2026-22026NoticeWallet

SEC Approves a Clearinghouse's Recovery and Wind-Down Plans

Published Date: 10/29/2026

Notice

Summary

ICE Clear Credit LLC updated its Recovery and Wind-Down Plans to handle recent changes and support its new U.S. Treasury clearing service. These plans help the company stay strong during tough times and safely close or transfer services if needed. The SEC gave the green light in October 2026, so these updates are official and ready to protect everyone involved.

Analyzed Economic Effects

5 provisions identified: 5 benefits, 0 costs, 0 mixed.

Separate loss pools for CDS vs. Treasury

ICC's updated Plans state that the CDS clearing service and the Treasury clearing service maintain separate financial resources. The Recovery Plan explicitly says the CDS General Guaranty Fund and CDS margin assets will not be used to cover losses from a default in the Treasury clearing service, and vice versa, with the Plans current as of March 6, 2026.

Treasury clearing service added to recovery/wind-down plans

ICC amended both the Recovery Plan and Wind-Down Plan to incorporate the U.S. Treasury clearing service throughout the documents and to distinguish between the Treasury and CDS clearing services. The Plans note they are current as of March 6, 2026 and include a footnote that the Treasury clearing service has not yet launched.

Stronger board-level risk oversight

ICC added a board-level Board Risk Committee to the governance charts and revised the annual review process so material amendments and annual reviews of the Plans are presented to the Board Risk Committee, which will recommend approval to the Board. The Plans also specify that testing results will be provided to the Board Risk Committee and Treasury Risk Committee as well as existing committees.

Membership qualification language aligned

ICC revised Recovery Plan language to align with CDS Rule 201(c) and Treasury Rule 201(c) by replacing 'must' with 'may' when listing categories of entities that may qualify as Clearing Participants and Treasury Participants. The Treasury participant list includes registered broker-dealer, registered investment company, bank, insurance company, futures commission merchant, registered clearing agency, or other entities as designated by the SEC.

Staffing and operations continuity preserved

ICC's Plans state that, in general, staff in a functional area provide support for all cleared products and markets and that personnel are not split between the CDS and Treasury clearing services. ICC also states it is likely that a recovery in one clearing service would not trigger a significant reduction in ICC's employee headcount because the other clearing service would continue business-as-usual operations.

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Key Dates

Effective Date
Published Date
10/26/2026
10/29/2026

Department and Agencies

Department
Independent Agency
Agency
Securities and Exchange Commission
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