Depository Trust Refines Its Crisis Recovery Blueprint
Published Date: 4/7/2025
Notice
Summary
The Depository Trust Company (DTC) updated its Recovery and Wind-Down Plan to keep up with new business changes and make the plan clearer and easier to follow. This affects anyone relying on DTC’s rules for handling emergencies or shutdowns, ensuring smoother operations if things go wrong. The changes took effect right away on March 25, 2025, with no new costs announced.
Analyzed Economic Effects
6 provisions identified: 6 benefits, 0 costs, 0 mixed.
Critical Services Reclassified and Consolidated
DTC consolidated and renamed multiple entries in its Table of Critical Services (for example, renaming "CNS Deliveries" to "Equity, Corporate, and Muni Debt Transaction Processing" and moving several functions to be listed as material components). DTC also moved the ACATS entry to NSCC's critical services list and added two services: "Reorganizations" and "Tax Event Announcements."
Governance, Review Frequency, and Cost Wording
DTC updated governance references (e.g., increasing Board committees from six to seven, renaming committees) and states it completed its most recent biennial review in 2024. The filing notes that upon the effective date of SEC Rule 17ad-26(9), DTC will update procedures to require Board review and approval of the Plan at least every 12 months or after material operational changes. The Plan's text was also revised to state estimated execution costs are "at least" four months of operating expenses.
Amendments Effective Immediately
DTC's amended Recovery & Wind-Down Plan took effect immediately on March 25, 2025. The filing states no new costs were announced in connection with these amendments.
New Hyderabad Facility Added
DTC updated its intercompany facilities table to add a leased DTCC site in Hyderabad, India that became operational at the end of 2024 and made clear DTCC owns the Tampa, Florida location. These changes update where corporate support services are provided.
Clearing Links Reclassified and Updated
DTC removed Deposito Central de Valores S.A. from its list of inbound Clearing Agency links (following its voluntary termination) and reclassified Federal Reserve Bank Pledge Services from the Links table to the Schedule A Relationships table. The filing also updates certain wording in link descriptions.
Hedging Corridor Indicator Removed
DTC removed the "hedging" entry from its Table 5-A Corridor Indicators because the liquidation portfolio is primarily long-only and hedging those positions is not judged to be cost-effective. The plan explains positions are subject to conservative haircuts as a business-as-usual process.
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