ICE Clear Credit wants senior officers to certify annually that Treasury participants have met their trade-submission obligations and maintain controls to detect failures. The SEC published the proposal on November 5; the procedures require approval before taking effect.[1]
The underlying obligation is already set out in Treasury Rule 303. From the applicable compliance date, participants must promptly submit transactions that meet both tests: eligibility for clearing under ICE’s rules and classification as eligible secondary-market transactions under SEC rules. They may send those trades to ICE or another covered clearing agency.[2]
That second route is important for firms using more than one clearinghouse. Rule 303 does not require every qualifying transaction to go through ICE, and its monitoring provision permits ICE to require evidence of compliance. Choosing another eligible clearing venue does not remove the participant’s obligation to demonstrate that submission happened.[2]
Under the proposal, a firm would promptly notify ICE in writing within 30 calendar days of learning of non-compliance, setting out its duration and remediation. An annual senior-officer attestation would cover the preceding 12 months. ICE would give at least 30 calendar days’ notice of its submission deadline.[1]
Reviews could examine submissions to other clearing agencies, rejections, retries and timing. An internal record of sending a trade may therefore leave its eventual resolution unexplained.[1]
The SEC’s implementation timetable sets December 31, 2026 for eligible cash-market transactions and June 30, 2027 for eligible repos. The agency extended the original dates by a year. These are separate deadlines for the two transaction classes, rather than one start date for all Treasury activity.[3]
The reporting clock would run from discovery of non-compliance. It would not give a participant 30 days to submit a trade that Rule 303 requires to be submitted promptly after execution.[1][2]
Sources & further reading
- SR-ICC-2026-014: Treasury submission monitoring procedures US Securities and Exchange Commission / ICE Clear Credit · 5 Nov 2026 · Accessed 6 Nov 2026
- Treasury Clearing Rules, revised July 27, 2026 ICE Clear Credit · 27 Jul 2026 · Accessed 6 Nov 2026
- Treasury clearing implementation: compliance dates US Securities and Exchange Commission · Accessed 6 Nov 2026