Done-away Model Design Considerations

This 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.

Summary

Through input collected for the USTC Considerations Report, eight total industry challenges were highlighted related to open concerns and specific elements to design a controlled and resilient USTC done-away model.

This initiative began in summer 2025 with a Steerco comprised of representative buy-side and sell-side firms and supported by EY. Input for the done-away flows and core requirements was provided through:

1. Working sessions with SIFMA done-away Steerco and broader SIFMA members firms
2. Bilateral conversations with various types of market participants, and
3. Informational sessions with CCAs, trading venues, and technology vendors

Scope

• This document is for industry-wide consumption to support CCAs, technology vendors, and broader market participants to build, refine, and implement a consistent and functional done-away model in advance of the upcoming compliance dates
• The scope of this document focuses on transactions that do not require allocations; flows and requirements for bunched order allocations continue to be discussed and refined
• Flows and requirements documented are agnostic to products (Cash and Repo), clearing access models, and CCAs

Primary 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.