SIFMA Publishes US Treasury and Repo Done-Away Model Design Considerations

New York, NY, December 15, 2025 – Today, SIFMA published a report with Ernst & Young LLP (EY US), “U.S. Treasury and Repo Clearing Done-Away Model Design Considerations.” The report provides a guideline and framework for baseline U.S. Treasury done-away clearing requirements under the Securities and Exchange Commission’s (SEC) upcoming Treasury Clearing Rule. This report is a follow-on to the “U.S. Treasury Central Clearing Industry Considerations Report” published in November 2024.

Done-away Treasury clearing refers to the process in which trades executed by an external broker are centrally cleared through a firm’s designated clearing provider rather than the executing broker.

The document has four objectives:

• Outline the desired done-away flows for different execution paths as defined by market participants;
• Describe roles and responsibilities of market participants, covered clearing agencies (CCAs), trading venues, and other technology platforms across the trade lifecycle;
• Identify the core capabilities and data requirements need to be established to enable the desired done-away flows; and
• Indicate proposed owners for developing and implementing the defined core capabilities.

“As we approach the effective date for central clearing of U.S. Treasury securities, SIFMA is working to support the industry with the transition to ensure there is as little disruption as possible to this important market,” said Joe Seidel, SIFMA Chief Operating Officer.  “This report, in conjunction with our other efforts, is designed to help firms with their steps to preparedness.  Treasuries play a key role in both the U.S. and world economies and SIFMA is supportive of efforts to make the market more resilient, while at the same time we recognize the need to ensure liquidity is not negatively impacted.”

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 December 31, 2026, for eligible cash market transactions, and June 30, 2027, for eligible repo market transactions.

“As the effective date for central clearing of U.S. Treasury securities approaches, the industry faces a critical transition that must be managed carefully to avoid disruption,” said Neal Ullman, Managing Director, Financial Services Consulting, EY. “This report provides key design considerations for implementing a done-away model to help prepare for compliance, while reinforcing the importance of maintaining market stability and liquidity.”

The report is designed to capture and organize the proposed done-away flows and core requirements based on input and subject-matter analysis from market participants on both the buy side and sell side. Through input collected for the November 2024 Considerations Report, eight total industry challenges were highlighted related to open concerns and specific elements to design a controlled and resilient U.S. Treasury Clearing done-away model. SIFMA organized a done-away steering committee comprised of both buy and sell side representation to help discuss, prioritize, ideate, and document a proposed done-away model that includes operational flows, core capabilities required, and roles and responsibilities of each party involved.

The following challenges were prioritized for this effort:

• Supporting data capabilities
• Pre-trade limit checks for various execution paths (e.g., Central Limit Order Book “CLOB”, Request for Quote “RFQ”, Voice)
• Operational flows and submission to CCAs
• Bunched orders/allocations

The full report is available at the following link.

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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).