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DAILY INTELLIGENCE · SETTLEMENT, DEFAULT RESOURCES & EMIR

Trust companies enter DCO settlement as FICC’s fund faces deeper review

CFTC relief removes a barrier between trust-company custody and daily DCO settlement. The SEC opens approval/disapproval proceedings on FICC’s proposed guaranty fund, while the UK makes cross-border intragroup exemptions permanent from January.

Research cut-off 6 Nov · 06:54 CET · historical catch-up distinguished3material changes
Published content frozen

The 2 November FCA policy is a newly indexed historical omission. No-action relief, approval proceedings and permanent exemptions remain distinct from collateral approval, final SEC approval and realised client effects.

EXECUTIVE TAKEAWAYS

  1. 01Trust-company settlement ↓

    Treat trust-company settlement as a controlled DCO option, not as approval of stablecoin collateral or evidence of live use.

  2. 02FICC fund review ↓

    Rework FICC fund scenarios around a longer approval path and the SEC’s credit, liquidity, access, competition and disclosure questions.

  3. 03UK intragroup regime ↓

    Preserve valid UK intragroup exemptions, route new cases through the 5 December transition gate and prepare Connect controls for 1 January.

Action radar

NEW · NO-ACTION RELIEF01

Clearing · INT-2026-078 · 76/100 · CFTC 5 NOV 2026

CFTC permits trust companies in DCO daily settlement workflows

DCR will not recommend enforcement against a DCO using a trust company for daily settlement if settlement-bank controls are applied. INT-2026-078 scores 76/100.

PRIMARY SOURCECFTC — Letter 26-30 ↗PRIMARY SOURCECFTC — Nodal Clear request ↗

Why it matters

FACT · DCOs retain documented selection criteria, ongoing monitoring, exposure controls and legally final transfers. Nodal Clear’s request links the relief to planned stablecoin initial margin, but the letter approves neither a collateral asset nor production use.

Likely business impact

GDI ANALYSIS · Separate legal permission from eligible-collateral approval. Map custody, finality, concentration, liquidity, capital, segregation, default access and recovery before adding a trust company to DCO or clearing-member workflows.

What to watch

  • First DCO and trust-company production use
  • Collateral eligibility, haircuts and account treatment
  • Settlement finality, concentration and recovery evidence
MATERIALLY CHANGED · PROCEEDINGS OPEN02

Clearing · INT-2026-007 · 85/100 · SEC 5 NOV 2026

SEC opens approval proceedings on FICC’s GSD guaranty fund

The SEC opened approval/disapproval proceedings instead of deciding by the prior 9 November boundary. INT-2026-007 remains 85/100.

PRIMARY SOURCESEC — FICC guaranty-fund proceedings ↗

Why it matters

FACT · The SEC asks whether the cash-funded Cover 2 structure, intramonth resizing, additional margin, loss allocation and liquidity changes satisfy credit, liquidity, access, competition and disclosure requirements. Comments and rebuttals fall 21 and 35 days after Federal Register publication.

Likely business impact

GDI ANALYSIS · Keep the fund out of baseline pricing until approved. Re-run member funding, assessment-cap, liquidity-replacement and client-pricing scenarios, and test whether access and cost disclosures are decision-useful.

What to watch

  • Federal Register publication and comment dates
  • FICC and industry evidence on member funding and access
  • Approval, amendment, withdrawal or disapproval
HISTORICAL CATCH-UP · FINAL POLICY03

Regulation · INT-2026-079 · 74/100 · FCA 2 NOV 2026

UK makes intragroup clearing and margin exemptions permanent

PS26/21 implements a permanent UK EMIR intragroup regime from 1 January 2027 and preserves valid existing exemptions. INT-2026-079 scores 74/100.

PRIMARY SOURCEFCA — PS26/21 ↗PRIMARY SOURCEFCA — Notifications and exemptions ↗

Why it matters

FACT · New overseas exemptions no longer depend on equivalence; margin and clearing notifications move to Connect and the margin review period falls from three months to 30 days. The FCA recommends current-process submissions by 5 December for completion before year-end.

Likely business impact

GDI ANALYSIS · Inventory exemption evidence and material-change controls, triage December applications, and test Connect entitlements, data lineage and approval ownership. Permanent treatment reduces cliff risk but not the need to evidence consolidation and centralised risk control.

What to watch

  • 5 December transition gate
  • Connect form and entitlement readiness
  • First permanent exemptions and supervisory findings

Urgent open matters

Eurex 7–9 November cutoversUNCHANGED SINCE 2 NOVEMBERNEXT TRIGGERConnection-test and production evidence →OCC Rule 213UNCHANGED SINCE 26 OCTOBERNEXT TRIGGER13 November comments and final rule →FICC guaranty fundPROCEEDINGS OPEN SINCE 5 NOVEMBERNEXT TRIGGERFederal Register comment and rebuttal dates →