FICC Overhauls Wind-Down Rules for Market Protection
Published Date: 4/28/2025
Notice
Summary
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.
Analyzed Economic Effects
4 provisions identified: 3 benefits, 1 costs, 0 mixed.
Keeps FICC Services Running if Trouble Hits
If you are an FICC Member, the amended Recovery & Wind-Down Plan is designed to help Members maintain access to FICC's core services by enabling the transfer of FICC membership to a Transferee if FICC defaults or the Board triggers the Wind-down Plan. The proposed changes are to take effect by the Rule 17ad-26 compliance date on December 15, 2025.
Secures Third-Party Service Contracts in Stress
FICC will review written agreements with third-party service providers and seek to amend intercompany agreements so service providers (including DTCC-affiliated providers) will continue performing in a recovery or orderly wind-down. This effort is tied to compliance with Rule 17ad-26 and the compliance date of December 15, 2025.
Plans to Keep Key Staff During Crises
FICC will identify staffing roles needed to support its core services (Attachment A-1) and analyze retention challenges (Attachment A-2). The Plan explicitly lists retention tools such as succession planning, retention agreements, and cross-training to help keep critical staff during a recovery or orderly wind-down, with changes effective by December 15, 2025.
Annual Tests and Member Simulation Participation
FICC will test its ability to implement the Recovery & Wind-Down Plan at least every 12 months and will require certain Members to participate in simulations; Member selection criteria may include account structure, affiliated family structure, business model, operational details, and Member size. These testing procedures are part of the Rule 17ad-26 compliance work to be in place by December 15, 2025.
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