FICC Rolls Out Collateral Swap: Easier Bond Trading Ahead
Published Date: 9/15/2025
Notice
Summary
The Fixed Income Clearing Corporation (FICC) is rolling out a new way for members to use collateral in their Sponsored GC Service and letting sponsoring members clear special "done-away" trades between other parties. This change helps more folks join in and makes clearing smoother, with no big cost changes announced yet. If you’re a member or work with one, get ready for these fresh options coming soon!
Analyzed Economic Effects
7 provisions identified: 4 benefits, 2 costs, 1 mixed.
Possible Clearing Fund Deposit—$1M Minimum
In certain situations FICC may require a Sponsoring Member to post a Sponsored GC CIL Omnibus Account Required Fund Deposit equal to the greater of $1,000,000 and the sum of applicable charges (VaR Charge, Portfolio Differential Charge, and other charges). This requirement applies only where specific conditions are met (e.g., the account records trades for which the GC Funds Borrower is the Sponsoring Member or a Segregated Indirect Participant and that Sponsoring Member has a Segregated Indirect Participants Account).
New CIL Service to Cut “Double Margining”
FICC is creating a Collateral-in-Lieu (CIL) offering that lets a Sponsored Member (a CIL Funds Lender) grant FICC a lien on Purchased GC Repo Securities so FICC can use those securities to settle if the lender or its sponsor defaults. That lien is intended to largely remove the need for FICC to collect initial margin and to reduce the regulatory capital and funding costs Sponsoring Members face when providing access to RICs and other cash providers.
Done-Away Sponsored GC Trades Allowed
FICC will expand the Sponsored GC Service so a Sponsoring Member may submit a “done-away” Sponsored GC Trade (i.e., a repurchase trade between its Sponsored Member and another Netting Member or an indirect participant) for clearing. That change increases the pool of possible counterparties for Sponsored Members and aims to facilitate greater access to FICC clearing and settlement.
No Twice-Daily Funds-Only Payments Required
The CIL Service would not require Sponsored Members to exchange Funds-Only Settlement Amount payments with FICC for Sponsored GC CIL Trades, avoiding the twice-daily funds-only transfer requirement that many RICs and other cash providers cannot operationally support. Instead, Sponsoring Members historically would satisfy and receive such amounts, but the new service removes FICC's need to collect Funds-Only Settlement Amounts for these trades.
Minimum 2% Initial Haircut Requirement
FICC will require a Sponsored GC CIL Trade to have an Initial Haircut no less than 2 percent of the Start Leg Contract Value (the “CIL Required Haircut”), or such other amount FICC determines, and FICC will give Netting Members at least 30 Business Days' notice of changes. This haircut is intended to provide resources to address default or liquidation scenarios where FICC cannot otherwise rely on alternative resources.
Sponsor Liability: Less Guarantee, But Termination Risk
FICC proposes that, generally, a Sponsoring Member would not guarantee the obligations of a Sponsored Member arising under a Sponsored GC CIL Trade (reducing the sponsor's guaranty exposure). However, if a Sponsoring Member exercises its termination rights under Rule 3A Section 16 to close out done-with Sponsored GC CIL Trades, the Sponsoring Member would be responsible for any Sponsored Member Liquidation Amount owed by the CIL Funds Lender.
Submit Joint-Account Trades Before Allocation
Under the CIL Service, a Sponsoring Member may submit Sponsored GC CIL Trades that were executed through a joint trading account even if the investment adviser has not yet completed the allocation among participants. This change addresses timing mismatches where allocations often cannot be completed before FICC's submission deadline and should let more joint-account transactions be cleared.
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: 2025-17728, Self-Regulatory Organizations; NYSE Arca, Inc.; Notice of Filing and Immediate Effectiveness of Proposed Rule Change To Amend the NYSE Arca Equities Fees and Charges
NYSE Arca is changing some fees for certain stock orders to make things simpler and fairer. They’re removing one fee for displayed orders and tweaking how fees for auction-only orders are calculated. These changes start right away and could save some traders money in the first month they trade.
Next: 2025-17730, Self-Regulatory Organizations; Fixed Income Clearing Corporation; Order Approving of Proposed Rule Change To Revise the Definition of the Backtesting Charge
The Fixed Income Clearing Corporation (FICC) updated how it defines the Backtesting Charge, a key part of managing financial risks for U.S. government securities trades. This change affects FICC members by clarifying margin rules to keep the market safe and sound, with no extra costs or delays expected. The Securities and Exchange Commission gave the green light on September 10, 2025, so the new rules are ready to roll.