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Katten

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To IDB or to ECN? Will Your Cash Market Transactions in US Treasuries Be Subject to the Clearing Mandate Come December 31, 2026?

In December 2023, the US Securities and Exchange Commission (SEC) adopted rules requiring covered clearing agencies to maintain written policies and procedures that are reasonably designed to require their direct participants to centrally clear all eligible secondary market transactions in US Treasury securities to which they are a counterparty (the Clearing Mandate).2 There are three "covered clearing agencies" (each, a CCA) in scope of the Clearing Mandate: the Fixed Income Clearing Corporation, CME Securities Clearing and ICE Clear Credit. The term direct participant refers to each CCA’s clearing members. The deadline for eligible cash market transactions is December 31, 2026.