Treasury Clearing
The U.S. Securities and Exchange Commission (SEC) has adopted new rules requiring most market participants to centrally clear U.S. Treasury (UST) cash and repo transactions. This represents one of the most significant structural changes to the Treasury market in decades — with major implications for market participants, infrastructure providers, and regulators alike.
Key Rule Requirements
Under the SEC’s December 2023 rule, secondary trading in in-scope U.S. Treasury securities and repos must be cleared through a Covered Clearing Agency (CCA).
Today, these transactions are either settled bilaterally or centrally cleared through the Fixed Income Clearing Corporation (FICC), the sole CCA in the Treasury market.
This new mandate expands the range of transactions subject to clearing and establishes phased compliance dates:
- September 30, 2025: CCAs must implement enhanced risk management, margin, and customer protection practices.
- December 31, 2026: Clearing required for eligible Treasury cash transactions.
- June 30, 2027: Clearing required for eligible Treasury repo transactions.
The rule will significantly reshape U.S. Treasury market structure, impacting broker-dealers, institutional investors, interdealer brokers, principal trading firms, and clearing agencies.
Key Focus Areas
Supporting Implementation and Industry Readiness
On behalf of our members, SIFMA is leading coordinated workstreams to prepare the industry for implementation. These efforts include developing operational timelines, enhancing market structure, and ensuring readiness across both the buy- and sell-side.
SIFMA’s Industry Considerations Report, published in partnership with Ernst & Young LLP (EY US), provides a blueprint for firms to evaluate implementation priorities, access models, and operational dependencies ahead of compliance deadlines.
Developing Market Standard Documentation
To promote consistency and efficiency as new participants enter the clearing ecosystem, SIFMA has convened cross-industry working groups to establish market standard documentation for key access models:
- “Done-With” Model: Available here.
- “Done-Away” Model: In development, expected first half of 2025.
SIFMA has also partnered with Arteria AI to launch a data-driven documentation platform that streamlines onboarding, ensures compliance, and accelerates operational integration.
Evaluating Market Structure Evolution
SIFMA is leading industry discussions on supplementing the existing “sponsored” or “done-with” clearing approach with a “done-away” model — allowing participants to trade with third parties and submit trades to their clearing member.
An industry Roundtable has been convened to evaluate the operational, legal, and market impacts of this evolving structure.
Advancing Regulatory Reforms and Clarifications
This rulemaking is extraordinarily complex, and several open questions remain. SIFMA continues to engage with regulators to:
- Clarify inter-affiliate exemptions that are currently impractical to implement.
- Address implications for triparty repo, registered funds, and offshore UCITS.
- Ensure appropriate accounting treatment for agency and sponsored clearing models.
SIFMA has completed a review of FICC’s Agent Clearing Service and engaged with the SEC’s Office of the Chief Accountant to resolve accounting issues, with the working group’s conclusions and correspondence made publicly available.
Industry Considerations Report
Originally published in November 2024 and updated in November 2025, the outlines key activities market participants should prioritize in preparing for implementation. It provides:
- A roadmap for operational change across clearing models.
- Analysis of transaction lifecycle impacts, from execution to margining.
- Recommendations for addressing gaps and dependencies in market structure.
SIFMA has also published a document to accompany the report.
The Bottom Line
Central clearing of U.S. Treasuries represents a historic transformation in the world’s most important government securities market. SIFMA is committed to supporting a smooth, coordinated transition—one that enhances market resiliency, promotes efficiency, and preserves the liquidity and depth that define the U.S. Treasury market.
