Wall Street Clearing Firm Preps for Tech Glitches with Rule Tweaks
Published Date: 3/27/2025
Notice
Summary
The Fixed Income Clearing Corporation (FICC) is updating its rules to better handle system disruptions that might affect participants using their services. These changes also involve two sister agencies, NSCC and DTC, and aim to keep things running smoothly during tech hiccups. If you’re a participant, expect clearer steps and protections soon, with no immediate cost changes announced.
Analyzed Economic Effects
5 provisions identified: 0 benefits, 5 costs, 0 mixed.
Reconnection needs third‑party report, attestation, indemnity
Before a disconnected DTCC Systems Participant can be reconnected, the Clearing Agencies will require: (i) a detailed, auditable report from a Third-Party Cybersecurity Firm (including timeline, root cause, confirmation of resolution and confirmation of normal operation for at least 72 hours); (ii) an attestation from a Participant Officer confirming report accuracy, remediation implementation and recommendation for reconnection; and (iii) an executed indemnity acceptable to the Clearing Agencies.
Mandatory reconnection testing and approval steps
Prior to approval to reconnect, a DTCC Systems Participant must demonstrate in a test environment that it can send/receive messages and transactions, replay/resubmit, reverse/void, confirm integrity, maintain alternative communications with the Clearing Agency, and meet any other reasonably requested requirements. Approval of reconnection must be made by two or more members of the Clearing Agencies’ senior most management committee after satisfactory testing.
Broader rule coverage for affiliates
If your firm connects with DTCC systems, the rules now explicitly cover Affiliates of participants and entities similar to third-party service providers or service bureaus that connect directly or indirectly on behalf of participants. The definition of “DTCC Systems Participant” is broadened to name specific participant types and include Affiliates and such third parties.
Fast 2-hour disruption reporting requirement
If you are a DTCC Systems Participant, you must provide immediate written notice — and in any event within two hours — to the Clearing Agencies after experiencing or having legal permission to disclose knowledge of an unaffiliated participant’s disruption. Notices must include legal entity names, contact details, event type, start/end dates (if known), scope, and other contextual details.
Stronger noncompliance and responsibility rules
The Disruption Rules replace the ‘‘conflicts’’ provision with a ‘‘failure to comply’’ provision: Respective Participants that fail to comply may face any disciplinary action allowed under Clearing Agencies’ rules; non‑Respective Participants may face actions or obligations under the agreements with the Clearing Agencies; and a participant that authorized another party’s access can be required to assume responsibility for that party’s compliance failures.
Your PRIA Score
Personalized for You
How does this regulation affect your finances?
Sign up for a PRIA Policy Scan to see your personalized alignment score for this federal register document and every other regulation we track. We analyze your financial profile against policy provisions to show you exactly what matters to your wallet.
Key Dates
Department and Agencies
Take It Personal
Get Your Personalized Policy View
Start a Free Government Policy Watch to see how policy affects your household, then upgrade to PRIA Full Coverage for year-round monitoring.
Already have an account? Sign in