Non-members are impacted when:

1.  trading cash via interdealer brokers that are CCA  (e.g. FICC) members; and
2. trading repo with any counterparty that is a direct participant of a CCA, unless the entity is specifically exempted. Non-members must ensure appropriate documentation and operational readiness to avoid settlement disruptions by the compliance dates.

Yes, Northern Trust is currently evaluating broadening its repo clearing model to include both Agent Clearing “Done-With” and Agent Clearing “Done-Away”. Adoption of these models will be subject to the conclusion of internal product evaluations and approvals, which will be communicated to clients in due course.

U.S. Treasury Cash (Outright Purchases and Sales): Northern Trust Securities Inc. (NTSI) offers a standard U.S. Treasury cash execution and clearing product. Within this model, NTSI can allocate (or “flip”) post-trade client instructions to their designated custodian or Northern Trust Investment Operations Outsourcing (IOO). Jurisdictional restrictions may apply; clients may contact their Northern Trust representative for more information. U.S. Treasury Repo Clearing: Northern Trust Securities Finance can provide repo clearing through the FICC Sponsored Repo “Done-With” program for entities located in the U.S., Cayman Islands, and Ireland. Northern Trust is also expanding its repo clearing service models into the agent clearing service space. Jurisdictional restrictions apply; clients may contact their Northern Trust representative for more information. Capital Markets FICC-sponsored-repo.

Northern Trust is supporting clients with their compliance obligations by providing best practices and industry insight. Clients are encouraged to confirm clearing applicability directly with their direct participant counterparties. FICC provides a refreshed list of FICC direct participants5. While most direct participants are U.S. entities, some non-U.S. entities are also direct participants.

The SEC U.S. Treasury Clearing regulation applies at trade execution level and is therefore a pre-settlement process. As a result, Northern Trust has assessed there will be no impact to our custody settlement instructions for repo and cash and we will continue processing settlements as received from clients based on existing settlement instruction processes.

• Any purchase or sale transactions or repo or reverse repo transactions between CCA direct participant and a central bank, a sovereign entity, an international financial institution, state government, local government, or a natural person.
  
  
• Any repo or reverse repo transactions in which one counterparty is a CCA providing central counterparty services or a derivative clearing organization or is regulated as a central counterparty in its home jurisdiction.
  
  
• Any repo and reverse repo transactions between direct participant and an affiliated counterparty1, provided that the affiliated counterparty submit for clearance and settlement all other repurchase or reverse repurchase agreements collateralized by U.S. Treasury securities to which the affiliate is a party.

FICC was historically the only CCA for Treasuries and is a subsidiary of the Depository Trust & Clearing Corporation (DTCC).  CME Securities Clearing, Inc. and ICE Clear Credit LLC are now SEC approved CCAs as of December 2025 and February 2026 respectively. ICE Clear Credit LLC’s service is currently live for cash transactions, with repo clearing planned for late 2026.

• Direct participation client types: Dealers, Banks, Interdealer Brokers, Government Securities Issuers, Trust Companies, Futures Commission Merchants, etc.
  
  
• Membership types: Netting Member including Sponsoring Member and Agent Clearing Member.

• Indirect participation client types: Generally used by buy-side firms and various non-US Banking entities.
  
  
• Indirect Participant Types: Sponsored Member (client of the Direct Sponsoring Member), and Executing Firm Customer (client of the Direct Agent Clearing Member).