NSCC Requires Members to Test Wind-Down Plans Yearly
Published Date: 12/9/2025
Notice
Summary
The National Securities Clearing Corporation (NSCC) is updating its rules to make sure certain members and banks join in yearly tests of its recovery and wind-down plan. This change helps keep the financial system safe and follows new SEC rules. The updates take effect right away, so those involved should be ready to participate in these important drills without delay.
Analyzed Economic Effects
3 provisions identified: 0 benefits, 2 costs, 1 mixed.
Annual Recovery & Wind-Down Testing Required
NSCC will require certain "Members," "Limited Members," and "Settling Banks" to take part in testing of its Recovery and Wind-down Plan at least once every 12 months, consistent with SEC Rule 17ad-26(a)(8). You (if you are an affected NSCC participant) must be prepared to join annual simulations of NSCC's recovery and orderly wind-down procedures.
NSCC Can Select Who Must Participate
NSCC may designate which Members, Limited Members, and Settling Banks must join annual testing using standards that may consider account structure, affiliated family structure, business model, operational details, and participant size, trading and settlement activity. NSCC may also determine the scope of each test, how results are reported, and require compliance within specified timeframes.
Rule Effective Immediately; Compliance Date
The Commission waived the 30-day operative delay so NSCC's rule change was made operative upon filing (filed November 25, 2025). The filing also states the proposal would be operative by the December 15, 2025 compliance date for SEC Rule 17ad-26, so affected participants should be ready to participate without delay.
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