DTC Refines Doomsday Plan Under New Exchange Rules
Published Date: 4/28/2025
Notice
Summary
The Depository Trust Company (DTC) is updating its plan to handle tough times, like big money losses or business troubles, to keep the financial system safe and steady. This update makes sure DTC follows new rules that require clear steps for recovery or an orderly shutdown if needed. These changes affect DTC and its users, aiming to protect everyone's money and keep things running smoothly without surprise costs or delays.
Analyzed Economic Effects
4 provisions identified: 3 benefits, 0 costs, 1 mixed.
Keeps DTC services running during crises
DTC's amended Recovery & Wind-Down Plan is designed to keep DTC's core payment, clearing, and settlement services operating in extreme stress and to enable Participants and Pledgees to maintain access by transferring DTC membership if DTC defaults or the Wind-down Plan is triggered. The changes are intended to meet SEC Rule 17ad-26 and would take effect on the rule's compliance date, December 15, 2025.
Defines staffing needs and retention tools
The amended Plan will include an attachment (Attachment A-1) listing staffing roles needed to support DTC's core services and an analysis (Attachment A-2) of how to retain those roles during recovery or wind-down. The analysis explicitly lists succession planning, retention agreements, and cross-training as key tools to address employee retention challenges.
Requires review of service-provider contracts
DTC will identify third-party and affiliated service providers for core services (Attachment B-1) and, by the compliance date, review written agreements to evaluate termination and alteration rights and endeavor to amend agreements so those providers continue to perform in a recovery or orderly wind-down. The compliance date for Rule 17ad-26 is December 15, 2025.
Annual testing and participant simulations required
The Plan will include procedures (Attachment F) to test DTC's ability to implement recovery and wind-down at least every 12 months, and certain DTC Participants will be required to participate in simulations based on criteria like account structure, business model, and Participant size. The Board must review and approve the Plan at least every 12 months or after material changes (Attachment G).
Personalized for You
How does this regulation affect your finances?
Personalize government policy and PRIA will tell you what this federal register document means for your household, plus every other regulation we track. PRIA reads each provision against your financial profile to show you exactly what matters to your wallet.
Key Dates
Department and Agencies
Related Federal Register Documents
2026-20466, Adviser and Regulated Fund Custody Rules; Crypto Custody Rules
The SEC is updating rules for how investment advisers and funds handle crypto assets, making sure they keep these digital investments safe and properly reported. These changes affect advisers, funds, and anyone managing crypto securities, aiming to modernize rules and improve transparency. Comments on the proposal are open until December 7, 2026, so get ready to weigh in!
2026-19260, Rescission of Rule 14a-8's Federal Regulation of Shareholder Proposals and Amendments to Rule 14a-4
The SEC wants to stop its federal rule that controls how shareholders can make proposals at company meetings, letting state laws and company rules take over instead. They’re also changing rules so companies can sometimes vote on proposals not in their official materials—but shareholders can opt out if they want. This affects investors and companies, with comments open until November 20, 2026, and could shake up how shareholder voices are heard and counted.
2026-18424, Political Contributions by Certain Investment Advisers
The Securities and Exchange Commission (the "Commission" or the "SEC") is proposing to rescind the political contribution rule under the Investment Advisers Act of 1940 (the "Advisers Act"), which prohibits investment advisers from providing investment advisory services for compensation to a government client for two years after an adviser or any covered associate of the adviser makes a contribution to certain categories of elected officials or candidates, among other prohibitions. In the more than fifteen years since the rule was adopted, implementation challenges associated with the political contribution rule have resulted in a range of significant unintended consequences, including compliance practices among some investment advisers that may have had the effect of restricting all political contributions by the investment advisers and their employees. Market participants also have stated that the political contribution rule is burdensome, complex, and both lacks clarity and creates a de facto strict liability standard. The Commission is of the view that other existing requirements of the Advisers Act and its associated rules, including prohibitions on fraud, fiduciary duty requirements, the compliance rule, and the code of ethics rule (defined below), are likely sufficient to address pay-to-play practices while allowing an adviser the flexibility to implement an approach that is more appropriately tailored to its particular risks, rendering the political contribution rule unnecessary. The Commission also is proposing to amend the rule under the Advisers Act pertaining to books and records consistent with the proposed rescission.
2026-18190, Transfer Agent Rules
The U.S. Securities and Exchange Commission ("SEC" or "Commission") is proposing to adopt new rules, amend existing rules, amend the existing form for registration with the Commission as a transfer agent (Form TA-1) and the existing form for reporting activities of transfer agents (Form TA-2), and rescind an existing rule governing registered transfer agents. The proposals are designed to modernize the rules governing registered transfer agents.
2026-17183, Regulation Crypto Assets
The Securities and Exchange Commission ("Commission") is proposing new rules to create a tailored offering regime for certain investment contracts involving crypto assets. The proposed offering regime is intended to facilitate capital formation and accommodate innovation within the crypto asset markets while, at the same time, ensuring that investors are adequately protected and provided with the information they need to make informed investment decisions. The proposed rules would be set forth in a new regulation titled "Regulation Crypto Assets" and would include two exemptions from the registration requirements of section 5 of the Securities Act of 1933. The first exemption would permit offerings of up to $5 million during a four-year period. The second exemption would permit offerings of up to $75 million during each 12-month period. Under both exemptions, issuers would be required to make certain principles-based narrative disclosures available to their investors. In addition, issuers under the second exemption would be required to provide financial statements and would be subject to ongoing reporting requirements. Issuers that rely on these exemptions would remain subject to the antifraud and antimanipulation provisions of the Federal securities laws. The proposed rules also would include a conditional safe harbor from the term "investment contract" in the definitions of "security" in the Securities Act of 1933 and the Securities Exchange Act of 1934. If the conditions of that proposed safe harbor are satisfied, then a crypto asset would be deemed not to be subject to an investment contract for purposes of those definitions of "security."
2026-12163, The Trade-Through Rule and Locked and Crossed Markets Provisions of Regulation NMS
The SEC wants to scrap some old rules that stop stocks from being traded at worse prices and prevent confusing market quotes. This change affects stock traders and exchanges, aiming to simplify trading and possibly speed things up. If you want to share your thoughts, you’ve got until August 17, 2026, so don’t miss out!
Previous / Next Documents
Previous: 2025-07219, Self-Regulatory Organizations; Fixed Income Clearing Corporation; Order Approving Proposed Rule Change To Adopt a Volatility Event Charge
The Fixed Income Clearing Corporation (FICC) is adding a new fee called the Volatility Event Charge to help manage risks during wild market swings. This change affects members who trade U.S. government and mortgage-backed securities and kicks in during big market ups and downs. The SEC gave the green light in April 2025, so members should be ready for this new charge to keep the system safe and steady.
Next: 2025-07221, Self-Regulatory Organizations; Fixed Income Clearing Corporation; Notice of Filing of Proposed Rule Change To Amend the Recovery and Wind-Down Plan To Satisfy the Requirements of Exchange Act Rule 17ad-26
The Fixed Income Clearing Corporation (FICC) is updating its plan to handle tough times, like big money losses or business troubles, to keep things running smoothly. This change helps FICC follow new rules and protect everyone who depends on its services. The update was filed in April 2025 and aims to make sure FICC can bounce back or close down in an orderly way without causing chaos.