SEC Speeds Up Trade Matching Rule—Feedback Invited
Published Date: 4/20/2026
Notice
Summary
The SEC is asking for feedback on extending a rule that helps companies who match securities trades speed up their work. This rule affects firms that aren’t registered as clearing agencies but help make sure trades settle faster—cutting the wait from two days to just one. The goal? Smoother, quicker trade settlements with no extra costs or delays for these companies.
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Analyzed Economic Effects
4 provisions identified: 0 benefits, 4 costs, 0 mixed.
Must Adopt Straight‑Through Policies
If you operate a matching service that is exempt from clearing agency registration (a central matching service provider), Rule 17Ad-27 requires you to establish, implement, maintain, and enforce written policies and procedures reasonably designed to facilitate straight-through processing for transactions involving broker-dealers and their customers. This requirement is part of the SEC’s effort to shorten the standard settlement cycle from two business days (T+2) to one business day (T+1).
Annual Reporting Requirement for CMSPs
If you are a central matching service provider, you must submit to the SEC an annual report every 12 months that includes: (1) a summary of your straight-through processing policies and procedures current as of the report end date; (2) a qualitative description of progress over the 12-month period; (3) quantitative data including total trades submitted, total allocations, total confirmations and cancellations, percentage of confirmations affirmed on trade date with timeframe, percentage of matches/automatic confirmations, and metrics on manual vs automated processes; and (4) a qualitative description of planned actions for the following 12 months.
How Annual Data Must Be Organized and Presented
Data submitted under Rule 17Ad-27 must be organized month-by-month starting with January for the 12 months covered, separated where applicable between central matching and electronic trade confirmation services, separated by asset class and by type of user, and presented on an anonymized and aggregated basis.
Estimated Compliance Time: 37 Hours Annually
The SEC estimates the ongoing annual burden of Rule 17Ad-27 on a respondent CMSP is 37 hours per year (24 hours for a compliance attorney + 10 hours for a computer operations manager + 3 hours for Inline XBRL tagging). The notice also states the aggregate annual burden for the industry is 37 hours and notes that currently one CMSP operates under the exemption.
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