U.S. SECURITIES AND EXCHANGE COMMISSION·RULE 17AD‑22(E)(18)
Answers to the questions we hear most about the SEC's U.S. Treasury Clearing Mandate — compliance dates, scope, exemptions, and eligible collateral. For the full walkthroughs, see the reference guide and the interactive tools.
01 · About USTC
USTC is shorthand for the SEC's U.S. Treasury central clearing mandate under Rule 17Ad‑22(e)(18) — the requirement that covered clearing agencies (CCAs) providing central counterparty services for Treasury securities require their direct participants to submit eligible cash and repo Treasury trades for central clearing, rather than settling them bilaterally.
Yes. The SEC extended the original compliance dates by one year on February 25, 2025, and staff have continued to publish interpretive guidance on scope questions — including basket‑repo treatment and other collateral edge cases — as covered clearing agencies finalize their own rulebooks. See the reference guide for the current state of that guidance.
SEC Rule 17Ad‑22(e)(18) applies to any covered clearing agency (CCA) providing central counterparty services for U.S. Treasury securities. Today that CCA framework spans FICC's Government Securities Division, CME, and ICE.
We advise trading, operations, and compliance teams on USTC readiness — scoping which of your trades are affected, evaluating sponsor, agent, and direct access models, and navigating the SEC's rules and FICC's rulebook changes.
Any firm that trades U.S. Treasury securities on a cash or repo basis — dealers, interdealer brokers, hedge funds, asset managers, and other buy‑side firms — particularly those trading through a CCA direct participant or considering an access‑model arrangement for repo.
Contact AKONCEPT Consulting Americas LLC for tailored support scoping your firm's exposure and access‑model options, or work through the interactive tools below to get a first read on specific trades.
02 · Compliance Dates & Phase‑In
The full roadmap — including the countdown to each phase — lives on the USTC reference guide.
December 31, 2026 for eligible cash Treasury trades (Phase 1), and June 30, 2027 for eligible repo and reverse repo trades (Phase 2). FICC's own rulebook and access‑model changes reached their compliance date on September 30, 2025, ahead of both.
The SEC pushed both original compliance dates back by one year on February 25, 2025, giving the market more runway — particularly for the repo access‑model build‑out. See "Three dates on the path to full clearing" on the reference guide for the complete timeline.
There's no hedge‑fund carve‑out for repo, so most levered repo users need a sponsored, agent, or direct access model in place before June 30, 2027. See "How the two phases differ" on the reference guide for the detail.
03 · Trade Eligibility: Scope & Exemptions
For a determination on a specific trade, walk through the guided walkthrough on the trade flowchart page.
It depends on the instrument, the counterparty, and — for repo — several additional exclusions. Use the guided walkthrough on the trade flowchart page for a determination specific to your trade.
Trades where a counterparty is a central bank, sovereign entity, international financial institution (IFI), or natural person are exempt outright. Repo trades carry additional exclusions for basket (general collateral) repos, CCP/DCO counterparties, and government counterparties.
The outcome after the three common gates means the mandate doesn't apply at all — wrong instrument, exempt counterparty, or a securities loan. The outcomes further down the repo branch are trades that already passed those common gates but qualify for a repo‑specific statutory exclusion instead.
Cash outrights only pass through the three common gates. Repo and reverse repo face those same gates plus four repo‑specific checks — direct participant, basket repo, CCP/DCO or government counterparty, and inter‑affiliate — reflecting the wider range of repo structures and the exemptive relief the SEC has carved out for repo activity specifically.
04 · Eligible Securities & Collateral
The full instrument and collateral scope — plus an interactive scope check — is on the USTC Eligible Securities page.
No. The mandate applies only to U.S. Treasury securities. Municipal bonds, agency debt, agency MBS, corporate bonds, and foreign sovereign debt are different asset classes entirely and fall outside its scope regardless of transaction structure or counterparty.
No. SEC Rule 17ad‑22(a) defines an Eligible Secondary Market Transaction by transaction type and counterparty, not by an enumerated instrument list — it defers the operative instrument‑level detail to the relevant CCA's own rulebook.
Not currently. FICC doesn't presently accept open, intraday, or T+0 same‑day cash trades for clearing, so they remain outside the mandate's scope.
No. The mandate covers repo collateralized specifically by U.S. Treasury securities; repo collateralized by Agency securities or Agency MBS falls outside this particular rule.
Generally not, unless Treasury CUSIPs are present in the basket from the outset rather than added later as a permitted substitution — an area of ongoing interpretive discussion between the industry and the SEC.
No. The SEC has confirmed that securities lending doesn't fall within the definition of an Eligible Secondary Market Transaction, regardless of the instrument involved.
Related USTC pages
AKONCEPT Consulting Americas LLC helps trading, operations, and compliance teams work through USTC readiness — from instrument and collateral scoping to sponsor and custodian model selection.
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