or more CCAs to support their trading and clearing strategies. Such changes to the market will require new operations and capabilities to accommodate increased clearing volumes and new relationships between firms.

The report details the critical activities that institutions should consider as they design and implement a process for Treasury clearing. The primary objectives of the report are to:

• Provide an implementation blueprint for industry participants on implementation priorities.
• Identify the key steps to operationalize change across different clearing access models.
• Surface key issues, open questions, and gaps in market structure and provide recommendations on the path to resolution.
• Provide views on the target state transaction lifecycle from execution through margin processing, including proposed high-level transaction flows.
• Provide insights on implementation dependencies across work efforts, where possible.
• Serve as an educational resource on the rule and its implications.

The report includes input and subject-matter analysis from market participants on both the buy-side and sell-side that was gathered 1) via a survey issued to SIFMA member firms by SIFMA and EY, 2) from information workshops hosted with SIFMA member firms, and 3) from bilateral conversations with market participants. It is available at the following link: https://www.sifma.org/resources/general/us-treasury-central-clearing-industry-considerations-report/

Media Alert:
There will be an industry briefing to discuss the report on November 19^th at 2:00 pm EST. The briefing is open to the media; interested reporters should RSVP to Katrina Cavalli.

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SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry's one million employees, we advocate on legislation, regulation and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA).