Treasury Margin Math Gets a Special Broker-Dealer Exception
Published Date: 11/9/2026
Notice
Summary
The SEC is giving broker-dealers a special pass to handle margin calculations for U.S. Treasury trades cleared through certain agencies more flexibly. This means they can count margin held on a net or omnibus basis even if the clearing agency calculates it differently, making the process smoother and less costly. This change helps keep the market running efficiently without risking investor protection, starting right away.
Analyzed Economic Effects
3 provisions identified: 2 benefits, 1 costs, 0 mixed.
Net/Omnibus Margining Allowed for Treasuries
Broker-dealers are allowed to include a debit in their Rule 15c3-3a reserve computations for customer margin tied to U.S. Treasury trades even when they deliver margin on a net, omnibus basis rather than on a gross, customer-by-customer basis. The relief applies where the qualified clearing agency has calculated margin on a net, omnibus or gross basis, and is limited to cleared, settled, and novated purchases/sales of U.S. Treasury securities and Treasury repurchase and reverse repurchase agreements. The exemption is subject to seven conditions (e.g., collateral must be cash, U.S. Treasury securities, or qualified customer securities; the Item 15 debit is limited to the 'least of' three specified amounts; and clearing-agency rule changes and books/records and procedures are required).
Supports Access for Smaller/Indirect Participants
The Commission found the exemption will help broker-dealers avoid costly, highly granular gross customer-level margin systems that could discourage onboarding of smaller or indirect market participants (including buy-side clients). The order states the relief should alleviate capital and operational constraints, support broader market access, and help preserve liquidity in the U.S. Treasury market.
Compliance Conditions and Limits Imposed
Broker-dealers may use the exemption only if they meet seven specified conditions, including: (1) relief limited to purchases/sales and repo/reverse-repo in U.S. Treasuries that are cleared, settled, and novated; (2) collateral delivered may be only cash, U.S. Treasury securities, or qualified customer securities; (3) the Item 15 debit included in reserves must equal the least of three amounts (margin collected from customers; margin required; or collateral delivered); (4) maintain books and records to identify margin collected and delivered; and (5) qualified clearing-agency rulebook amendments plus written policies/procedures are required.
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