DTC Updates Disruption Rules to Keep Transactions Flowing Smoothly
Published Date: 6/27/2025
Notice
Summary
The Depository Trust Company (DTC) wants to update its rules about what happens if their system faces a big disruption. This affects all participants who rely on DTC’s services to keep financial transactions running smoothly. The SEC is reviewing these changes and will decide soon if they’re good to go, with public comments already in the mix—so stay tuned for possible impacts on timing and operations!
Analyzed Economic Effects
4 provisions identified: 4 benefits, 0 costs, 0 mixed.
Narrower 'System Disruption' Scope
The rule change narrows the definition of a Participant System Disruption so it covers only incidents to systems that are connected to DTCC Systems. The amended definition describes an incident from unintended or unauthorized access, malfunction, or corruption of one or more systems of a DTCC Systems Participant or its Third-Party Provider that are connected to DTCC Systems.
New Third-Party Provider Responsibility
The amendment adds a defined term 'Third-Party Provider' and redefines 'DTCC Systems Participant' to mean any Respective Participant that connects with DTCC Systems either directly or indirectly via a Third-Party Provider. The filing states Respective Participants would be the sole responsible parties under the Disruption Rules whether they connect directly or indirectly.
Slimmed Notification and Reporting Rules
The amendment simplifies notification requirements: it removes proposed language requiring notices 'on behalf of itself and any Affiliate' and deletes the proposed requirement for knowledge-based notices about unaffiliated participants. It also limits the Clearing Agencies' request to notices and other information about a Participant System Disruption that have been made 'public.'
Allow Summaries Instead of Full Cyber Reports
Under the amendment, a DTCC Systems Participant seeking to reestablish connectivity may provide a 'summary' of the Third-Party Cybersecurity Firm report instead of the full report itself. The change is intended to address concerns about providing material non-public information to the Clearing Agencies.
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