Treasury Clearing Mandate: What Broker-Dealers Need Ready by December 31, 2026

Updated October 2026, two months before the cash clearing deadline. First published February 2024.

The SEC adopted its Treasury clearing rules on December 13, 2023. The first broad deadline is now close: eligible cash Treasury trades must be centrally cleared by December 31, 2026, and eligible repo by June 30, 2027. Both dates were pushed back a year in February 2025. On September 22, 2026, Commissioner Mark Uyeda told a Treasury market conference that "the SEC does not currently intend to extend these deadlines."

One correction to the first version of this post. It said the SEC had extended the customer protection rule to Treasury securities and required firms to segregate customer assets. Rule 15c3-3 already covered customers' Treasury securities. The 2023 change was narrower, and we explain it below.

Which Treasury Trades Must Be Cleared

The rule works through the clearing agencies. Each covered clearing agency that clears Treasuries, such as FICC and, since December 2025, CME Securities Clearing, must require its direct participants to submit these trades for clearing:

• Repos and reverse repos collateralized by Treasuries that a member enters into. Trades with state or local governments, with other clearing organizations, and certain inter-affiliate trades are excluded.
• Purchases and sales of Treasuries by a member that is an interdealer broker.
• Purchases and sales between a member and a registered broker-dealer, government securities broker, or government securities dealer.

Trades with a central bank, a sovereign entity, an international financial institution, or a natural person are exempt. So the question for a broker-dealer that isn't a direct participant is whether its counterparty on a Treasury trade is one, because the participant is the one that has to submit it.

CME Securities Clearing became the second option on December 1, 2025, when the SEC granted its registration as a clearing agency for U.S. Treasury cash and repo trades.

What Already Took Effect in March 2025

Three parts of the rule had a March 31, 2025 compliance date, and the February 2025 extension left the access and Rule 15c3-3 dates in place:

• Clearing agencies must calculate and collect margin for house and customer positions separately.
• Clearing agencies must have policies that give indirect participants appropriate ways to access clearing.
• A broker-dealer may include margin it posts at a Treasury clearing agency for its customers' positions as a debit in the customer reserve formula, subject to conditions. This is the change to Rule 15c3-3.

The debit lets the reserve computation count margin the firm has posted for customers. In August 2025, staff in the Division of Trading and Markets answered a related question in FAQs on Rule 15c3-3a, saying, per Commissioner Uyeda's September 2025 summary, that "it is permissible for broker-dealers to pre-fund, on behalf of their customers, segregated margin with U.S. dollars, in addition to U.S. Treasury securities."

What Changed Between 2024 and October 2026

Volume has already moved. Citing FICC, Commissioner Uyeda said in September 2026 that daily cleared Treasury volumes are about 165% higher than before the SEC proposed the rule.

Still Open as of October 2026

Two scope questions are unresolved. The Institute of International Bankers asked the SEC to exclude transactions executed entirely outside the United States between non-U.S. parties. SIFMA asked the SEC to widen the set of affiliates that can use the inter-affiliate exclusion. The SEC reopened comment on both, with comments due August 31, 2026, and Commissioner Uyeda floated a firm-specific cap on non-cleared, non-U.S. repo as one option. SIFMA has also asked for an exemption that would let broker-dealers calculate customer margin on a net omnibus basis for Rule 15c3-3 purposes.

Staff FAQs address a failed-trade scenario and clearing agency outages, though Commissioner Uyeda's August update still listed the treatment of failed trades as a work item. The SEC keeps the current guidance on its Treasury clearing implementation page, which is the place to check for anything issued after this update.

What to Have Ready

1. Map your Treasury activity by type and counterparty: cash or repo, and whether the other side is a direct participant of FICC or CME Securities Clearing. That tells you which trades your counterparty will have to submit and which you'll clear yourself.
2. Pick an access model and sign the paper. Done-with and done-away arrangements have standard documents now. If you plan to clear through another firm, its onboarding timeline is your real deadline, not December 31.
3. Test the reserve formula. If you'll post margin for customer Treasury positions, run the Rule 15c3-3a debit through the daily reserve computation, which became mandatory for the firms it covers on June 30, 2026, after a six-month extension.
4. Write down how you'll handle a clearing agency outage and a failed trade before you need to. The staff FAQs cover both.
5. Expect an exam question. The SEC's fiscal 2027 examination priorities name the customer protection rule amendments for daily reserve computations and Treasury clearing as a broker-dealer focus. Our post on the SEC's broker-dealer exam priorities covers the rest of the list.

The Treasury clearing rule is one of the few items from the SEC's 2023 agenda that survived the change in leadership largely intact. Our post on what happened to the rest of that agenda covers the others.

This post is for informational purposes only and does not constitute legal advice. For guidance on specific regulatory obligations, consult your counsel or compliance advisor.