Self-Regulatory Organizations; ICE Clear Credit LLC; Order Approving Proposed Rule Change Relating to the Treasury Clearing Rules and Treasury Clearing Service Treasury Operations Policies and Liquidity Risk Management Framework
Published Date: 7/29/2026
Notice
Summary
No summary available.
Analyzed Economic Effects
10 provisions identified: 7 benefits, 2 costs, 1 mixed.
Hybrid Gross Initial Margin Split (70/30)
For Hybrid Gross IM Accounts, ICC requires clients to provide margin equal to 70% of the Initial Margin requirement and requires the Treasury Participant to provide the remaining 30% under revised Rule 409.
Treasury Guaranty Fund Minimum Cut
ICC lowers the minimum required contribution to the Treasury Guaranty Fund from $20,000,000 to $10,000,000. This change is reflected in Treasury Rule 801(a) and Schedule 401.
Specified Custodial and Investment Loss Reserves
ICC sets explicit amounts available for non-default loss allocation: $20,000,000 for Custodial Loss Resources and $10,000,000 for Investment Loss Resources under Treasury Rule 811 definitions.
Broader Use of Non‑cash Assets in Settlement
In a Settlement Liquidity Event, ICC may borrow or otherwise use non-cash Initial Margin and non-cash Treasury Guaranty Fund contributions for settlement, may borrow such non-cash assets from non-failing participants, and may accept substitution of securities of a specific CUSIP in lieu of cash.
Participant-Controlled Client Close-Outs
ICC will have Treasury Participants manage the close-out of their defaulting clients' positions by default, unless the Treasury Participant elects in writing for ICC to do so; however, a Treasury Participant may not elect ICC to manage close-out for defaults tied to Net Client IM Accounts (see new Rule 316(g)).
Offsetting House and Client Positions in Default
ICC may offset house and client positions against each other in default management where those positions correspond and economically offset, and ICC may permit settlement of open positions in accordance with their terms notwithstanding a default (changes to Chapter 20, including Rule 20-605).
Initial Margin May Include Other Assets
ICC expands the Eligible Margin definition so that Initial Margin may be satisfied with dollars, other currencies, or "other assets," explicitly allowing U.S. Treasury securities to be used to meet Initial Margin under Schedule 401 (change to Rule 401).
Clear Separation of Treasury and CDS Resources
ICC adds a rule (new Rule 312(c)) clarifying that no person has any recourse or claim to any margin, guaranty fund, ICC contribution, or other amount or assets held in connection with ICC's CDS Clearing Business with respect to payment or delivery obligations under the Treasury Rules.
Individual Direct Settlement Account Agreement Requirement
Non-Participant Parties that open an Individual Client Direct Settlement Account with ICC must enter into an agreement with ICC in the form designated by ICC, per the amendments to Rule 2204(c).
Treasury Risk Committee Flexibility Pre‑Launch
Before ICC establishes the Treasury Risk Committee, the Board may designate another committee (the Board Risk Committee) to perform the Treasury Risk Committee's functions, and Rule 503 is revised so the Treasury Risk Committee may consist of up to 14 members (rather than exactly 14) with up to nine participant representatives and up to two client representatives.
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