DTCC Begs SEC: Skip the Paperwork, Keep Matching Trades.
Published Date: 8/31/2026
Notice
Summary
DTCC ITP LLC wants to keep running its trade matching and electronic trade confirmation services without having to register as a clearing agency. This change affects brokers and institutional customers who rely on these services to confirm trades quickly and safely. The SEC is reviewing this request, which could save DTCC ITP time and money while keeping the system smooth and secure.
Analyzed Economic Effects
6 provisions identified: 5 benefits, 1 costs, 0 mixed.
Applicant Says Full Registration Could Raise Fees
DTCC ITP states that requiring the full range of clearing-agency regulation (e.g., registration for CCP or CSD functions) would increase compliance and related costs and "could lead to increased fees to customers." This claim appears in the Application as a rationale for seeking a conditional exemption.
DTCC ITP Will Be Subject to Regulation SCI
DTCC ITP proposes that, if exempted, it will be an 'SCI entity' under Regulation Systems Compliance and Integrity (Regulation SCI), meaning its systems must have sufficient operational and processing capacity, integrity, resiliency, and security to provide allocation, matching, confirmation, and affirmation services. The Application states this requirement explicitly as a proposed condition to the exemption.
Interoperability with Fair, Non‑Discriminatory Access
The proposed exemption conditions require DTCC ITP to maintain an Interface that permits connections to any exempt clearing agency, to process interoperability requests in a timely manner, to set fair, reasonable, and non-discriminatory fees and terms for use of the Interface, and to provide access on a first-in-time priority basis and without performance bias. DTCC ITP also would provide advance notice of material Interface changes.
DTCC ITP to Continue Matching Services
DTCC ITP filed on September 18, 2025, to take over the central trade matching and electronic trade confirmation (ETC) services currently provided by its subsidiary ITPM under the ITPM exemption first granted in 2001. If the Commission grants the requested exemption, DTCC ITP would directly provide the same CTM, TradeSuite ID, and ALERT services to clients such as investment managers, broker-dealers, custodians, and agents without changing their client base or core functionality.
Quarterly Reporting of Fee and Product Changes
DTCC ITP proposes to update the Commission at least quarterly, within 45 calendar days after each quarter, on changes including: changes to its Services Catalog, any introduction, removal, increase, or decrease of Fees, and certain changes to interfaces or client-facing requirements. The Application states the updates will be confidential and will not require Commission approval before implementation.
Applicant Will Not Hold Funds or Bear Credit Risk
DTCC ITP states explicitly that, based on the Client Services it will provide, it will not: bear credit risk or liquidity risk; maintain collateral or hold funds or securities; perform final settlement; perform central securities depository services; or work with security-based swaps. The Application frames these limitations as reasons certain clearing-agency risks do not apply to DTCC ITP.
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