ICE Clear Credit Refines Plans for Handling Market Crises
Published Date: 6/4/2025
Notice
Summary
ICE Clear Credit LLC is updating its Recovery and Wind-Down Plans to better handle big money problems like credit losses or cash shortages. These changes affect everyone involved with ICE Clear Credit and aim to keep things running smoothly or close down in an orderly way if needed. The new rules will kick in soon after SEC approval, helping protect the financial system and participants.
Analyzed Economic Effects
5 provisions identified: 5 benefits, 0 costs, 0 mixed.
Liquid Equity Buffer Requirement in Plans
The Plans, consistent with Rule 17Ad-22(e)(15), include maintaining liquid net assets funded by equity equal to the greater of six months of ICC's current operating expenses or an amount determined by the Board, and require a Board‑approved plan updated at least annually to raise equity if equity falls close to or below the required amount.
Plans Updated to Cite New SEC Rules
ICC updated both its Recovery Plan and Wind-Down Plan to add references and summaries of SEC Rule 17Ad-26 and SEC Rule 17Ad-25 throughout the documents. The amended Plans are stated to be current as of December 31, 2024 and the changes become effective following Commission approval.
Governance Structure Changes at ICC
ICC updated governance in the Plans to reflect several 2024 changes: a new Nominating Committee (minimum of three (3) Board members, a majority meeting independence standards, and one chair), the Risk Committee expanded from twelve (12) to fourteen (14) members with two (2) additional seats reserved for representatives of customers of Clearing Participants, and a new Risk Advisory Working Group (chaired by the Chief Risk Officer with at least two (2) Clearing Participant representatives and two (2) customer representatives). ICC also removed the Advisory Committee and the Risk Management Subcommittee and updated Board manager names and titles.
More Frequent and Inclusive Testing
ICC revised the Plans to clarify that testing of the Recovery Plan and Wind-Down Plan will occur at least every twelve (12) months and will include participation of Clearing Participants and, when practical, other stakeholders. The changes also state testing is in addition to annual default management drills and that ICC will consider including stakeholders in non-default scenario testing.
Stronger Service-Provider Risk Management
The Recovery and Wind-Down Plans were amended to rename 'vendors' to 'service providers', to describe a two‑pronged assessment approach for internal and external service providers for core services (SPCS), and to identify the role of ICC committees (including the BCP and DR Oversight Committee) and staffing roles necessary to support core services during recovery or wind-down.
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