FICC Mandates Yearly Wind-Down Plan Testing for Members
Published Date: 12/9/2025
Notice
Summary
The Fixed Income Clearing Corporation (FICC) is updating its rules to require certain members and banks to join in yearly tests of its recovery and wind-down plans. This change helps make sure everyone’s ready if things go wrong, keeping the system safe and sound. The new rules take effect right away, so affected parties should gear up for these important annual drills.
Analyzed Economic Effects
3 provisions identified: 0 benefits, 2 costs, 1 mixed.
Certain Members Must Join Annual RWP Tests
If you are an MBSD or GSD "Member," "Limited Member," or a "Settling Bank," FICC may require you to take part in annual testing of its recovery and wind-down plan at least every 12 months. FICC will designate which participants must join using factors like account structure, affiliated family structure, business model, operational details, and size (trading and settlement activity).
Rule Effective Immediately; Dec 15 Compliance
The rule filing was made on November 25, 2025 and the Commission waived the 30-day delay so the proposed rule change is operative upon filing; the filing also states the proposed rule change would become operative on December 15, 2025 to meet the Rule 17ad-26 compliance date. Affected participants should prepare to meet the annual testing requirements by those dates.
FICC Controls Test Scope and Reporting
FICC will decide the scope of each recovery and wind-down test, set reporting requirements for results, and require designated participants to comply within specified timeframes. FICC will also provide information on participant selection and key elements of the testing to relevant stakeholders.
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