The U.S. Treasury Market Reforms

The U.S. Treasury market, integral to the U.S. and the global financial system, has evolved significantly over the past decades. Representing a staggering 95% of the U.S. GDP today, compared to just 34% 20 years ago, it underscores the need for robust and effective risk management strategies. For market participants, both seasoned and new, understanding these changes is crucial. Clearing, a key risk mitigation strategy, ensures financial obligations are met, playing a pivotal role in maintaining market integrity and stability.

Origin of the reforms

Historical perspective

Historical incidents, such as the failure of non-bank Treasury dealers in the 1980s, highlighted vulnerabilities in the U.S. Treasury market, necessitating regulatory oversight. It was a wake-up call, leading to the Government Securities Act of 1986, which granted the U.S. Treasury and the Securities and Exchange Commission (SEC) regulatory authority over these markets.

SEC’s role

The SEC's involvement has been crucial in ensuring the market remains efficient, competitive, and resilient. The commission's oversight extends to clearinghouses for Treasury securities, recognising the need to mitigate systemic risk without eliminating it entirely. This background sets the stage for the latest reforms, aimed at strengthening the market's foundation and enhancing its resilience.

Details of the adopted rules

The SEC's reforms, adopted on 13 December 2023, enhance risk management and central clearing in the U.S. Treasury market. These changes include specific requirements for the types of transactions to be cleared, detailed guidelines for margin handling by clearing agencies, and clarified conditions for broker-dealer customer margin accounting. Aimed at bolstering market resilience, these rules mark a significant shift towards greater efficiency and stability, reflecting a focused effort to address the evolving dynamics of the Treasury Market.

From proposal to adoption

Initially proposed on 14 September 2022, these rules underwent thorough scrutiny and public comment before their adoption on December 13, 2023. This period allowed for refinement and clarification, ensuring the final regulations effectively address the complexities of the market.

Key changes from the proposed to the adopted rules focus on:

  • The adopted rules provide specific details on the types of transactions required to be cleared, offering clarity and precision absent in the initial proposal.
  • Detailed guidelines for margin handling by clearing agencies are a notable enhancement, ensuring robust risk management.
  • The final rules offer clear conditions for broker-dealers to count customer margin at clearing agencies, refining the broader outlines of the proposal.

Following these crucial developments, the adopted rules encompass:

  • Mandating the clearing of specific secondary market transactions, including repurchase agreements and trades executed by interdealer brokers.
  • Separating margin calculations for house and customer transactions, ensuring a more robust risk management framework.
  • Amending broker-dealer customer protection rules to include margins on deposit at clearing agencies.

Implementation timeline

The implementation of these rules is phased, reflecting the complex nature of the market and the need for a gradual adjustment. By the end of 2025, the rules concerning the separation of house and customer margin and adjustments to broker-dealer customer protection rules will take effect. The mandatory clearing requirements will follow, with full compliance expected by mid-2026.

Why clearing matters now

Market evolution

The U.S. Treasury market has undergone significant changes, particularly with the advent of electronic trading and the rise of new market participants like principal trading firms and hedge funds. This evolution brings new dynamics and risks, necessitating updated risk management strategies.

Risk management

The increased use of leverage, especially in repurchase agreement transactions, has amplified systemic risks. In this context, central clearing becomes a critical tool for mitigating these risks, ensuring that transactions are settled securely and efficiently, even in times of market stress.

Application of the Rules

Direct impact

The new rules directly impact clearing agencies, specifically the Fixed Income Clearing Corporation (FICC) as the sole clearer of the U.S. Treasury securities, requiring them to adapt their clearing processes to encompass a broader range of transactions. Broker-dealers also face changes in how they manage customer margins, aligning their practices with the new regulatory framework.

Indirect benefits

The broader market stands to benefit from these changes, with increased stability and reduced systemic risks. These reforms are expected to enhance the market’s resilience, particularly during times of stress, contributing to the overall health of the financial system.

Future Outlook

Short-term adjustments

Market participants will need to navigate the immediate changes, aligning their operations with the new requirements. This period will be marked by adaptation and potentially, some challenges as the market adjusts to the new regulatory landscape.

Long-term implications

In the long run, these reforms are anticipated to foster a more stable and efficient U.S. Treasury market. By enhancing the clearing process, the SEC aims to fortify the market against future shocks, ensuring its role as a reliable and robust component of the global financial system.


The SEC's reforms represent a significant milestone in the evolution of the U.S. Treasury market. For participants across both exchange-traded and over-the-counter markets, adapting to these changes is vital. As the market continues to evolve, staying informed and agile will be key to successfully navigating the future.

Get in touch to find out more about Cumulus9.