DTCC Consulting worked with a global broker-dealer to assess the impact of expanded U.S. Treasury clearing requirements across multiple entities. We identified critical decisions and developed a prioritized roadmap to support its readiness program.

Background

Preparing for expanded U.S. Treasury clearing required the client to understand the impact of regulatory change across multiple entities, systems, processes and controls.

The client engaged us to assess its current state across three entities and determine readiness in relation to the SEC-mandated requirements covering account separation, cash clearing and repo/triparty clearing. 

With deadlines of December 31, 2026, for cash clearing and June 30, 2027, for repo clearing, the engagement also needed to establish a clear set of priorities and decisions to help guide the client's timely preparations.

“By combining a detailed understanding of the client’s operating model with deep knowledge of FICC’s clearing framework and industry practices, we helped turn complexity into a clear path forward, focused on the decisions that matter most for implementation.”

DTCC Consulting

Our Approach

DTCC Consulting took a three-phase approach covering current-state assessment, impact assessment and key decisions, followed by recommendations and roadmap development.

We identified nine relevant workstreams across the three entities and reviewed U.S. Treasury trade data alongside information including sponsoring client numbers, trade-processing architecture and client-outreach documentation.

Working sessions were used to assess impacts across the client's operating model and identify areas requiring action. 

We also drew on our firsthand knowledge and unique perspective into FICC's rules, operating model and market practices to develop recommendations, while collaborating with the client's existing sponsored repo initiative.

Impact

The engagement identified 243 impacts and 194 recommendations across the client's workstreams and entities, with recommendations prioritized according to their importance.

This provided the client with a structured view of the decisions and actions required to advance its readiness program, including considerations around margin requirements, service-model choices and risk and control involvement.

DTCC Consulting consolidated these findings into a prioritized roadmap aligned with regulatory requirements, giving the client a clear framework for progressing its U.S. Treasury clearing preparations.