Review of Pending US Regulatory initiatives

Mandated central clearing of US Treasuries

Final rule: The compliance dates for US Treasury Clearing were extended by the SEC on February 25, 2025

• Clearing of eligible cash secondary market transactions: December 31, 2026
• Clearing of eligible repo market transactions: June 30, 2027

Rule text: S7-23-22

ACS TRIPARTY

Collateral-in-Lieu

Proposed Rule:

• On September 19 the FICC filed Rule Filing SR-FICC-025-021 to add a new offering called the ACS Triparty Service
• On August 29 the FICC filed Rule Filing SR-FICC-2025-019 to establish a Collateral-in-Lieu Offering Within the Sponsored GC Service

Rule text: SR-FICC-2025-021

SR-FICC-2025-019

• The SEC has approved CME’s application for registration as a Clearing Agency for US Treasury cash and Treasury repo transactions
• The SEC has instituted proceedings to determine whether to grant or deny Ice Clear Credit’s Application for Registration as a Clearing Agency

Rule text: CMe Approval

ICC Order

Final rule:

• The compliance date has been extended to June 30, 2026

Rule text: S7-11-23

Extension Notice

Amendments requiring firms to adopt written policies and procedures for incident response programs to address unauthorized access to or use of customer information.

Final Rule:

• The Compliance Date for Larger entities is 12/3/2025.  Smaller firms have until June 3, 2026

Rule text: S7-05-23

Final rule: The compliance date for the Transparency of Better Priced Odd Lot Orders is May 1, 2026.

On October 31 the SEC issued exemptive relief extending the following compliance dates:

• The amended minimum pricing increment: November 2, 2026
• Access fee caps: November 2, 2026
• Requirement that exchange fees be determined at the time of execution: February 2, 2026

Rule text: S7-30-22

SEC Exemptive Relief

Final rule:

• Approved March 6, 2024
• The SEC has extended the compliance date to August 1 2026

Rule text: S7-29-22

Extension of Rule 605 Compliance Date

Final Rule:

• On August 25 2025, the 5th Circuit Court remanded Rule 13F-2 to the SEC finding they failed to conduct a proper economic analysis when issuing the original rule
• On December 3, 2025, the SEC provided exemptive relief extending the compliance date to January 2, 2028

Rule text: 5th Circuit Court Opinion

SEC exemptive relief

Proposal:

• The comment period closed October 21, 2024 (Listed as “in Final Rule Stage” on the SEC’s Flex Agenda)

Rule text: S7-2024-05

Proposal: Notice of Proposed Rulemaking issued May 21, 2024

• Comment period closed July 22, 2024

Rule text: S7-2024-02

Exemptive Relief

• The SEC granted a six-month extension on representative order linkage (through January 31, 2026) to allow the SEC to determine a long-term solution.
• FINRA extended the current rule allowing firms to truncate order event time stamps more precise than a nanosecond, when sending data to the Consolidated Audit Trail, to April 8, 2030

Rule text: Release No. 34-103528

SR-FINRA-2025-12

Exemptive Relief

• The SEC issued an exemptive order in February 2025 to exclude certain PII from CAT. FINRA CAT published CAT Alert 2025-02 announcing changes to align CAIS with the SEC's exemptive order
• On March 7, 2025, the CAT Plan Participants submitted a rule filing to remove PII from CAT
• On November24, 2025, the SEC published Notice of Designation of a Longer Period for Commission Action extending the SEC’s decision date to January 23, 2026

Rule text: CAT Alert 2025-02

CAT NMS Plan CAIS Amendment

SEC Notice

Court Ruling:

The 11th Circuit Court held the SEC’s Funding Order for the Consolidated Audit Trail (CAT) is “arbitrary and capricious and is in violation of the Administrative Procedure Act” The Court stayed their decision to vacate the Rule for 60 days from the effective date of the rule to allow the SEC to conduct an economic analysis and reconsider the allocation CAT costs in accordance with their opinion.

• FINRA-CAT issued an alert stating “CAT fees remain in effect and will continue to be invoiced and collected while the stay is in effect”
• The CAT Participants have filed a proposed alternate funding model

Rule text: 11th Circuit Court No. 23-13396

CAT Alert 2025-03

Proposed Amended CAT Funding Model

The SEC has issued an FAQ on Crypto Custody

Rule text: SEC FAQ

The SEC approval of the exchange applications to offer 24x5 trading is contingent upon SIPS confirming they are prepared to disseminate quotation and transaction data during the extended trading hours

• The SIPS have announced that they will submit a Plan to the SEC to extend their operating hours
• NSCC has announced 24x7 operations beginning in Q2 2026

Rule text: SIP Press Release

NSCC Bulletin

Reporting of Securities Lending Transactions in accordance with SEC Rule 10c-1

Final rule:

• On August 25 2025, the 5th Circuit Court remanded Rule 10c1 to the SEC finding they failed to conduct a proper economic analysis when issuing the original rule
• On December 3, 2025, the SEC provided exemptive relief extending the compliance date to September 28, 2028,

Rule text: 5th Circuit Court Opinion

Sec exemptive relief

Final rule:

• The SEC has approved FINRA’s   rule proposal to maintain the 15-minute reporting window

Rule text: SEC approval of FINRA rule filing

Technical Notice:

• FINRA Issued a Technical Notice setting the effective date for Fractional Shares Reporting for February 23, 2026. UAT will begin in November 2025

Rule text: Trade Reporting Notice 032224

Technical Notice

Final Rule:

• Expansion of TRF Operating Hours (changing open from 8:00am to 4:00am)

Rule text: SR-FINRA-2025-011

Guidance:

• FINRA issued updated interpretations of Financial and Operational Rules

Rule text: FINRA RN 25-12

Proposed:

• FINRA is considering changes to the day trading rules, aligning day trading rules with traditional margin

Rule text: FINRA RN 24-13

Final rule:

• Consultation Period closed on October 18, 2024
• Approval was published in Bulletin 25-0200

Rule text: CIRO Bulletin 24-0213

CIRO Bulletin 25-0200

Proposed rule:

• Proposed UMIR amendment for trading increments for US inter listed securities
• Anticipating republication by the end of 2025

Rule text: CIRO Bulletin 24-0363

Amendments to introduce a mandatory close-out requirement and expand the requirement to have a reasonable expectation to settle on Investment dealers that are not participants.

Proposal:

• Comment Period closed April 10, 2025

Rule text: Bulletin 25-0001

Amendments to enhance the rule framework regarding retail Fully Paid Securities lending

Proposal:

• Comment Period closed April 15, 2024
• Anticipating republication for comment in by the end of 2025

Rule text: Bulletin 24-0067

• Dealers will be required to provide detailed information on the investments held by their retail clients as at December 31, 2026
• CIRO has put this effort on hold until further notice

Rule text: Bulletin 25-0111

CIRO Notice

CIRO has proposed guidance on Order Execution Only services related to “decision-making supports” and outlines key safeguards that OEO dealers should consider

• Final Guidance expected in the first quarter of 2026

Rule text: Bulletin 25-0227

CIRO issued a white paper that offers regulatory and technological solutions to improve account transfers, a major source of frustration for investors.

Rule text: CIRO White Paper on Account Transfers

Final rule:

• The SEC has approved the MSRB’s proposed rule maintaining the 15 minute reporting time frame

Rule text: SEC approval of MSRB rule filing

Final rule:

• Testing will resume in January 2026. Go live is projected for the first half of 2026

Rule text: OCC Transformation Site

Final rule:

• The compliance date for withholding for combinations and non delta 1 securities has been moved to January 1, 2027

Rule text: IRS Notice 2024-44

Final rule:

• January 1, 2026: Insurance and Investment Dealers begin collecting accrued fees and factors charged to clients related to ETFs, mutual funds, and segregated funds
• January 1, 2027: Dealers start communicating through the Annual Report on Charges and other Compensation (ARCC) The CSA has approved the CIRO amendments to the IDPC and MFD rules

Rule text: OSC Notice

Bulletin 25-0176