5: Documentation Considerations for the US Treasury Clearing Rules

The latest episode of TonicBoom! is hosted by Philip Forkan, Tonic’s Head of Collateral, who was joined by Tonic’s head of post-trade, Philip Cook and our legal friends from D2LT Emma Wooldridge and Sydney Hassal.

In this episode, the group addressed the SEC’s recent extension of clearing deadlines and what this could mean for market participants. The new compliance dates set for December 2026 (cash transactions) and June 2027 (repo) seem to give breathing room, but we know that the market is eagerly awaiting done-away trading models and new CCP offerings, which result in massive undertakings across financial firms and market participants who trade in-scope US Treasuries, particularly UST repo. New paper will be required for the ‘new’ clearing methods and CCP offerings.

The podcast teams also addressed:

• The growing need to standardize legal agreements across clearing access models for speed and efficiency
• Lessons Learned from FINRA 4210, and
• Smaller Player Challenges, or challenges for firms without exposure to derivatives markets

Please do give it a listen, and reach out to us at Tonic to discuss your US treasury clearing compliance journey!

00:00 Episode Intro
02:45 Two Truths, One Lie Challenge
09:30 Treasury Clearing Mandate 
16:22 What Should Clients Be Doing Today?
18:00 Start Early and Maintain Momentum
23:46 The Implementation Timeline Iceberg
25:00 Episode Conclusion and Outro