SEC seeks comment on DTCC ITP clearing exemption application

The U.S. Securities and Exchange Commission (SEC) is soliciting public comment on an application by DTCC ITP LLC to be exempted from registration as a clearing agency under Section 17A of the Securities Exchange Act of 1934, so that it can take over the central trade-matching role currently performed by its wholly owned subsidiary, DTCC ITP Matching (ITPM). The notice was published in the Federal Register of Monday, August 31, 2026 (Vol. 91, No. 167, Notices section, p. 55933), as Release No. 34-106203; File No. 600-46 (FR Doc. 2026-17674).

Background of the application

DTCC ITP filed its application on Form CA-1 on September 18, 2025, seeking a conditional exemption from registration as a clearing agency. The company proposes to assume ITPM’s obligations as a central matching service provider and exempt clearing agency, so that eventually ITPM may withdraw its exemption status and be duly dissolved. ITPM has provided central matching and electronic trade confirmation (ETC) services under the ITPM Exemption granted by the Commission in 2001.

DTCC ITP is a Delaware limited liability company whose sole member is The Depository Trust & Clearing Corporation (DTCC). It operates entirely through service agreements with DTCC and its affiliates, has “zero” employees of its own, and relies on roughly 60 full-time DTCC staff who provide dedicated support. Its proposed services would be unchanged from those ITPM currently offers:

• CTM, a central post-trade matching platform;
• TradeSuite ID, a confirmation and affirmation service;
• ALERT, a global database of securities, cash and collateral standing settlement instructions;
• ITP Integration Business Services, a non-core service to help clients implement the above.

Proposed conditions to the exemption

The application proposes a new set of conditions, split into operational and interoperability conditions, designed to reflect the evolution of clearing regulation since 2001. Under the proposed operational conditions, DTCC ITP would offer client services limited to allocation, matching, confirmation and affirmation, and would not perform other clearing agency functions such as net settlement or maintaining open positions.

If the exemption is granted, DTCC ITP would become an “SCI entity” under Regulation SCI, requiring its systems to have sufficient operational and processing capacity, integrity, resiliency and security. The proposed interoperability conditions would require the company to maintain an interface open to any exempt clearing agency, on fair and non-discriminatory terms, with advance notice of material changes.

Why the exemption matters

DTCC ITP argues that imposing the full range of clearing agency regulation on an entity that performs only post-trade matching would unnecessarily raise compliance costs and could lead to higher fees for customers. It points to ITPM’s track record, including its role in the move to T+1 settlement on May 28, 2024, and the earlier shift from T+3 to T+2 in 2017, both of which it handled effectively as an exempt clearing agency.

Interested persons are invited to submit written data, views and arguments on whether the proposed exemption is consistent with the public interest, the protection of investors and the purposes of Section 17A. Comments may be submitted electronically through the SEC’s website or by email to rule-comments@sec.gov, referencing File No. 600-46, or by paper to the Secretary, Securities and Exchange Commission, 100 F Street NE, Washington, DC 20549-1090. All submissions must be received on or before October 15, 2026.

The decision will shape the competitive structure of post-trade processing in U.S. markets, determining whether a single DTCC entity can continue to run the central matching utility that underpins settlement for broker-dealers and institutional investors without the full burden of clearing agency registration.

Source: Federal Register, Vol. 91, No. 167, August 31, 2026, Notices, p. 55933 (official reference: Release No. 34-106203; File No. 600-46 / FR Doc. 2026-17674).