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SEC

SEC

Securities and Exchange Commission (US)

Medium Impact

SEC notice: NSCC immediate-effectiveness amendments to Clearing Agency Risk Management Framework

Published

Sep 29, 2026

Effective

Sep 18, 2026

Topics

Clearing agency risk management, NSCC, DTC, FICC, Rule 17ad-22(e), Rule 17ad-25(j), Rule 17ad-26, Recovery and wind-down planning, Governance and conflicts of interest

Executive Summary

The SEC has published NSCC’s notice of filing and immediate effectiveness for SR-NSCC-2026-010, amending the Clearing Agency Risk Management Framework used by NSCC, DTC and FICC. The filing is primarily clarifying and governance-oriented rather than a new participant-facing operating requirement. It reorganizes the Framework to align with internal policy and procedure governance standards; adds a new exceptions section; consolidates governance provisions; updates descriptions showing how the Framework supports compliance with Rule 17ad-25(j) on core service provider risk and stakeholder views and Rule 17ad-26 on recovery and wind-down plans; and adds a reference to the Clearing Agency Framework for Certain Requirements on Governance and Conflicts of Interests adopted in 2024. NSCC states the administrative and conforming changes do not alter how the Clearing Agencies comply with Rule 17ad-22(e) and do not impose a competitive burden. Business impact is therefore low for participants, but members and service providers should refresh internal regulatory inventories, oversight mappings and due diligence materials that cite the Framework.

What Changed

modifiedFramework structure and governance layout

Previous

Governance, ownership, approval and descriptive material were concentrated in earlier sections, including the prior “Executive Summary” and “Framework Ownership and Change” sections.

New

The Framework separates purpose, roles and responsibilities, audience, exceptions and governance into updated sections designed to improve clarity and consistency.

newExceptions process section

Previous

The source does not identify a dedicated exceptions section in the existing Framework.

New

Exceptions to the Framework are addressed in a separate section covering escalation, approval and documentation.

modifiedRule 17ad-25(j) and core service provider risk references

Previous

The Framework previously supported several covered clearing agency requirements, but the filing adds further disclosures addressing Rule 17ad-25(j).

New

Sections 1, 5.2.1 and 5.3 include updated references to Rule 17ad-25(j), core service provider risk management and advisory councils.

modifiedRule 17ad-26 recovery and wind-down plan references

Previous

The Framework addressed risk management and recovery and wind-down planning, and the source states Board approval of the plans was described as biennial.

New

Section 6 references Rule 17ad-26 and states that Board approval of Recovery and Wind-down Plans is required annually.

modifiedConforming and administrative updates

Previous

The Framework used older department names, section references, framework titles and some less precise wording.

New

The Framework uses updated names, corrected citations and clarified descriptions without changing NSCC’s stated compliance approach under Rule 17ad-22(e).

Business Impact

Who is affected

Directly affected

NSCC, DTC and FICC governance, legal, risk, compliance, internal audit and recovery and wind-down planning functions.

Indirectly affected

NSCC, DTC and FICC participants, firms that rely on clearing agency disclosures for due diligence, and providers of core services referenced in oversight or continuity materials.

Jurisdictions

United States

Business processes

Clearing agency risk management framework governance, Core service provider risk oversight mapping, Recovery and wind-down plan governance, Participant due diligence and regulatory inventory maintenance, Internal policy and control library updates, Monitoring of SEC SRO rule filing comments and potential suspension window

Estimated effort

Low

Compliance risk

Low

Affected Reports

Internal regulatory change inventory entry for SR-NSCC-2026-010Clearing agency due diligence questionnaire or oversight file referencing the Risk Management FrameworkThird-party and core service provider risk control mapping tied to Rule 17ad-25(j)Recovery and wind-down plan governance mapping tied to Rule 17ad-26Policy library cross-reference table for DTCC Clearing Agency frameworks
FieldValidation rule
Framework section title and location referencesThe SEC notice states Sections 1 and 2 are renamed, new Sections 7 and 8 are created, and current sections are renumbered to reflect the revised structure.
Risk function owner nameThe SEC notice states references to the “Risk Department” are replaced with “Group Chief Risk Office.”
Rule citation formatThe SEC notice states references to “17 CFR 240.17Ad-22(e)” are replaced with “17 CFR 240.17ad-22(e).”
Supporting framework titleThe SEC notice states the “Clearing Agency Securities Valuation Framework” is renamed the “Clearing Agency Price and Margin Input Data Framework.”
Recovery and Wind-down Plan Board approval frequencyThe SEC notice states Section 6 is revised to reflect that Board approval of the Recovery and Wind-down Plans is required annually rather than biennially.

Recommended Actions

7 suggested next steps· derived from source analysis
  1. 1
    AI generatedStep 1 of 7

    Update regulatory inventories and obligation mappings to record SR-NSCC-2026-010 as effective upon filing and to link the Risk Management Framework to Rules 17ad-25(j), 17ad-26 and 17ad-22(e).

  2. 2
    AI generatedStep 2 of 7

    Refresh internal policy library cross-references for renamed or relocated Framework sections, including the new Exceptions and Framework Governance sections.

  3. 3
    AI generatedStep 3 of 7

    Where due diligence files refer to DTCC Clearing Agency risk governance, replace outdated references to the Risk Department with Group Chief Risk Office and update the renamed Price and Margin Input Data Framework reference.

  4. 4
    AI generatedStep 4 of 7

    Review recovery and wind-down oversight materials for consistency with the stated annual Board approval requirement and the core staffing/core service provider description.

  5. 5
    AI generatedStep 5 of 7

    Confirm third-party or core service provider oversight control mappings reflect the Rule 17ad-25(j) framing described in the amended Framework.

  6. 6
    AI generatedStep 6 of 7

    Monitor the SEC comment file for any comments and the 60-day SEC suspension period following the September 18, 2026 filing date.

  7. 7
    AI generatedStep 7 of 7

    Do not create new participant reporting builds solely from this notice unless DTCC or the Clearing Agencies separately publish operational instructions or template changes.

Timeline

other

2024

The Clearing Agencies adopted the Clearing Agency Framework for Certain Requirements on Governance and Conflicts of Interests, which the amended Risk Management Framework now references.

effective date

Sep 18, 2026

NSCC filed SR-NSCC-2026-010 with the SEC under Section 19(b)(3)(A) and Rule 19b-4(f)(4); the filing became effective pursuant to those provisions.

publication

Sep 29, 2026

SEC Release No. 34-106527 was dated and published as a notice soliciting comments on the immediately effective proposed rule change.

other

Nov 17, 2026

End of the 60-day period from the September 18, 2026 filing date during which the SEC may summarily temporarily suspend the rule change if it appears necessary or appropriate under the Act.

Sources

AI-generated analysis is based on the following primary sources. Always verify against the official publication.

Related Evidence

Verified source support for this analysis

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