Swap Dealers Get a Bigger Sandbox, But Only If
Published Date: 11/2/2026
Notice
Summary
The SEC is thinking about doubling the limit for certain swap dealers’ activities from $50 billion to $100 billion. This change affects security-based swap dealers who also register as swap dealers but have smaller swap businesses. If approved, it could make compliance easier and more flexible, and the SEC wants your feedback before deciding.
Analyzed Economic Effects
4 provisions identified: 3 benefits, 0 costs, 1 mixed.
Possible Raise of ACM Threshold to $100B
The SEC is considering raising the maximum fixed-dollar threshold in Rule 18a-10 from $50,000,000,000 to $100,000,000,000 for security-based swap dealers (SBSDs) that are also registered as swap dealers. The Commission published this notice on October 28, 2026 and is soliciting comments through December 2, 2026 about whether to make that change.
Less Duplicate Compliance for Eligible Firms
If the maximum fixed-dollar amount is raised to $100,000,000,000, firms eligible for Rule 18a-10 could avoid duplicative capital, margin, and segregation calculations under both SEC and CFTC regimes. The notice states that such relief would spare firms the cost and inefficiency of maintaining duplicate calculations and reduce burdens on the firms and the Commission.
Potential Small Market Effect on SBS Markets
The SEC and the requester (Mizuho Capital Markets LLC) state that raising the threshold to $100,000,000,000 would likely have only a small impact on the security-based swap (SBS) market and broader securities markets. The Commission is asking commenters to explain how significant SBSDs using the ACM could be to the SBS market if the threshold is increased.
Who Can Use the Alternative Compliance Mechanism
To use Rule 18a-10's alternative compliance mechanism, a firm must be registered as a security-based swap dealer (SBSD) under the Exchange Act, registered as a swap dealer under the Commodity Exchange Act, not be registered as a broker or dealer under the Exchange Act, and have aggregate gross notional outstanding SBS positions that do not exceed the lesser of the maximum fixed-dollar amount or 10% of the firm's combined SBS and swap positions. The current maximum fixed-dollar amount is $50,000,000,000 but the SEC is considering changing it to $100,000,000,000.
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