Preparing for US Treasury Clearing: Industry Readiness and the Done-Away Framework

Rob, let’s start with the big picture. The SEC’s clearing rule has been described as one of the most significant structural changes to the U.S. Treasury market in decades. For listeners who may not be steeped in this, can you briefly explain what the rule requires and why it matters and what SIFMA’s role has been in preparing the industry for this?

Robert Toomey: Yeah, thanks, Joe. Um, I think it’s important to have a little background, because as you said, I do think this is, and I think we all think that this is, is, as you said, the biggest structural change in the treasury market, which is the most important financial markets in the in the world, but this is the biggest structural change in at least 30, 40 years, involving all market participants. So a little on the rule and where the rule came from and some of the, I guess, policy objectives of the rule. First off, um, there had been over the last decade plus or so, a number of extreme volatility events in the treasury market, which um, you know, folks deemed were really unacceptable to what is the baseline, as I said, the baseline financial markets around the world. So, in order to address this, a number of policy prescriptions have been floated, some have been implemented, but treasury clearing is part and parcel of part of that effort to create a little more, and I think the goal is a little more resiliency and a little more capacity for intermediation within the treasury market. So moving ahead, the SEC in 20 in the early 2020s put put out the proposal around clearing and then finalized it in I don’t know, roughly a year later after an extensive comment period. Um, and basically what the rule does is it takes it looks at it takes the two ends of the treasury market. One, the cash market, and then the second piece is the treasury repo market, and it ups the ante on how much clearing is required and required as a regulatory matter to be within the clearing ecosystem, transactions that need to be within the clearing ecosystem. First off, is in the cash market, it’s a narrower scope than the repo market. I’ll talk about that in a second, but the cash market is a narrower scope, um, really focused on broker dealer activity, interdealer broker activity, cash activity. The repo market, on the other hand, is a much broader, um, has a much broader scope, really covering all treasury repo transactions, um, basically, is what’s within that. There are some exemptions there, some exemptions for certain types of entities, like so um, you know, sovereign entities, central banks and the like. Those are taken out as well. Um, so just a few notes, and then we can move on to some other issues just about the timeline on this. Um, for those who have been in this space and living under a rock, um, the original timeline was quite aggressive and would have been, would have required full implementation, including the repo piece this coming summer. That was extended by a year, about a year and change ago. And the current timelines are for the cash market for in-scope cash transactions are required to be cleared by the end of this year, and for repo transactions by the middle of next year. Um, so I think those are important deadlines that people should be focused on.

Seidel: Terrific. You know, each of you comes to this issue with a with a different perspective. And I think our listeners would like to hear all of these varying perspectives on this question. The rules proponents, SIFMA included, argue mandatory clearing will reduce systemic risk and improve resilience in the treasury market. But how does that happen? And are there structural benefits you’re already seeing as voluntary clearing has grown?

Bill Thum: You know, I’ll jump in here, Joe, you know, coming from a buy-side shop, my experience has been that voluntary clearing, which has been going on now for the better part of six or seven years, really helped to expand liquidity in the market, in that the benefits of capital relief for the sell side meant that they could they could clear more trades than they could do on an uncleared basis. So we found that our repo lines could at least stay as big as they are, perhaps even get bigger if we move to clearing. So on a voluntary basis, we did that some time ago when I was at a buy side shop. So now the mandatory clearing will kind of impose that for the entire market. And the expectation is that liquidity will certainly stay the same, if not improve significantly.

Toomey: Yeah, I think that’s a a couple things that I think you know policymakers are trying to get at in increasing, I guess, really the resiliency of the market. One piece, what clearing does is it eliminates counterparty credit risk. You know, the the CCP, the central counterparty, becomes buyer to all sellers and sellers to all buyers. And I think that’s an important feature to create additional sort of structural integrity to the market. As Bill noted, the capital benefits are real and do come to the the broker dealers, and that gives it some additional capacity to continue to intermediate to build liquidity in the market. So, and I think over time, and and Bill noted this, I mean, there was a buildup in you know, people accessing and getting into the clearing environment and accessing it because there are clear benefits. But that was starting to seemingly plateau a bit. And with the mandate, I think the goal is to get the significant majority of this market within clearing to get these benefits. It won’t be all of the market, but it’ll be pretty close to it, to get these benefits. And we’ve seen since the rule was put in place, certainly an increase in entities that I mean, before these deadlines certainly that have entered the clearing ecosystem because there are benefits and you know, benefits to, as I said, both the resiliency and expanding the capacity of particularly the dealers.

Stephen Byron: Yeah, let me just maybe build a little bit on what Rob said there. I think, you know, some of the benefits that you’ll see operationally in theory should be reduction in fails, right? You you’re netting off your transactions and therefore reducing the amount of trades that need to settle bilaterally, therefore reducing your settlement risk, which obviously then has positive knock-ons from from a capital perspective, as well as just an operational removing operational friction from the sort of settlement ecosystem that exists. So obviously the more volume they put through, the more trades can net and and the least bilateral reduction in bilateral settlement that you ultimately ultimately see, which is an important endpoint.

Seidel: Steve, following up a little bit on that line, what about the operations lift to comply with the new rules? You know, SIFMA has been running a number of coordinated work streams, including standardized documentation, developing operational timelines, and regulatory engagement. Can you walk us through the most significance of these efforts and and sort of where we stand today in terms of readiness?

Byron: Yep, thanks for that. Thanks for that, Joe. Let me give a bit of background here. So this has really been a multi-year effort here for us at SIFMA. I want to take you back to 2024 when we released our Treasury Clearing implementation guide, which really laid out how the changes would impact every aspect of a firm’s operations. So that with Treasury Clearing, there are actually impacts to documentation, as you mentioned, which will impact firms’ client onboarding. There are changes to margin structure, which will impact how firms process, receive customer margin. There, as we’ve mentioned already, there are changes to the settlement layer with the introduction of netting and fails. This really is a unique change in terms of it impacting every part of a firm’s post-trade life cycle. So, with that document, we we really published out a roadmap of areas that firms need to consider as to how they may be impacted by the move to treasury clearing. really that laid out the fact that the first step that firms need to take is really understand what access model they are going to use to access the market. That could be through an agency capacity, it could be through a sponsor capacity. Treasury clearing also introduces the concept of done away clearing for treasuries, which obviously exists in the derivative space but is new to Treasury. So that led on to our subsequent piece of work, which was really a done-away implementation guide, which laid out the trade flows for how done-away clearing will operate in the US Treasury market. That has some key components to it, which it which also includes the introduction of a pre-trade credit check. So, what is important to firms in the done-away space is the fact that they have certainty of clearing at point of execution. So the introduction of this pre-cra pre-trade credit check enables firms to get that certainty prior to executing the transaction that exists today in the derivative space, does not exist in the treasury space. So that needs to be built by firms as they start to build out their Donaway model if they are if they are planning to offer that. I’d also say we did we did extensive work on margin, that both from an operational perspective, but also from our SIFMA Capital Committee did a lot of work around capital treatment there, which I know we’re gonna get to later. Um, and also the documentation Fred, which I know Rob and Bill have been central to kind of running for SIFMA. So in terms of a high-level summary, Joe, I think that’s probably it.

Seidel: All right. But Rob and Bill, you have been leading some of our key work streams with the industry as well. So let’s maybe tell us a little bit about what’s going on there.

Toomey: Yeah, I’ll start off and then Bill certainly should jump in. But first off, and and Steve kind of outlined at least some of these, but most particularly and significantly, and this this developed right after the rule was finalized. We got input from our members that we really needed to develop market standard documentation to help with. Steve mentioned this, the onboarding of clients. Um, it was going to be obviously a significant uptick of those who were within the mandate and had to come into clearing. So we worked with our members to develop our first work stream around documentation, involved developing done with documentation. We published that some time ago, over a year ago. That’s been out of the market. People are using that documentation. We’re in the very last stages of putting together documentation to support the done away model. Obviously, Steve mentioned that’s starting to develop. It’s not fully developed yet, particularly in the repo space. Um, but we do expect that to come over time. So that documentation should be gotten out soon. We supplement our documents with as changes come into the structure or into the products that are being offered in the clearing space. We supplement with modules. We’ve recently published a collateral and LU module to support BNY’s and FICC’s collateral and LU product. Also a module to support triparty ACAs, ACS. We’ll also look to do models as new clearinghouses come up come on board modules for the documentation. As new clearinghouses come on board, we do expect CME and ICE, who have rule books out there.  and we expect them to come online sometime later in the year or early next year. So we’ll work on that as well. I’ll also note we have been doing consistently since the proposal and through till today, we continue to do advocacy work around open issues on the rule. And we’ll talk a little bit more in detail about what they are, but that’s been a significant work product all along because it’s important that people understand the scope of what’s in, what’s out. So what they can do then to implement appropriately, because they have to know which of their clients needed to be onboarded, which don’t. And I think that clarity is important. So we’ve been working on that over time. We’re working on margin issues, collateral issues, capital issues as well. And I know there’s some certainly some unique issues for the buy side, and Bill can talk to them. But Bill, from your perspective on the buy side, which which work streams do you want to highlight?

Bill Thum: Yeah, I think Rob, you did a great summary of the tremendous work on documentation that all of our members, Zelfside and Buy Side, have been doing for the past two years. You know, I would highlight one other thing, which is we’ve been partnering with service providers to offer to the market a documentation system so where parties can create a draft that is tailored to their business relationship and credit profile and otherwise negotiate the document through the system which tracks approvals for non-standard terms. And then once the document is agreed, the terms in the agreement can be populated in a database that can be shared internally in each organization to have platinum terms to steer the margin management systems. You know, all internal systems are better controlled by doing that. So that’s one thing that we’ve been doing in addition to just to coming up with a standard form documentation. On the regulatory front, for certainly on the buy side, you know, we focused on issues that are very important to the buy side members. We had a recent win. The NCC granted an exemption for interaffiliate trading for private funds that clear through a captive clear. That was a big win. We also have a comment into the IRS. REIT funds are limited in terms of concentration, and we have petitioned the IRS to make an exception for that with respect to clear trades. So those are just two examples of the regulatory work that we’re also doing for the buy side as well as the sell side.

Seidel: And we certainly have had very, very good regulatory engagement with our friends at the agencies. Bill, then for asset managers in particular, the done-away clearing model is central to how they’ll access Cleary. CIFPA published done-away model design considerations and more recently done-away documentation. What are the core operational challenges that framework is trying to solve? And what does a well-functioning done-away model look like in practice to you?

Thum: Yeah, that’s a great question. You know, and make no mistake, many of our members will continue to access the market through the done with model where they trade with their, they execute a trade with their clearing member and then clear the trade with the clearing member. But other members are very eager to be able to enter the market and on a competitive basis with across the dealer community to get the best price and liquidity and other terms. So they really are looking forward to the done-away model, which will allow you to execute a trade with any number of brokers that you reach out to for a quote and then have any of those trades cleared through your central clearing member. You know, and you may have one or more clearing members, but you’ll be able to trade with across the street. The interest in that, of course, is to get the best pricing possible. Also to have an efficient approach to documentation. You don’t need a full-blown clearing agreement with everyone that you trade with. So many of our members are very, very excited about that. The infrastructure for that is going to be similar to the infrastructure that has been developed in the future space or the clear derivative space over the past few years. Um, so that will have to be replicated and a lot of those considerations are spelled out in the playbooks that SIFMA has developed that Steve was talking about earlier. So there’s one for both the Done With and one for the done-away markets, and that they provide an outline of connectivity and plumbing and relationships with service providers that you’ll need to be able to move ahead in the done-away space.

Seidel: So presumably with Donewith and done-away combined, we’ll have the capacity online to take up what is needed with the treasury market one on sort of today.

Thum: That’s the expectation, you know, and not just take it up, but maybe expand it significantly. Terrific.

Seidel: Rob and Steve, then, from the broker dealer side, what are the most significant and operational and capital implications of the rule? How are the firms thinking about their role as clearing members under the expanded clearing mandate?

Toomey: Well, I think first certainly firms do recognize over time that there will be, and this is one of the goals, create some capital benefits for the broker dealer community specifically so that they can provide more intermediation services. I think that’s key. But then also you talk about efficiencies and changes too, and and Steve can talk to those a bit, around margin practices. I know um, you know, that’s an important piece of this. Those have to develop over time, and those have to develop for the the models to develop. I think, too, from a broker dealer perspective, and you know, firms are looking very much at the two models, the done with, the done away. FICC is a sponsored service which largely works with the done with model. Firms, as a first measure, and this reflects, you know, why we did the documentation the way we did and why we sequenced it the way we we did, was as as a first measure, making sure their done-with relationships are locked up, are you know appropriately papered, ready to go. And this, unlike T1, this isn’t a, you know, big bang deadline. If you’re ready, you can go tomorrow. You can you know bring somebody into clearing, bring transactions into clearing. And we’re seeing that happen. I do think the second piece of this, and Steve can talk, is the is really around the development. And you know, Bill alluded to this: the development of the done-away, how that’s gonna work, the infrastructure providers, the third party, the vendors that are gonna have to support that, the documentation that’s gonna support that, and how that ramps up over time. I do think firms are looking at it, looking at it as how they accommodate their customers.

Byron: Yeah, I think that’s I think that’s right. I know it’s a good segue. I think, Rob, the the drive in my mind is really that client-demand angle, right? So the the sell side will respond to the buy side looking for access to a particular model, right? And I I think that and you you’ll see as the as the buy side starts looking to build out the Donaway model, the sell side obviously will be looking to support that. I think the introduction of the new central current parties here with ICE and CME coming online will be again another aspect which will be client-driven, right? So firms are going to have to react to clients looking to use those use those CCPs to potentially leverage some of the margin benefits that they may see from having activity, derivative activity as well as on futures activity as well as their treasury activity on the same CCP. So there’s that. I think the development of the cross-margining is going to be important and the build-out of liquidity there. So there are a number of there are a number of pieces that have to kind of fall into place there. As as Rob said, the Dunn Wayflow is still is being built out, but we’re at early stages of that. So last year, when we published our implementation guide, we met with multiple infrastructure providers. Um, it was a combined effort across biceps. And sell side in terms of laying out how they want the done-away clearing flow to work. But that does require infrastructure to be built out, and it does require both buy side and sell side to do some work there in order to support that. On the documentation side, that’s certainly an area that firms are going to need to focus on. Because I think that that is good is likely going to be a bottleneck as we kind of walk through the next 12 months as firms start that process. And whilst we have standardized documentation, there is a certain amount of negotiation that will need to take place between firms. And that will take time. So firms need to be looking at that and kind of building that out and building that time that they need to take to do that documentation negotiation into their projected project timelines as we kind of move forward towards that repo go live next summer. On the capital side, I’d say that there are some in-flight open questions out there with with the regulators. One is particularly around how firms can treat customer margin for 15C3 purposes. So that is an open question as to whether or not they can take the the debit on their as part of their calculation for 15c3 calcul calculations. So we’re still waiting to hear back on that, but that will obviously as well impact how firms continue out their sort of capital calculations.

Thum: I did want to just jump in one thing on the documentation. You know, it it does sound daunting to think that we have a new master agreement that has to be signed up, but the beauty of what we’ve published so far is that if you have a an MRA or a Jimra, there’s also an amendment agreement that you can add to that to upgrade it to clearing. And if you already are voluntarily clearing, we have an amendment agreement to that, to your clearing agreement, so that it comes in line with the market standard terms. So you can either sign a full-blown new master agreement, you can sign an amendment to an existing clearing agreement or an addendum to your Jim or MRA. Yeah, any one of those paths will get you to the finish line.

Seidel: With the deadline so close, there are still open regulatory questions and particularly about the interaffiliate exemptions, the treatment of offshore entities and registered funds potentially in scope. How are we at SIFMA engaging with the SEC on these outstanding issues and how much uncertainty do they create for firms trying to finalize their implementation plans right now?

Toomey: Yeah, Joe, and we’ve talked a little bit about it and you really teed up the key issues. These are important issues for implementation in that they really go, and I think I mentioned it earlier, but they really go to scoping. What’s in, what’s out? And if you think about it for a nanosecond, you realize that an important question in any implementation is what do I include and what is excluded? And I think these open questions specifically get to that. And you know, there has been considerable, I guess, lack of clarity up until now around the interaffiliate exemption, around the global cross-border impact. This rule does not stop at the U.S. border. It does have impacts globally for transactions and treasuries that are done throughout the world. So it’s an important issue to understand what’s in, what’s out. The SEC, and we have certainly been engaged with the SEC on these issues really since day one, because they were recognized as key scoping issues that needed additional clarity. And to the SEC’s credit, they’ve certainly been engaged in this. You’ve heard Commissioner Ueda, who is leading kind of the effort at the SEC to help the industry implement this, has mentioned on numerous occasions they are focused on getting these resolved. There have been recent proposals, one by SIFMA, one by the IRB, to address some of these issues. And the SEC has put those out for comment. Comment periods closed. We do, and we are continuing to engage with the SEC on how they’re going to resolve those issues. We do expect that to get done in a relative short order. Steve certainly mentioned the question around, you know, gross versus net treatment of your margin for the customer reserve formula. We expect that to get resolved. That’s been a key piece of this puzzle. But I will say the industry, MESC has been very engaged collectively in trying to address these. They they really do need to get addressed because that drives a lot of the implementation. Again, which of your clients are in, which of your clients are out? These are important questions that need to be resolved, and that will smooth things over. And I think we’re right at the point where they need to be done now so people can then smoothly implement going forward. There are sorry, sorry.

Byron: No, I was gonna I was gonna maybe build a little bit on Rob’s response there, because there are there are a couple of other areas that we are also working with the SEC on, in particular around more on the operational side, and particularly around a trade that is submitted for clearing in good faith that gets kicked out for any particular reason on the operational side and how the SEC will view that. Obviously firms will make their best attempts to resubmit for clearing, but in the case that it is unable to clear and the trade has to settle bilaterally, what will be the regulator’s view on that? So that’s certainly an open question that we have outstanding with the SEC currently, as well as there’s an open question around a government securities dealer list, which will ultimately help if a golden source is available for that, which will ultimately help firms determine what’s in scope and out of scope there. So there’s there’s a couple of additional areas that we’re still waiting for clarity on. Absolutely.

Seidel: No, that list has been something we’ve we’ve wanted for a while. Rob and Bill, you know, this rule affects broker dealers and asset managers, the sell side and the buy side differently, but they’re deeply interdependent. A firm can’t clear done-away trades without tight coordination between both sides. Where have you seen the strongest collaboration? And where are the friction points we still have that still need to be worked out before the deadlines hit?

Thum: Well, I’ll start out. I think, you know, we’ve been working on the done-away documentation for a long time, and obviously there there’s a reason for that, and it has been a challenge to bring the parties together on some of the issues as they face a document that will live in the coming decades as a business relationship for them. So I think we’re just about at the finish line here, but that has been, you know, I think a very intense effort on both sides to make sure that it speaks to their concerns. So I’m glad we’re almost at the end of that process. And I want to applaud the members on both sides that have stuck with it so long to get the optimal document. But publishing it now is very important because we’ll have little more than a year to get them all in place. That’s the thing that I would highlight. We’ve seen collaboration and we have an opportunity to get to the finish line.

Toomey: Yeah, Bill highlights, I think, what was certainly the goal of the effort and with why we structured it the way we did here at CIFMO on the documentation was it is a joint buy and sell side effort because what we want to do, and Joe, in your in your question you asked about frictions. I mean, the idea is to try to minimize those frictions as much as possible in the onboarding process by having um, you know, documents that people are comfortable with and that have largely been looked at by many participants within the industry. So I think that helps with the onboarding. But I mean, onboarding itself, you know, Steve certainly alluded to this, is a friction. Is you know, documents still need to be negotiated. People need to still understand. There are still other things in play that we haven’t mentioned. The FICC rule book will need to be finalized in relatively short order. So people just again, these all these issues that are kind of at the periphery need to be resolved so that people can move on with a smooth implementation timeline, again, knowing what’s in, what’s out, who’s in, who’s out, how the negotiations are going forward. And once that’s in place, I think people can get comfortable with the implementation timeline.

Seidel: No, I I think you guys had lots of input from and places to look at, what do swaps agreements look like, what are futures agreements, but you really went about the task beginning whatever, 18, 24 months ago of putting together something that was entirely new and bespoke. And while you could look at other things, we really could not, you know, draw on them and to the extent as opposed to creating a sort of a new thing here. So as you look looking at it, look at the sort of final result, and there remains a lot of work to do before that that implementation deadline next year. What at the end of this trail do you think the key the buy and the sell side will see as the key benefits they’ve gained? You know, credit risk, capital relief, other things that you think will ultimately be at the end of the journey that will benefit both both all participants out of this?

Toomey: Well, yes, you highlighted, and we have talked about that. Those are certainly the policy goals to get some capital benefits to eliminate some of the risk within the system. But I think the overall goal certainly, and Bill gets to this, is how do you take the largest, most important financial market in the world, create stability within it, and create additional, you know, the the treasury market is a very attractive market for investors. Certainly, obviously it’s it’s deep, it’s liquid, it continues to be deep and liquid. But how do you enhance that? How do you make that better? Clearings isn’t the be-all and end all here, but it’s certainly part of, you know, the overall response to creating a more resilient market. So I think there’s benefits. There’s benefits to individual firms in their ability to do more activity, to invest in more, to intermediate more within the treasury market. That’s a benefit to the individual firms. It’s a benefit to the market overall. And I think that’s the broader policy goal. So I think once, and there may be, as in with any new process that’s kind of this vast, I guess, or significant to a particular market, there may be some bumps in the road here and there. But if you look out five years, I do think firms are going to look back and think this is well worthwhile, and well worthwhile in the sense of, again, increasing that capacity, increasing the resiliency within the treasury market. And I think that’s kind of the the bottom line here.

Thum: Yeah, and I would just add, I think the participants have been very effective at identifying potential challenges to the expansion of the market and have been coming up with creative solutions the whole time. And one, you know, certainly for money market funds has been the development of the collateral and loo model, which FICC has nailed down. And I understand the other clearinghouses are going to have their own version of it. But that really gets at one of the core challenges of clearing, which is the double margining issue. And whether it was done on a voluntary basis or is expanded into a mandatory basis, there was, you know, effectively the double margining increased costs and you know created some friction that is resolved through collateral and low, where the clearinghouse takes a security interest in the margin that’s held by the custodian. So, you know, that’s one example, but there are many, many examples of problems that have been solved that you know, we we really didn’t have in our crystal bowl two years ago, but have cropped up in this process. And, you know, the market buy and sell side, the clearinghouses, the service providers have all been working hard to identify and address those. And I think they’ve been successful.

Seidel: Then for each of you, as we get closer now to the December 2026 clash going deadline, what should listeners, whether they’re a broker dealer, an asset manager, or a service provider, be doing right now? And where can they find the SIFMA resources to help?

Toomey: Yeah, I’ll start off. Certainly, we have a section on our website that contains the resources, particularly Steve mentioned on our various considerations reports that we’ve done. I think they’re they are excellent documents in giving you really a sort of a template on what the issues is are, what you should be considering, and particularly what you should be considering as you get into the Donaway context and as that model develops. Certainly, our documentation is all available. It’s available to the market on our website. You should become familiar with that. We have training courses that are available on the documentation. The documentation, quite frankly, is complex and it doesn’t hurt to get a little refresher course from all our partners, our legal partners, Cleary Gottlieb, who helped us develop those. Um, they do a very good training course that’s available, so you should think about that as well. Um, and I think too, you know, again, I think the cash piece, as I said this at the outset, the cash piece is a narrower set of market participants and transactions. We expect them to be very much in a position to be ready by the end of this year. The repo part’s a little more complicated because it does implicate a lot more types of entities are are certainly in scope. So I think if you’re not focused on this now, you should be focused on this if you’re a participant in this market because we’ve noted all throughout there is documentation that needs to be executed that needs to be negotiated. Notwithstanding that it may be market standard in the SIFMA documentation, it still takes time. Um, so you should be focused on getting this done now, not later. This is a this year project, not a next year project.

Thum: Yeah, and I’d add on the cash side, um, you know, certainly if you’re involved in the cash side, then reach out to your brokers as soon as possible if you haven’t already, and get an understanding from them as to what you need to do. We are looking to put together some form of workshop to bring the IDBs together to share exactly what those processes are for the for the buy side to start to engage in. We have about six months to go on the cash clearing. On the Rebo clearing, you know, Rob made a very good point, which is um, you know, you really can’t wait until next year to get going on the documentation. There will be gridlock. Um, you know, we’re already talking to members and they are looking at their dealer stable. They are identifying which dealers are the most critical for their businesses and they’re targeting those right away to get documents in place now with the idea to layer in additional dealers over time. Um, because it at this point with a year to go, it’s going to be a big challenge to get all the documents done for everyone. But if you can look at your stable of dealers and prioritize those that are most important, that’s probably the best way. And then for the dealer community, you know, I would certainly advocate look into the service providers for the documentation systems because you really can set them up to be more of a self-service approach where your clients can access a template, fill in forms, get the documentation process started, and then have it all handled through the documentation system much more efficiently than the old-fashioned way of having, you know, 20 negotiators, each with 150 negotiations, trying to struggle through those and listening to the ones that yell the loudest. So look at those service providers, it’s really the way of the future in a way that you get platinum terms in your organization.

Byron: Yeah, and I think there’s a couple of things I I would just flag in terms of, you know, similar to the documentation side, if firms are looking at supporting done-away activity, they need to be thinking about what needs to be built now. Um, and kind of you know, looking at those new flows that have been laid out and understanding what technology needs to be implemented in order for them to support that. That will take some time to work through that, understand how the clearing firms and and sell side by side are going to interact through those and understand what you need to build. So I’d certainly recommend firms start starting there. At the end of last year, SIFMA in conjunction with the value exchange, BNY, DTCC and Broadridge, ran a readiness survey. That survey came back and really highlighted that the US was in a fairly good place with a year, over a year to go to the cash deadline, and 18 months to the repo deadline. We’re rerunning that survey now. So in the next month, two months, we should have really good insight into where the industry is in terms of its its readiness. Um, I think as Rob said, the expectation is that the given the limited scope of the cash deadline, that that should firms will be prepared for that. I think it’s all eyes on that repo deadline next next summer and ensuring firms are have have built out the required flows and are moving volume earlier than the next summer’s deadline. Perfect.

Seidel: Well, thank you, Rob, Bill, and Steve. That was a great deal of you very useful information for our listeners, and thank you to our listeners for tuning into the SIFMA podcast. To learn more about SIFMA and our work to promote effective and resilient markets, please visit us at sifma.org, and thank you for listening today.