# SECURITIES AND EXCHANGE COMMISSION

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URL: https://www.frixlaw.com/law-library/documents/agency%3Asec%3Ad01eb39cfe91dc84

## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-106308; File No. SR-ICC-2026-009]
Self-Regulatory Organizations; ICE Clear Credit LLC; Notice of Filing of Proposed
Rule Change Relating to the ICE Clear Credit Recovery Plan and ICE Clear Credit
Wind-Down Plan
September 9, 2026.
Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934 (“Securities
Exchange Act” or the “Act”), 15 U.S.C. 78s(b)(1), and Rule 19b-4 thereunder, 17 CFR
240.19b-4, notice is hereby given that on August 27, 2026, ICE Clear Credit LLC (“ICC”
or “ICE Clear Credit”) filed with the Securities and Exchange Commission (“SEC” or
“Commission”) the proposed rule change, as described in Items I, II and III below, which
Items have been prepared primarily by ICC. The Commission is publishing this notice to
solicit comments on the proposed rule change from interested persons.
I.

Clearing Agency’s Statement of the Terms of Substance of the Proposed Rule
Change
The principal purpose of the proposed rule change is to revise the ICC Recovery

Plan (the “Recovery Plan”) and the ICC Wind-Down Plan (the “Wind-Down Plan”)
(collectively, the “Plans”). These revisions do not require any changes to the ICC CDS
Clearing Rules 1 (the “CDS Rules”) and to the ICC Treasury Clearing Rules 2 (“Treasury
Rules”) (collectively, the “Rules”). 3

1

A copy of the ICC CDS Clearing Rules can be found here:
https://www.ice.com/publicdocs/clear_credit/ICE_Clear_Credit_Rules.pdf.

2

A copy of the ICC Treasury Clearing Rules can be found here:
https://www.ice.com/publicdocs/clear_credit/ICE_Clear_Credit_Treasury_Clearing_Rules.pdf.

3

Capitalized terms used but not defined herein have the meanings specified in the Rules.

II.

Clearing Agency’s Statement of the Purpose of, and Statutory Basis for, the
Proposed Rule Change
In its filing with the Commission, ICC included statements concerning the

purpose of and basis for the proposed rule change, security-based swap submission, or
advance notice and discussed any comments it received on the proposed rule change,
security-based swap submission, or advance notice. The text of these statements may be
examined at the places specified in Item IV below. ICC has prepared summaries, set forth
in sections (A), (B), and (C) below, of the most significant aspects of these statements.
(A)

Clearing Agency’s Statement of the Purpose of, and Statutory Basis for,
the Proposed Rule Change
(a)

Purpose

ICC proposes revising the Recovery Plan and the Wind-Down Plan, which serve
as plans for the recovery and orderly wind-down of ICC necessitated by credit losses,
liquidity shortfalls, losses from general business risk, or any other losses, consistent with
Securities and Exchange Commission (“SEC” or the “Commission”) Rule 17ad22(e)(3)(ii)4 and SEC Rule 17ad-26.5 ICC proposes to make such changes effective
following Commission approval of the proposed rule change. The proposed amendments
reflect changes that impacted ICC in the past year, including the planned expansion of
ICC’s clearing services to encompass U.S. Treasury (“UST” or “Treasury”) securities as
part of the new Treasury clearing service, 6 as well as additional updates and edits to the

4

See 17 CFR 240.17ad-22(e)(3)(ii).

5

See 17 CFR 240.17ad-26.

6

ICC filed an application on Form CA-1 (“Application”) under Section 17A of the Securities
Exchange Act of 1934 (the “Act”) (15 U.S.C. 78q–1) with the Commission to register as a
clearing agency to provide central counterparty services for transactions involving UST securities
on August 1, 2025. Notice of ICC’s Application was published in the Federal Register on August
21, 2025. See Securities Exchange Act Release No. 103727 (August 18, 2025), 90 FR 40879
(August 21, 2025) (File No. 600-45). The Commission issued an order granting ICC’s Application

2

Plans intended to promote clarity, streamline, and to ensure that the information provided
is current. The proposed rule change is described in detail as follows.
I.

ICC Recovery Plan

Consistent with the regulations applicable to ICC, the Recovery Plan is designed
to establish ICC’s actions to maintain its viability as a going concern to address any
uncovered credit loss, liquidity shortfall, capital inadequacy, or business, operational or
other structural weakness that threatens ICC’s viability. The purpose of the Recovery
Plan is to describe the actions and steps that would be taken to: (i) restore ICC to a stable
and sustainable condition in the event that it came under severe stress; and (ii) maintain
effective arrangements for ensuring losses that threaten ICC’s viability as a going
concern are allocated. As noted above, the proposed amendments reflect and relate to
changes that impacted ICC, including the expansion of ICC’s clearing services to
encompass UST securities, as well as general updates and edits to the Plans intended to
promote clarity, streamline, and to ensure that the information provided is current.
ICC proposes to amend Section I. ICC proposes updating the terminology used to
reference its members throughout the Recovery Plan to distinguish between the existing
CDS clearing service and the new Treasury clearing service. ICC proposes to clarify that
ICC Clearing Participants (“Clearing Participants” or “CPs”) refer to members in the
CDS clearing service and ICC Treasury Participants (“Treasury Participants” or “TPs”)
refer to members in the Treasury clearing service. 7 ICC proposes related changes

for registration as a clearing agency to provide central counterparty services for transactions
involving Treasury securities on January 30, 2026. See Securities Exchange Act Release No.
104762 (January 30, 2026), 91 FR 5528 (February 6, 2026) (File No. 600-45).
7

Such terminology is consistent with the CDS Rules and Treasury Rules.

3

throughout the document to update terminology to distinguish between the existing CDS
clearing service and the new Treasury clearing service, including, among others,
references to the CDS Rules versus the Treasury Rules. Additionally, in Section I. and
throughout the document, the proposed changes specify that the information provided in
the amended Recovery Plan is current as of March 6, 2026, unless otherwise stated.
ICC proposes to amend Section II. ICC proposes to include background on
the launch of ICC as a CDS clearinghouse. 8 This additional context is intended to
distinguish ICC’s existing CDS clearing activities and approvals from its planned
Treasury clearing activities and recent approval to provide clearing services for Treasury
securities.9 ICC proposes language regarding this recent approval to offer central
counterparty clearing and settlement services to the Treasury market. ICC proposes a
footnote to acknowledge that the Treasury clearing service is not yet launched. The
footnote is intended to provide transparency and clarity, as the Recovery Plan
incorporates Treasury clearing service-specific information that is based on the
anticipated launch of the service. While the Treasury clearing service has not yet
launched, and ICC proposes the additional footnote noting so, ICC would include
available information pertaining to the Treasury clearing service throughout the Recovery
Plan, in accordance with ICC’s approved Treasury Rules and approved Treasury clearing
service policies and procedures.10 Moreover, currently, the Recovery Plan sets out ICC’s

8

Additional information is publicly available in ICC’s Disclosure Framework at
https://www.ice.com/publicdocs/clear_credit/ICEClearCredit_DisclosureFramework.pdf.

9

See Securities Exchange Act Release No. 104762 (January 30, 2026), 91 FR 5528 (February 6,
2026) (File No. 600-45) (Commission order granting ICC’s Application for registration as a
clearing agency to provide central counterparty services for transactions involving Treasury
securities).

10

Id.

4

sole critical operation as its CDS clearing services, which ICC proposes to expand more
generally to “clearing services” to consider the Treasury clearing service in Section II.
and throughout the Recovery Plan. ICC proposes to update terminology to distinguish
between the existing CDS clearing service and the new Treasury clearing service,
including references to the CDS clearing service General Guaranty Fund versus the
Treasury clearing service Treasury Guaranty Fund. 11 ICC proposes additional changes
to outline ICC’s role as a central counterparty for the Treasury clearing service in this
section and throughout the document.
ICC proposes changes to Section III. ICC proposes to remove references to
certain regulatory guidance that has been withdrawn. 12 While such guidance has been
withdrawn, ICC continues to consider the principles underlying that guidance in its
recovery planning and, accordingly, proposes to replace references to such guidance with
references to industry best practices.
ICC proposes changes to Section IV. ICC proposes a clean-up change in
describing CDS Rule 201(c) which sets out the types of entities that may qualify as
Clearing Participants. The current Recovery Plan language states that an entity “must be
one of the following” to qualify as a Clearing Participant. As amended, the language
would state that an entity “may be one of the following” to qualify as a Clearing
Participant in order to be consistent with the current language of CDS Rule 201(c). 13 ICC

11

See supra note 7.

12

See Commodity Futures Trading Commission, Press Release No. 9120-25 (September 11, 2025),
available at https://www.cftc.gov/PressRoom/PressReleases/9120-25 (noting “the guidance is
duplicative and not necessary”).

13

See CDS Rule 201(c), which states, in relevant part, that “the following categories of persons may
be approved by ICE Clear Credit as Participants”.

5

proposes to incorporate information regarding participation in the Treasury clearing
service in accordance with its Treasury Rules. For example, ICC would incorporate
reference to Treasury Rule 201(c), stating that to qualify as a Treasury Participant for the
Treasury clearing service, an entity may be one of the following: registered broker-dealer,
registered investment company, bank, insurance company, futures commission merchant,
registered clearing agency, or an entity which may not fall within the above categories, as
designated appropriate by the SEC. 14 Such changes are consistent with those approved in
SR-ICC-2026-002 and ICC proposes a footnote in the Recovery Plan to indicate that they
are more recent.
ICC proposes additional changes in Section IV., including regarding operational
capacity, financial responsibility and capital requirements, funding requirements, and
collateral management. Such changes generally incorporate reference to the Treasury
clearing service and distinguish between the Treasury clearing service and CDS clearing
service in accordance with the CDS and Treasury Rules. With respect to financial
responsibility and capital requirements, ICC proposes to outline that CDS and Treasury
clearing services operate separately in terms of financial resources. The CDS clearing
service maintains a separate General Guaranty Fund and calls for and holds margin
payments from Clearing Participants independently of margin payments called for in
connection with the Treasury clearing service. Regarding funding requirements, ICC
proposes to specify acceptable forms of collateral for Initial Margin and Treasury

14

Such changes are consistent with a recent ICC rule filing, SR-ICC-2026-002. ICC would include a
footnote in the Recovery Plan to indicate that these changes are more recent. See Securities
Exchange Act Release No. 105986 (July 24, 2026), 91 FR 47864 (July 29, 2026) (File No. SRICC-2026-002) (approving changes to clarify that futures commission merchants and registered
clearing agencies that meet the participation standards in Treasury Rule 201(b) may also be
approved as Treasury Participants).

6

Guaranty Fund contributions for the Treasury clearing service in accordance with
Treasury Rule 401 and Schedule 401 to the Treasury Rules. With respect to collateral
management, ICC proposes to specify that the Treasury clearing service determines its
liquidity needs separately from the CDS clearing service and maintains separate liquidity
resources. ICC also proposes to include the ICC eligible collateral for the Treasury
clearing service as of March 6, 2026 in accordance with Treasury Rule 401 and Schedule
401 to the Treasury Rules. ICC further proposes to update references throughout the
Recovery Plan to distinguish ICC CDS Rules and ICC Treasury Rules.
ICC proposes additional changes in Section IV. with respect to governance
structure. ICC proposes to update the Recovery Plan to reflect that ICC has a board-level
Board Risk Committee.15 With the addition of the Board Risk Committee, ICC proposes
to update the governance chart in this section to include the Board Risk Committee and to
include a new subsection describing the role and responsibilities of the Board Risk
Committee. ICC also proposes to incorporate certain Treasury clearing service-specific
committees and groups in this governance chart and include language describing their
roles and responsibilities. ICC proposes a footnote explaining that such Treasury clearing
service-specific working groups and committees have not yet been formed and may be
convened at the direction of ICC management in connection with the launch of the
Treasury clearing service. These groups and committees would include the Treasury Risk

15

ICC previously filed a proposed rule change to establish the Board Risk Committee. See Securities
Exchange Act Release No. 103161 (May 30, 2025), 90 FR 23970 (June 5, 2025) (File No. SR-ICC2025-006).

7

Committee,16 Treasury Operations Working Group, 17 and the Treasury Risk Working
Group.18,19 ICC also proposes to add language describing the Specified Actions (as
defined in ICC Treasury Rule 502) that require prior consultation with the Treasury Risk
Committee, including certain matters relating to the acceptance for clearing of Treasury
transactions, modifications to the ICC Treasury Rules relating to margin and the Treasury
Guaranty Fund, as well as certain recovery-related matters such as commencing reduced
gain distribution or implementing full clearing service termination. In connection with
these governance changes, ICC proposes related changes to update terminology
throughout the Recovery Plan to distinguish between the existing CDS clearing service
and the new Treasury clearing service, including references to the CDS Risk Committee
versus the Treasury Risk Committee. ICC further proposes a clarifying edit to provide
that a majority of each Risk Committee constitutes a quorum for doing business to ensure
consistency with the CDS and Treasury Rules. 20

16

The description of the Treasury Risk Committee included in the Recovery Plan is intended to align
with the corresponding provisions set forth in the Treasury Rules. See Chapter 5 of the Treasury
Rules for additional information regarding the role and responsibilities of the Treasury Risk
Committee.

17

The Treasury Operations Working Group would be composed of Treasury Participant operations
personnel, and the Treasury Operations Working Group would review and provide feedback
regarding various operational initiatives in connection with the Treasury clearing service. All
Treasury Participants would be invited to participate in the Treasury Operations Working Group.
In general, this structure is similar to that of the CDS Operations Working Group for the CDS
clearing service.

18

The Treasury Risk Working Group would be composed of Treasury Participant risk personnel and
would provide input to the ICC Risk Department and ICC management as well as the Treasury
Risk Committee to help ensure ICC’s risk management framework in connection with the
Treasury clearing service is robust and that it correctly and equitably charges each Treasury
Participant for the amount and type of risk they introduce to the clearing house. In general, this
structure is similar to that of the CDS Risk Working Group for the CDS clearing service.

19

For clarity, ICC proposes to apply a CDS or Treasury prefix to certain committees and working
groups to indicate the applicable clearing service.

20

See CDS and Treasury Rule 505.

8

ICC proposes additional changes in Section IV. to reflect changes impacting ICC
within the past year. Consistent with previously approved changes to the CDS Rules and
CDS default management procedures, ICC proposes to remove references to “direct
liquidation” as a hedging and liquidation mechanism in the context of managing a
defaulting CP’s portfolio.21 Additionally, ICC proposes to update titles and committee
memberships to reflect current committee composition.
ICC proposes amendments to Section V. With respect to the list of critical
services provided to ICC by affiliates, ICC proposes to update the relevant agreement
governing those services. 22 ICC proposes updates to include the core services for the
Treasury clearing service, consistent with the identification of such core services for the
CDS clearing service. These core services include acceptance of new trades, management
of positions, production of risk and banking reports, and movement of funds. ICC also
proposes to amend its staffing considerations regarding the roles necessary to support the
core services on a daily basis and in the event of recovery. ICC proposes to specify that,
in general, all staff in a functional area provide support for all cleared products and
markets at ICC and personnel are not split between the CDS and Treasury clearing
services.
ICC proposes amendments to Section VII. As required by CFTC and SEC
regulations,23 ICC would continue to identify scenarios that may potentially prevent ICC

21

See Securities Exchange Act Release No. 103601 (July 31, 2025), 90 FR 37612 (August 5, 2025)
(File No. SR-ICC-2025-010) (approving changes to ICC’s Clearing Participant Default
Management Procedures and CDS Rules).

22

See Securities Exchange Act Release No. 105918 (July 15, 2026), 91 FR 45306 (July 20, 2026)
(File No. SR-ICC-2026-004) (approving changes reflecting a new agreement executed by ICC).

23

CFTC Regulation 17 CFR 39.39(c)(1) and SEC Rules 17 CFR 240.17ad-22(e)(4), 17 CFR
240.17ad-22(e)(15)(i) and 17 CFR 240.17ad-26(a)(3).

9

from being able to meet its obligations, provide its critical operations and services as a
going concern. With respect to such stress scenarios, ICC proposes changes to
incorporate reference to the Treasury clearing service and distinguish between the
Treasury clearing service and CDS clearing service where appropriate. ICC proposes to
clarify that whether a member is in default in each clearing service will be determined
independently under the rules of each clearing service, except as follows. Specifically,
should a common member default in a single clearing service, such event will not
automatically lead to a default declaration of such common member in the other ICC
clearing service. However, the fact the common member has defaulted in a single
clearing service could lead to the determination that such common member is, in the
judgement of ICC, likely to fail to meet any of its obligations to the other clearing
service, which could be a basis for declaring such common member in default in the other
clearing service. ICC further proposes minor changes to ICC’s existing monitoring
mechanisms to include Treasury Participants. ICC proposes certain clarifying edits to
remove modifiers from and add a parenthetical to the list of monitored metrics, which
currently applies to the CDS clearing service. Such changes are intended to update and
streamline the description such that it applies to both clearing services. For the avoidance
of doubt, such changes do not amend ICC’s existing practices for the CDS clearing
service and maintain consistency with existing policies and procedures.
Furthermore, ICC proposes to amend Section VIII. which describes the recovery
tools available to ICC in the event of a stress scenario. With respect to such recovery
tools, ICC proposes changes to incorporate reference to the Treasury clearing service and
distinguish between the Treasury clearing service and CDS clearing service where

10

appropriate. ICC proposes to clarify that the use of these recovery tools is done separately
under the rules of each clearing service. ICC further proposes to clarify that as each of the
CDS and Treasury clearing services are designed to be independent with their own
separate rulebooks, memberships and default resources, ICC does not expect that a
recovery caused by a participant default in one clearing service will cross over to cause a
recovery scenario in the other service. This design is intended to minimize the financial
risks posed by the Treasury clearing service to the CDS clearing service and vice versa.
Consistent with the separate rulebooks for the two clearing services, ICC proposes to
further specify that the CDS General Guaranty Fund and CDS margin assets will not be
used to cover losses from a default in the Treasury clearing service, or vice versa.
Additionally, ICC proposes amendments to its description of the tools available to
address credit losses in a participant default scenario. For example, ICC proposes to
specify that, for the Treasury clearing service, these tools generally include: (i)
declaration of a TP default; (ii) communicating the default; and (iii) conducting default
management actions to eliminate, settle, reduce, or replace the risk of the defaulter’s open
Treasury positions. ICC also proposes to add a subsection describing its ability under
existing Treasury Rule 20-605(d)(v) to run one or more default auctions to address credit
losses in a participant default scenario in the Treasury clearing service. 24 With respect to
financial resources, ICC proposes to include its financial resources hierarchy for the

24

See Treasury Rule 20-605(d)(v) (“to enter into Trades or other transactions that replace or mitigate
the risk of all or part of the Open Treasury Positions of the Defaulting Treasury Participant,
liquidate securities held as collateral or received in settlement from or for the account of the
Defaulting Treasury Participant and replace or liquidate any Initial Cover Transactions… Such
Trades or transactions may be entered into pursuant to (i) one or more Default Auctions conducted
pursuant to the Default Auction Procedures”). Additional detail is forthcoming in the Treasury
Clearing Service Default Auction Procedures.

11

Treasury clearing service, in the order of consumption. ICC also proposes changes to
include a description of ICC’s Treasury Guaranty Fund, consistent with Treasury Rule
801. ICC proposes changes to specify which recovery tools are applicable to the CDS
clearing service and/or the Treasury clearing service in accordance with the CDS and
Treasury Rules. ICC also proposes clean-up changes to its overview of initial default
auctions for the CDS clearing service. Such changes include updating examples to align
with those included in the current version of the Default Auction Procedures - Initial
Default Auctions and replacing existing tables and text-based examples with graphical
illustrations to improve formatting and presentation. 25
ICC also proposes changes to the tools to address liquidity shortfalls in participant
default scenarios to incorporate reference to the Treasury clearing service and distinguish
between the Treasury clearing service and CDS clearing service where appropriate. ICC
proposes to incorporate reference to ICC’s Treasury Clearing Service Liquidity Risk
Management Framework (“LRMF”) and describe the LRMF’s objectives as well as
ICC’s liquidity waterfall, consistent with the language in the LRMF. 26 ICC proposes an
additional subsection regarding certain additional liquidity tools for the Treasury clearing
service, consistent with the Treasury Rules 27 and LRMF. ICC similarly proposes changes
to the tools for non-participant default scenarios to incorporate reference to the Treasury
clearing service and distinguish between the Treasury clearing service and CDS clearing
service where appropriate. Additionally, ICC proposes to explicitly clarify that it is likely

25

The Default Auction Procedures - Initial Default Auctions are publicly available at
https://www.ice.com/publicdocs/ICC_Default_Auction_Procedures.pdf.

26

See supra notes 6 and 14.

27

See Treasury Rule 812.

12

that a recovery scenario in one clearing service would not trigger a significant reduction
in ICC’s employee headcount because the other clearing service would continue
business-as-usual operations. ICC further provides a minor terminology update to
improve clarity in the insurance coverage table by removing a duplicate entry when
outlining the insurance coverage maintained by Intercontinental Exchange, Inc. (“ICE
Inc.)”.
ICC proposes to amend Section IX. As the CDS and Treasury Risk Committees
provide for customer participation, ICC proposes to remove a related statement that is no
longer current. ICC proposes a terminology update to change a reference from “full tearup” to “full termination” to be consistent with the language in CDS and Treasury Rules
810, which use “termination” rather than “tear-up” when discussing the termination of
clearing. Additionally, ICC proposes revisions to the annual review process for the
Recovery Plan. Under the current language, the annual review and material amendments
to this plan are presented to the Risk Committee, 28 who then makes a recommendation to
the Board regarding their approval. As amended, the annual review and material
amendments to this plan would be presented to the Board Risk Committee, who would
then make a recommendation to the Board regarding their approval. This change is
generally intended to streamline the CDS and Treasury Risk Committees’ review
processes and remove the potential for duplicate reviews. The CDS and Treasury
Committees would continue to review material matters impacting this plan in accordance

28

This reference to “Risk Committee” in the plan refers to the CDS Risk Committee, as ICC has not
yet established a Treasury Risk Committee.

13

with the CDS and Treasury Rules and committee charters,29 but would no longer be
required to conduct a separate review solely in connection with the Recovery Plan. ICC
proposes to provide additional details regarding ICC’s testing of the Recovery Plan. ICC
proposes to include that ICC may determine to conduct this Recovery Plan testing
separately or together for the CDS and Treasury clearing services.
In addition to the foregoing proposed changes, ICC proposes general updates to
the Recovery Plan to ensure that the information in the Recovery Plan is current and
accurate. Namely, the proposed changes ensure that relevant information regarding ICC
for the purposes of recovery planning is current with respect to below regarding the CDS
clearing service and Treasury clearing service, where available:
•

Clearing Participants in Section IV.B.;

•

CDS Default Committee - Eligible Clearing Participants in Section IV.B.;

•

ICC revenue, volume, and expense data in Section IV.D.;

•

ICC personnel and facilities in Section VI.A.;

•

ICC CDS In-House Systems in Section VI.A.;

•

ICC UST In-House Systems in Section VI.A.;

•

identification of ICC’s counterparties in the Counterparty Chart in Section
VI.B.;

•

identification of ICC’s contractual agreements in Section VI.C.;

•

change in contact information for CFTC and SEC contacts in Section
VII.B.;

29

For example, by reviewing and recommending for Board approval changes to Rules or procedures
which are referenced in this plan.

14

•

ICE Inc. insurance coverage in Section VIII.B.;

•

ICE Inc. and ICC balance sheet information in Section VIII.B.;

•

ICC dividend payments made in 2025 in Section VIII.B.;

•

ICC 2025 transaction and clearing fee revenue in Section VIII.B.;

•

ICC 2025 outsourcing fees in Section VIII.B.;

•

ICC 2025 compensation data in Section VIII.B.;

•

ICC 2025 annual bonus payments in Section VIII.B.;

•

ICC lease payments to ICE Inc. in Section VIII.B.;

•

ICC projected estimated recovery and wind-down costs in Section X.;

•

calculation of ICC’s projected 12-month operating expenses in Section X.;

•

ICC and ICE Inc. financial information in Section XI.;

•

key ICC reports and descriptions for the Treasury clearing service in
Section XII;

•

ICC glossary of key terms in Appendix A in Section XIII;

•

banking institutions and example proportion of holdings in Appendix C in
Section XIII;

•

ICC stress scenario analysis in Appendix D in Section XIII;

•

ICC recovery tool analysis in Appendix E in Section XIII;

•

recovery tool analysis applied to each scenario in Appendix F in Section
XIII; and

•

index of exhibits in Section XIV.

15

Finally, ICC proposes non-substantive drafting changes and improvements to the
Recovery Plan, such as the correction of typographical errors, and the re-numbering of
sub-sections to reflect the addition and deletion of sub-sections as described above.
II.

ICC Wind-Down Plan

Consistent with the regulations applicable to ICC, the Wind-Down Plan is
designed to establish how ICC could be wound-down in an orderly manner. The WindDown Plan would be used in the event the recovery actions described in the ICC
Recovery Plan failed to preserve ICC’s viability as a going concern (and therefore
recovery is not possible) and resolution has not been triggered. Furthermore, the WindDown Plan may be used in the event ICC makes a business decision to exit all clearing
activities. As noted above, the proposed amendments reflect and relate to changes that
impacted ICC in the past year, including the expansion of ICC’s clearing services to
encompass UST securities, additional updates and edits to the Plans intended to promote
clarity, streamline, and to ensure that the information provided is current.
ICC proposes to amend Section I. The proposed changes specify that the
information provided in the amended Wind-Down Plan is current as of March 6, 2026,
unless otherwise stated. ICC also proposes a footnote to acknowledge that the Treasury
clearing service is not yet launched. The footnote is intended to provide transparency and
clarity, as the Wind-Down Plan incorporates Treasury Clearing Service-specific
information that is based on the anticipated launch of the service.
ICC proposes to amend Section II. As described above, ICC proposes updating
the terminology used to reference its members throughout the Wind-Down Plan to
distinguish between the existing CDS clearing service and the new Treasury clearing

16

service. ICC proposes to clarify that CPs refer to members in the CDS clearing service
and TPs refer to members in the Treasury clearing service. 30 ICC proposes related
changes throughout the document to update terminology to distinguish between the
existing CDS clearing service and the new Treasury clearing service, including,
references to the CDS clearing service General Guaranty Fund versus the Treasury
clearing service Treasury Guaranty Fund, the CDS Rules versus the Treasury Rules, and
the CDS Risk Committee versus the Treasury Risk Committee. 31
ICC proposes additional changes in Section II. to include background on the
launch of ICC as a CDS clearinghouse. 32 This additional context is intended to
distinguish ICC’s existing CDS clearing activities and approvals from its planned
Treasury clearing activities and recent approval to provide clearing services for Treasury
securities.33 While the Treasury clearing service has not yet launched, and ICC proposes
an additional footnote noting so, ICC would include available information pertaining to
the Treasury clearing service throughout the Wind-Down Plan, in accordance with ICC’s
approved Treasury Rules and approved Treasury clearing service policies and
procedures.34 Moreover, currently, the Wind-Down Plan sets out ICC’s sole critical
operation as its CDS clearing services, which ICC proposes to expand more generally to
“clearing services” to consider the Treasury clearing service in Section II. and throughout
the Wind-Down Plan. ICC proposes additional changes to outline ICC’s role as a central

30

Such terminology is consistent with the CDS Rules and Treasury Rules.

31

Id.

32

See supra note 8.

33

See supra note 9.

34

See supra notes 6 and 14.

17

counterparty for the Treasury clearing service in this section and throughout the
document.
ICC proposes changes to Section III. ICC proposes to remove references to
certain regulatory guidance that has been withdrawn. 35 While such guidance has been
withdrawn, ICC continues to consider the principles underlying that guidance in its winddown planning and, accordingly, proposes to replace references to such guidance with
references to industry best practices.
ICC proposes changes in Section IV. with respect to governance structure. ICC
proposes to update the Wind-Down Plan to reflect that ICC has a board-level Board Risk
Committee.36 With the addition of the Board Risk Committee, ICC proposes to update
the governance chart in this section to include the Board Risk Committee and to include a
new subsection describing the role and responsibilities of the Board Risk Committee.
ICC also proposes to incorporate certain Treasury clearing service-specific committees
and groups in the governance chart and include language describing their role,
responsibilities, and composition. ICC proposes a footnote explaining that such Treasury
clearing service-specific working groups and committees have not yet been formed and
may be convened at the direction of ICC management in connection with the launch of
the Treasury clearing service. These groups and committees would include the Treasury

35

See supra note 12.

36

See supra note 15.

18

Risk Committee,37 Treasury Operations Working Group,38 and the Treasury Risk
Working Group.39,40
ICC proposes amendments to Section V with respect to wind-down stress
scenarios. As required by CFTC and SEC regulations,41 ICC would continue to identify
scenarios that may potentially prevent ICC from being able to meet its obligations,
provide its critical operations and services as a going concern, which may lead to ICC’s
orderly wind-down. With respect to such stress scenarios, ICC proposes changes to
incorporate reference to the Treasury clearing service and distinguish between the
Treasury clearing service and CDS clearing service where appropriate.
ICC proposes to amend Section VI. which describes the wind-down
options that will be used in the event that the recovery actions described in the Recovery
Plan failed to preserve ICC’s viability as a going concern and resolution has not been
triggered. With respect to such wind-down options, ICC proposes changes to incorporate
reference to the Treasury clearing service and distinguish between the Treasury clearing
service and CDS clearing service where appropriate. Additionally, ICC proposes
amendments to its approach, timeline, resources, considerations and/or potential
impediments of each wind-down option to include the Treasury clearing service. ICC’s
wind-down options continue to consist of transfer, sale and termination, and amended

37

The description of the Treasury Risk Committee included in the Wind-Down Plan is intended to
align with the corresponding provisions set forth in the Treasury Rules. See supra note 16.

38

See supra note 17.

39

See supra note 18.

40

See supra note 19.

41

CFTC Regulation 17 CFR 39.39(c)(1) and SEC Rules 17 CFR 240.17ad-22(e)(4), 17 CFR
240.17ad-22(e)(15)(i) and 17 CFR 240.17ad-26(a)(3).

19

Section VI. contemplates ICC winding down the CDS and/or Treasury clearing services
using such options. With respect to the termination option, ICC proposes terminology
updates to change references from “tear-up” to “termination” to be consistent with the
language in CDS and Treasury Rules 810, which use “termination” rather than “tear-up”
when discussing the termination of clearing.
ICC proposes changes to its description of the transfer option to contemplate a
transfer of either the CDS clearing service or the Treasury clearing service, as well as a
transfer of both services. For example, ICC proposes to specify in Section VI. that ICC
may transfer ICC’s Treasury clearing service, including open positions to an alternative
clearing house. ICC further proposes to clarify that if both CDS and Treasury clearing
services will be transferred, ICC anticipates pursuing the relevant processes in parallel,
such that the anticipated timeline will not be delayed. In addition, ICC proposes to clarify
if only one clearing service will be transferred, ICC would continue to maintain risk,
treasury, compliance and operations teams on a business-as-usual basis for the remaining
clearing service. With respect to potential impediments or considerations, ICC proposes
to note that there may be a limited number of potential recipient clearing houses because
such clearing houses would be required to have all appropriate registrations.
ICC proposes changes to its description of the sale option to contemplate the sale
of either the CDS clearing service or the Treasury clearing service, as well as the sale of
both services. ICC proposes to define the sale option to include the sale of ICC’s
Treasury clearing activities to another entity. Similarly, ICC proposes to specify that in
the case of a sale of both CDS and Treasury clearing activities, ICC anticipates pursuing
the relevant processes in parallel, such that the anticipated timeline will not be delayed.

20

With respect to potential impediments or considerations, ICC proposes to clarify that if
only one clearing service will be sold, a service provider may prefer to provide
transitional services to the recipient clearing house for a specified time period.
ICC proposes changes to its description of the termination option to contemplate a
transfer of either the CDS clearing service or the Treasury clearing service, as well as a
transfer of both services. ICC proposes to define the termination open to include the
termination of open Treasury positions ideally through orderly close out, and if orderly
close out is not achieved, through the tear up of open positions. ICC proposes to specify
that if only one clearing service will be terminated, ICC will continue to maintain risk,
treasury, compliance and operations teams on a business-as-usual basis for the remaining
clearing service.
ICC proposes amendments to Section VII. With respect to the list of critical
services provided to ICC by affiliates, ICC proposes to update references to the relevant
agreement governing those services. 42 ICC further proposes to revise the service
descriptions in the “Critical Services Provided to ICC by Third Party Service Providers”
chart to incorporate reference to the Treasury clearing service and to describe the relevant
services more generally. Such changes are intended to align the language in the chart
with the corresponding chart in the Recovery Plan. ICC proposes updates to include the
core services for the Treasury clearing service, consistent with the identification of such
core services for the CDS clearing service. These core services include acceptance of new
trades, management of positions, production of risk and banking reports, and movement
of funds. ICC also proposes to amend its staffing considerations regarding the roles

42

See supra note 22.

21

necessary to support the core services on a daily basis and in the event of wind-down.
ICC proposes to specify that, in general, all staff in a functional area provide support for
all cleared products and markets at ICC and personnel are not split between the CDS and
Treasury clearing services. ICC proposes to clarify that ICC separately holds the
dedicated funds used to meet financial resources requirements for the CDS clearing
service from the Treasury clearing service.
ICC proposes to amend Section VIII., which analyzes ICC’s contractual
arrangements in the context of continuation of services during wind-down. ICC proposes
to incorporate reference to the Treasury clearing service and to distinguish between the
Treasury clearing service and the CDS clearing service where appropriate. This includes
identifying which arrangements are applicable to each clearing service. ICC also
proposes conforming updates to its description of the relevant contractual provisions and
to its analysis of the potential impact of such provisions on wind-down implementation.
Such updates include the effect of a counterparty’s termination of an agreement on a nonimpacted clearing service.
ICC proposes to update Section IX, X and XI. ICC proposes updates to Section
IX. with respect to its financial resources for wind-down planning. Namely, ICC
proposes to specify that it ensures that it is in compliance with all regulatory capital
requirements at the entity level in Section IX. ICC proposes to update Section X. with
respect to wind-down governance. ICC proposes updates to include the ICC Board Risk
Committee in the Wind-Down Plan’s governance. Under the current language, the annual
review and material amendments to this plan are presented to the Risk Committee, 43 who

43

See supra note 28.

22

then makes a recommendation to the Board regarding their approval. As amended, the
annual review and material amendments to this plan would be presented to the Board
Risk Committee, who would then make a recommendation to the Board regarding their
approval. As discussed above, this change is generally intended to streamline the CDS
and Treasury Risk Committees’ review processes and remove the potential for duplicate
reviews. The CDS and Treasury Committees would continue to review material matters
impacting this plan in accordance with the CDS and Treasury Rules and committee
charters,44 but would no longer be required to conduct a separate review solely in
connection with the Wind-Down Plan. ICC proposes to specify that the results of testing
of the Wind-Down Plan will be provided to the Treasury Risk Committee and Board Risk
Committee, in addition to the CDS Risk Committee and Board. ICC proposes to update
Section XI. with respect to certain clearing process charts in Section XI.B and C. ICC
proposes to specify that these charts reflect the CDS clearing service. The Treasury
clearing service has not yet launched. Accordingly, Treasury clearing process charts are
not included at this time, and this section will be updated in a future filing.
In addition to the foregoing proposed changes, ICC proposes general updates to
the Wind-Down Plan to ensure that the information in the Wind-Down Plan is current
and accurate. Namely, the proposed changes ensure that relevant information regarding
ICC for the purposes of wind-down planning is current with respect to below regarding
the CDS clearing service and Treasury clearing service, where available:
•

44

Clearing Participants in Section IV.A.;

See supra note 29.

23

•

change in contact information for the SEC and CFTC contacts in Section
VI.A.;

•

ICC clearing and processing fees in Section VII.;

•

ICC personnel and facilities in Section VII.C.;

•

ICC CDS In-House Systems in Section VII.C.;

•

ICC UST In-House Systems in Section VII.C.;

•

identification of ICC’s counterparties in the Counterparty Chart VII.D.;

•

contractual arrangements chart in Section VIII.;

•

financial resources to support wind-down in Section IX.;

•

glossary of key terms in Section XI.A;

•

banking institutions and example proportion of holdings charts in Section
XI.C.;

•

ICC stress scenario analysis chart in Section XI.D.; and

•

index of exhibits in Section XII.

Finally, ICC proposes non-substantive drafting changes and improvements to the
Wind-Down Plan, such as the correction of typographical errors and the re-numbering of
sub-sections to reflect the addition and deletion of sub-sections as described above.
(b)

Statutory Basis

ICC believes that the proposed rule changes are consistent with the requirements
of Section 17A of the Act45 and the regulations thereunder applicable to it, including the
applicable standards under Rule 17ad-22.46 In particular, Section 17A(b)(3)(F) of the

45

15 U.S.C. 78q-1.

46

17 CFR 240.17ad-22.

24

Act47 requires that the rule change be consistent with the prompt and accurate clearance
and settlement of securities transactions and derivative agreements, contracts and
transactions cleared by ICC, the safeguarding of securities and funds in the custody or
control of ICC or for which it is responsible, and the protection of investors and the
public interest.
ICC believes the proposed changes would enhance its ability to effectuate a
successful recovery as well as to execute an orderly wind-down by providing updates and
additional clarity with respect to ICC’s recovery and wind-down processes and
procedures. As discussed herein, the proposed revisions ensure that relevant information
regarding ICC for recovery and wind-down planning is current and up to date and
includes ICC’s Treasury clearing service. The Plans would thus promote ICC’s ability to
continue providing clearing services with as little disruption as possible, and should
continuation not be feasible in one or both clearing services, promote ICC’s ability to
discontinue one or both clearing services in an orderly manner with minimum negative
impact to the marketplace and stakeholders. Accordingly, in ICC’s view, the proposed
rule change is consistent with the prompt and accurate clearance and settlement of
securities transactions, derivatives agreements, contracts, and transactions, the
safeguarding of securities and funds in the custody or control of ICC or for which it is
responsible, and the protection of investors and the public interest, within the meaning of
Section 17A(b)(3)(F) of the Act.48

47

15 U.S.C. 78q-1(b)(3)(F).

48

Id.

25

The proposed rule changes would also satisfy the relevant requirements of Rule
17ad-22.49 Rule 17ad-22(e)(2)50 requires, in relevant part, each covered clearing agency
to establish, implement, maintain, and enforce written policies and procedures reasonably
designed to provide for governance arrangements that are (i) clear and transparent; (ii)
clearly prioritize the safety and efficiency of the covered clearing agency; (iii) support the
public interest requirements of Section 17A of the Act 51 applicable to clearing agencies,
and the objectives of owners and participants; (iv) establish that the board of managers
and senior management have appropriate experience and skills to discharge their duties
and responsibilities; (v) specify clear and direct lines of responsibility; and (vi) consider
the interests of participants’ customers securities issuers and holders, and other relevant
stakeholders of the covered clearing agency. The proposed changes include the addition
of the Board Risk Committee and Treasury clearing service-specific committees and
working groups thereby, clarifying ICC’s governance arrangements that are relevant to
recovery and wind-down, including the roles and responsibilities of the Board, applicable
committees, and management. Additionally, pursuant to the amended Plans, the annual
review and any material amendments would be presented to the Board Risk Committee,
which would make a recommendation to the Board regarding approval. As described
above, this change would streamline the CDS and Treasury Risk Committees’ review
processes and eliminate the potential for duplicative reviews, while continuing to
maintain governance arrangements that support ICC’s recovery and wind-down planning.
ICC’s governance arrangements continue to promote the safety and efficiency of ICC and
49

17 CFR 240.17ad-22.

50

17 CFR 240.17ad-22(e)(2).

51

15 U.S.C. 78q-1.

26

support the public interest requirements in Section 17A of the Act 52 applicable to clearing
agencies, and the objectives of owners and participants, by updating ICC’s governance
structure, such that ICC continues to clearly define relevant roles and responsibilities that
prioritize the safety and efficiency of ICC so that it continues to provide safe and sound
central counterparty services in the context of recovery or wind-down. As such, ICC
believes that the proposed rule change is consistent with the requirements of Rule 17ad22(e)(2).53
Rule 17ad-22(e)(3)(ii)54 requires ICC to establish, implement, maintain, and
enforce written policies and procedures reasonably designed to maintain a sound risk
management framework for comprehensively managing legal, credit, liquidity,
operational, general business, investment, custody, and other risks that arise in or are
borne by ICC, which includes plans for the recovery and orderly wind-down of ICC
necessitated by credit losses, liquidity shortfalls, losses from general business risk, or any
other losses. The Recovery Plan continues to establish ICC’s actions to maintain its
viability as a going concern to address any uncovered credit loss, liquidity shortfall,
capital inadequacy, or business, operational or other structural weakness that threatens
ICC’s viability. The Wind-Down Plan continues to establish how ICC could be wounddown in an orderly manner should its recovery efforts fail. As described above, the
proposed changes include updates and edits to promote clarity and to ensure that the
information in the Plans is current and includes the expansion of ICC’s clearing services
to encompass UST securities. In ICC’s view, such changes would ensure that the Plans
52

Id.

53

17 CFR 240.17ad-22(e)(2).

54

17 CFR 240.17ad-22(e)(3)(ii).

27

remain useful and effective in a recovery and wind-down scenario. The proposed rule
change would thus promote ICC’s ability to carry out a successful recovery or orderly
wind-down, consistent with the requirements of Rule 17ad-22(e)(3)(ii).55
Rule 17ad-22(e)(15)56 requires ICC to establish, implement, maintain, and enforce
written policies and procedures reasonably designed to identify, monitor, and manage
ICC’s general business risk and hold sufficient liquid net assets funded by equity to cover
potential general business losses so that ICC can continue operations and services as a
going concern if those losses materialize, including by (i) determining the amount of
liquid net assets funded by equity based upon its general business risk profile and the
length of time required to achieve a recovery or orderly wind-down, as appropriate, of its
critical operations and services if such action is taken; (ii) holding liquid net assets
funded by equity equal to the greater of either (x) six months of ICC’s current operating
expenses, or (y) the amount determined by the Board to be sufficient to ensure a recovery
or orderly wind-down of critical operations and services of ICC, as contemplated by the
plans established under Rule 17ad-22(e)(3)(ii)57; and (iii) maintaining a viable plan,
approved by the Board and updated at least annually, for raising additional equity should
its equity fall close to or below the amount required under Rule 17ad-22(e)(15)(ii).58
The Plans continue to analyze ICC’s particular circumstances and risks to ensure
that ICC maintains financial resources necessary to implement both Plans and that ICC
remains in compliance with all regulatory capital requirements. The Plans include

55

Id.

56

17 CFR 240.17ad-22(e)(15).

57

17 CFR 240.17ad-22(e)(3)(ii).

58

17 CFR 240.17ad-22(e)(15)(ii).

28

information on the financial resources maintained by ICC for recovery and to support
wind-down of one or both clearing services in compliance with relevant regulations and
include procedures to follow in case of any shortfall. As such, ICC believes that the
proposed rule change is consistent with the requirements of Rule 17ad-22(e)(15).59
The proposed rule change would also satisfy the requirements of Rule 17ad-26,
which broadly covers the requirements for the recovery and orderly wind-down plans of
covered clearing agencies. 60 Rule 17ad-26 requires ICC to (1) identify and describe its
core payment, clearing, and settlement services and address how ICC would continue to
provide such core services in the event of a recovery and during an orderly wind-down,
including by: (i) identifying the staffing roles necessary to support such core services;
and (ii) analyzing how such staffing roles necessary to support such core services would
continue in the event of a recovery and during an orderly wind-down; (2)(i) identify and
describe any service providers for core services, specifying which core services each
service provider supports; and (ii) address how ICC would ensure that service providers
for core services would continue to perform in the event of a recovery and during an
orderly wind-down, including consideration of its written agreements with such service
providers and whether the obligations under those written agreements are subject to
alteration or termination as a result of initiation of the recovery and orderly wind-down
plan; (3) identify and describe scenarios that may potentially prevent ICC from being
able to provide its core services as a going concern, including uncovered credit losses,
uncovered liquidity shortfalls, and general business losses; (4) identify and describe

59

17 CFR 240.17ad-22(e)(15).

60

17 CFR 240.17ad-26.

29

criteria that could trigger ICC's implementation of its recovery and orderly wind-down
plans and the process that the ICC uses to monitor and determine whether the criteria
have been met, including the governance arrangements applicable to such process; (5)
identify and describe the rules, policies, procedures, and any other tools or resources on
which ICC would rely in a recovery or orderly wind-down; (6) address how the rules,
policies, procedures, and any other tools or resources would ensure timely
implementation of the recovery and orderly wind-down plan; (7) require ICC to inform
the Commission as soon as practicable when ICC is considering implementing a recovery
or orderly wind-down; (8) include procedures for testing ICC's ability to implement the
recovery and orderly wind-down plans at least every 12 months, including by: (i)
requiring ICC's participants and, when practicable, other stakeholders to participate in the
testing of its plans; (ii) requiring that such testing be in addition to default management
testing; (iii) providing for reporting the results of such testing to ICC's board of directors
and senior management; and (iv) specifying the procedures for, as appropriate, amending
the plans to address the results of such testing; and (9) include procedures requiring
review and approval of the plans by ICC’s Board at least every 12 months or following
material changes to ICC's operations that would significantly affect the viability or
execution of the plans, with such review informed, as appropriate, by ICC's testing of the
plans.
The Plans continue to establish ICC’s actions in the event of recovery or orderly
wind-down, and as modified by these proposed changes, include coverage of all the
requirements of Rule 17ad-26.61 Specifically, the Plans (1) describe how ICC identifies

61

Id.

30

staffing roles necessary to support recovery and orderly wind-down; (2) describe its
service providers for core services, and include an analysis of its agreements with its
service providers for core services and the potential impact of the initiation of its
recovery and orderly wind-down plan on such contractual agreements; (3) describe
scenarios that potentially could prevent ICC from being able to provide its identified core
services; (4) describe criteria that would cause ICC to trigger implementation of the Plans
and ICC’s monitoring methods to determine if the criteria have been met; (5) identify
ICC Rules, policies, procedures and tools for implementation of the Plans; (6) describe
how the Rules, policies, procedures and tools ensure a timely recovery or wind-down
process; (7) require notification of the Commission by ICC when it is considering
implementing the Plans; (8) cover testing of the Plans every twelve (12) months; and (9)
include annual review of the Plans by the Board. ICC believes the Plans continue to
provide appropriate procedures and tools, and comprehensively describe ICC’s plans for
recovery and orderly wind-down consistent with the requirements of Rule 17ad-26.62
(B)

Clearing Agency’s Statement on Burden on Competition

ICC does not believe the proposed rule changes would have any impact, or
impose any burden, on competition. The proposed changes to the Plans will apply
uniformly across all market participants. The changes are being proposed to promote
clarity, streamline, and ensure that the information provided is current in the Plans. ICC
does not believe the amendments would affect the costs of clearing or the ability of
market participants to access clearing. Therefore, ICC does not believe the proposed rule

62

Id.

31

changes would impose any burden on competition that is inappropriate in furtherance of
the purposes of the Act.
(C)

Clearing Agency’s Statement on Comments on the Proposed Rule Change
Received from Members, Participants or Others

Written comments relating to the proposed rule change have not been solicited or
received. ICC will notify the Commission of any written comments received by ICC.
III.

Date of Effectiveness of the Proposed Rule Change and Timing for Commission
Action
Within 45 days of the date of publication of this notice in the Federal Register or

within such longer period up to 90 days (i) as the Commission may designate if it finds
such longer period to be appropriate and publishes its reasons for so finding or (ii) as to
which the self-regulatory organization consents, the Commission will:
(A)

by order approve or disapprove such proposed rule change, or

(B)

institute proceedings to determine whether the proposed rule change

should be disapproved.
(IV)

Solicitation of Comments
Interested persons are invited to submit written data, views, and arguments

concerning the foregoing, including whether the proposed rule change is consistent with
the Act. Comments may be submitted by any of the following methods:
Electronic Comments:
•

Use the Commission’s Internet comment form
(https://www.sec.gov/rules/sro.shtml); or

•

Send an e-mail to rule-comments@sec.gov. Please include File Number SR-ICC2026-009 on the subject line.

32

Paper Comments:
Send paper comments in triplicate to Secretary, Securities and Exchange
Commission, 100 F Street, NE, Washington, DC 20549.
All submissions should refer to File Number SR-ICC-2026-009. This file number
should be included on the subject line if e-mail is used. To help the Commission process
and review your comments more efficiently, please use only one method. The
Commission will post all comments on the Commission’s Internet website
(https://www.sec.gov/rules/sro.shtml). Copies of such filings will be available for
inspection and copying at the principal office of ICE Clear Credit and on ICE Clear
Credit’s website at https://www.ice.com/clear-credit/regulation.
Do not include personal identifiable information in submissions; you should
submit only information that you wish to make available publicly. We may redact in part
or withhold entirely from publication submitted material that is obscene or subject to
copyright protection.

33

All submissions should refer to File Number SR-ICC-2026-009 and should be
submitted on or before [INSERT DATE 21 DAYS AFTER DATE OF PUBLICATION
IN THE FEDERAL REGISTER].
For the Commission, by the Division of Trading and Markets, pursuant to
delegated authority.63

Sherry R. Haywood,
Assistant Secretary.

63

17 CFR 200.30-3(a)(12).

34

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Asec%3Ad01eb39cfe91dc84. Public record. Not legal advice.