Overview
FICC implemented the Agent Clearing Service (ACS) and other access model enhancements in March 2025. The implementation of the ACS and other access models offer indirect participants a clearing model through which both done-away and done-with customer activity can be cleared.
Done-away transactions are executed by an Indirect Participant with a counterparty other than its clearing intermediary. In contrast, done-with bundles trade clearing and execution.
Agent Clearing Members (ACMs) are Direct Participants of FICC with full netting membership. However, their customers are not participants of FICC. Under the ACS model, the Indirect Participant (referred to as an “Executing Firm Customer”) can enter into a trade with its Agent Clearer or a third party that is either a Direct Participant or Indirect Participant at FICC and give the trade up to its Agent Clearer, as applicable, to clear at FICC for the benefit of the Executing Firm Customer.
Eligible transactions include outright purchases and sales of U.S. Treasury and Agency securities, as well as two-directional (i.e., cash borrowing and cash lending) overnight and term DVP repo.
The ACS allows Netting Members (as ACMs) to submit, on behalf of their customers, transactions to FICC for novation. The ACS access model offers the same benefits of central clearing as client clearing models offered in other asset classes (e.g., derivatives).
Central clearing at FICC offers significant benefits, including centralized risk management, centralized default management, comparison, multilateral netting, and settlement efficiencies.
Other benefits:
- Reduction of counterparty risk: Central clearing reduces counterparty risk through FICC’s guarantee of the completion of settlement in a member default scenario.
- Balance sheet and capital relief opportunities
- The ACS facilitates agent-style trading by allowing an ACM to act as a processing agent and credit intermediary for its Executing Firm Customers.
- Like FICC’s Sponsored Service, the ACS facilitates both done-with and done-away activity.
- The ACS will make it possible to bring a much larger percentage of the market into clearing, while still maintaining robust risk management standards.
- Most Netting Members are eligible to apply to be an ACM of FICC. The application requires information about the applicant’s customers, past and/or projected volumes of customer activity, and the applicant’s controls for monitoring and mitigating risks, including customer risks.
- An applicant to be an ACM must be a FICC/GSD Netting Member that has established a relationship with one or more Executing Firm Customer(s) pursuant to the GSD Rules.
- ACMs must be from a FICC-approved jurisdiction.
- Agent Clearing Trades may be gross- or net-margined with other Agent Clearing Trades in the Agent Clearing Member’s Omnibus Account.
- An ACM can designate one or more of its Agent Clearing Member Omnibus Accounts to be segregated (Segregated Indirect Participants Accounts), in which case the margin calculated on activity cleared in that account (Segregated Customer Margin) would be done on a gross basis and funded by the Executing Firm Customer whose activity is recorded in the Segregated Indirect Participants Account.
- Agent Clearing trades that have not been recorded in a segregated account, are net-margined with other Agent Clearing trades in that Agent Clearing Member Omnibus Account.
- Irrespective of whether the Agent Clearing Trades are gross- or net-margined, the ACMs are responsible for posting margin to FICC arising from Agent Clearing trades of their Executing Firm Customers.
| Category | Agent Clearing Member | Executing Firm Customer |
| Participant Type | Direct Participant | Indirect Participant |
| Membership Type | Agent Clearing Members are direct participants of FICC as Netting Members of FICC/GSD. | Executing Firm Customers are not members of FICC |
| Qualification | Must be a FICC/GSD Netting Member that has established a relationship with its Executing Firm Customer(s) pursuant to the GSD Rules. | N/A |
| Jurisdictions | Agent Clearing Members must be from a FICC-approved jurisdiction. | N/A |
| Onboarding | A CCR Questionnaire and all applicable documents to become a FICC/GSD Netting Member; no additional onboarding is currently necessary to act as an Agent Clearing Member. Must provide FICC with documentation of its relationship and authorization from its Executing Firm Customer(s), which includes the Executing Firm Customer(s)’ executing symbol and LEI. | An Agent Clearing Member must provide FICC with documentation of its relationship and authorization from its Executing Firm Customer(s), which includes the Executing Firm Customer(s)’ executing symbol and LEI. |
| Liability to FICC with respect to Indirect Participant Trades | Agent Clearing Member acts as the processing agent of its Executing Firm Customer(s)’ trades (“Agent Clearing Trades”) and is liable for the performance of all obligations to FICC arising in connection with Agent Clearing Trades. | Executing Firm Customers have no liability to FICC. |
| FICC's liability with respect to Indirect Participant Trades | N/A | FICC has no liability to Executing Firm Customers. |
| Default Considerations (Third Party GSD Netting Member Default) | Agent Clearing Members are responsible for any loss allocation obligations of the Netting Member Accounts through which the Agent Clearing Trades of their Executing Firm Customers are processed. | Executing Firm Customers are not responsible for any loss allocation obligations. |
| Customer Trade Execution | Agent Clearing Members are permitted but not required to act as the pre-novation counterparty to their own Executing Firm Customer(s). | Executing Firm Customers can execute with any Netting Member, including their Agent Clearing Member or customer of any Netting Member in clearing. |
| Customer Trade Submission | Agent Clearing Members act as the processing agent for their Executing Firm Customer(s) and submit to FICC their Executing Firm Customer(s)’ side of a trade. | Agent Clearing Trades are submitted to FICC by Agent Clearing Members. |
| Margin Calculation | Agent Clearing Trades may be gross- or net-margined with other Agent Clearing Trades in the Agent Clearing Member’s Omnibus Account. | Agent Clearing Trades that are net-margined, are calculated at the Agent Clearing Member’s Omnibus Account level. Agent Clearing Trades that are gross-margined, are calculated at the individual Executing Firm Customer within the Agent Clearing Member’s Omnibus Account. |
| Responsible Party to FICC for Margin Posting | Agent Clearing Members are responsible for posting margin to FICC arising from Agent Clearing Trades of their Executing Firm Customers. | Executing Firm Customers are not responsible for posting margin to FICC. |
| Reporting |
FICC provides real-time trade status messages, reporting to the Agent Clearing Member of its Agent Clearing Trades. Agent Clearing Trades reports include: Compared and Uncompared Trade Report at the Executing Firm Customer level Intraday and EOD VaR report at the Executing Firm Customer level. |
FICC provides all reporting related to Agent Clearing Trades to the Agent Clearing Member |
| CCLF | Agent Clearing Members are responsible to FICC for CCLF obligations arising from settlement obligations in their Agent Clearing Member Omnibus Accounts through which the Agent Clearing Trades of their Executing Firm Customers are processed. | Executing Firm Customers are not responsible to FICC for CCLF obligations. |
| FICC Fees | Agent Clearing Members are responsible for FICC fees arising from Agent Clearing Trades | Executing Firm Customers are not responsible for FICC fees. |
Please visit the DTCC Client Center at https://www.dtcc.com/client-center.
- Scroll down to the Clearing & Settlement Services header and click Fixed Income - GSD for area-specific contact information.
You can also visit the U.S. Treasury Clearing microsite at https://www.dtcc.com/ustclearing.