Regulatory Timeline
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27'
The U.S. Treasury market is moving to mandatory central clearing to strengthen market resilience, transparency, and risk management. Banks, broker-dealers, and institutional participants must adapt their trading models, operating structures, and technology to remain compliant and competitive.
U.S. Treasury Clearing requires eligible cash and repo transactions to be centrally cleared through a CCP, primarily the Fixed Income Clearing Corporation (FICC). Once cleared, the CCP becomes the legal counterparty, introducing margining, netting, and default management mechanisms. The SEC set the compliance dates in its extension order of 4 March 2025: 31 December 2026 for eligible cash transactions and 30 June 2027 for eligible repo transactions.
U.S. Treasury Clearing requires eligible cash and repo transactions to be centrally cleared through a CCP, primarily the Fixed Income Clearing Corporation (FICC). Once cleared, the CCP becomes the legal counterparty, introducing margining, netting, and default management mechanisms. The SEC set the compliance dates in its extension order of 4 March 2025: 31 December 2026 for eligible cash transactions and 30 June 2027 for eligible repo transactions.
Clearing Models
Netting Member: Direct FICC membership with full clearing responsibilities
Sponsored Member: Indirect access via a sponsoring clearing member
Agent / Agency Client: Clearing through a member on an agency basis
Tri-Party / CCIT Models: Focused on tri-party and GCF-style repo activity
Trading Models
Done-With: Execution directly with the clearing sponsor
Done-Away: Execution with third parties and subsequent clearing via a sponsor
How Comyno Supports
Comyno supports clients across the full U.S. Treasury clearing journey:
Regulatory impact and readiness assessments
Clearing model selection and target operating model design
Collateral, margin, and liquidity framework optimisation
Technology, custody, and clearing connectivity integration
