Collateral mobility, regulatory readiness, and structural changes in the US market
14 October 2026
BNY’s Nate Wuerffel, global head of market structure and head of product, Global Collateral, discusses the regulatory environment in the US, its impact on collateral, and how the firm is working with clients to not only meet today’s requirements, but to adapt as market structures evolve
Image: BNY
As we head toward the end of 2026, market participants are navigating a shifting collateral landscape. Exemptive relief for the US Securities and Exchange Commission (SEC) Rule 15c3-3, which took effect on 30 June 2026, has expanded the collateral that broker-dealers can pledge when borrowing securities, creating new opportunities to use eligible equities more flexibly.
At the same time, the SEC extensions to central clearing implementation deadlines, now set for 31 December 2026, for eligible cash Treasury transactions and 30 June 2027, for eligible repo transactions, have given firms more time to prepare, but that window is narrowing.
According to The ValueExchange’s 2026 U.S. Treasury Central Clearing Pulse Survey, 86 per cent of firms are confident they will be ready for the upcoming deadlines, although firms are comparatively less confident in their readiness for the repo implementation timeline. But readiness varies considerably by firm type and region, with dealers ahead of buy side participants, and non-US jurisdictions less confident than those in the US.
Alongside these regulatory changes, the shift toward 24/7 trading, faster settlement, and growing collateral volume is increasing the importance of mobility and optimisation — and raising the stakes for trusted and resilient infrastructure that can keep pace. As firms look ahead to 2027, the challenge is shifting from having eligible collateral to deploying it effectively.
SEC Rule 15c3-3: Equity eligibility expansion
The updates to SEC Rule 15c3-3 represent a major change to securities lending markets in the US. The most significant aspect of the rule change is the expansion of equity collateral eligibility in certain securities borrowing transactions, giving firms more flexibility in how they deploy available collateral and optimising the use of existing asset pools.
For some market participants, the changes may also influence how those transactions are structured. Notably, the expansion aligns the US with international markets where equities are already widely accepted as collateral today.
Implementing those changes, however, requires careful coordination across operations, liquidity, and collateral management. With the updated rule now in place, firms are assessing how newly eligible equity collateral can be incorporated into their funding and securities finance activity.
Managing equity collateral through bilateral arrangements can be operationally intensive and difficult to scale. Participants must independently deliver eligible equity collateral to each counterparty and continuously manage mark-to-market obligations throughout the lifecycle of every transaction, which may create inefficiencies for both borrowers and lenders.
These processes can be streamlined through triparty, which helps to address the operational inefficiencies by offering independent valuation, sophisticated eligibility criteria, and supporting collateral allocation across collateral liabilities in the trading portfolio.
BNY’s Global Collateral platform — a proven triparty infrastructure supporting US$8.2 trillion in balances across 1,700 clients globally — enables firms to incorporate eligible equities into funding and securities finance activity at scale.
Collateral in a broader clearing landscape
As the market moves closer to mandatory US Treasury clearing, firms will need to manage collateral, liquidity, and clearing demands in a more tightly coordinated way. That challenge is becoming more complex as the US Treasury clearing landscape broadens with the launches of CME and ICE’s US Treasury central counterparties (CCPs).
While broader participation across CCPs may create new efficiencies and netting opportunities over time, it also introduces complexity in evaluating and operationalising multiple clearing frameworks.
As clearing activity grows, margin demands are becoming larger, drawing on the same high-quality liquid assets (HQLAs) that firms rely on for funding and liquidity management. This makes it essential to understand not only how much collateral is available, but where it is held, how quickly it can be accessed, and whether it can be deployed effectively against clearing obligations as they arise. As a result, the market has looked to create efficiencies around the margin and capital requirements created by mandatory clearing.
This has led to innovative new clearing models, including the Fixed Income Clearing Corporation’s (FICC’s) Sponsored GC Collateral-in-Lieu (CIL) model, accessible on the BNY Global Collateral platform, which addresses a specific inefficiency in sponsored clearing known as double margining, where cash lenders post margin to their sponsoring member who then posts margin to FICC on the same transaction. Instead of collecting initial margin, CIL uses a lien on the US Treasury collateral delivered at the start leg of the repo, eliminating double margining and removing the Sponsoring Member guarantee requirement — reducing capital pressure on intermediaries and lowering the cost of participation for cash providers.
FICC launched the CIL service in December 2025, which supports the triparty collateral mechanics, eligibility testing and settlement workflows the model requires. In addition to FICC clearing models, BNY’s Global Collateral platform will be connected to clearing models with CME and ICE, allowing market participants to choose from different clearing models and centralise their collateral management across clearing obligations.
Why collateral mobility matters in a 24/7 environment
Evolving requirements and a rapidly growing asset pool mean that collateral availability alone is no longer enough. In many cases, the decisive factor is whether firms can access and mobilise assets efficiently.
Access and mobilisation depend first on visibility across fragmented asset pools, which continue to present a common constraint. Many institutions hold collateral across multiple accounts, legal entities, custodians, and servicing models, each with its own rules, settlement cycles, and access considerations. Without a consolidated view of what is available and where, firms can find it harder to identify the most efficient source of collateral for a given obligation and may instead rely on larger precautionary buffers.
Location remains central to the challenge. Collateral may exist in the right form, but if it sits in the wrong account, with the wrong custodian, in the wrong venue, or in the wrong jurisdiction, it may not be available when needed. This is where collateral mobility becomes critical, enabling firms to reposition assets from where they are held to where they are needed. When that process is disjointed or highly manual, delays, substitution costs, and operational risk can increase; when it is more integrated and automated, firms are better positioned to manage collateral proactively.
The shift towards 24/7 markets is making this challenge more acute. As operating windows extend, the time available to identify, mobilise, and deliver collateral narrows — and the cost of delay grows. BNY’s always-on initiative is designed to meet that challenge directly. As one of the largest custodians of US Treasury securities, holding approximately one-third of the market, BNY is building the infrastructure for clients to trade, settle, and finance Treasuries around the clock, on both traditional and digital rails.
This dual-rails strategy reflects the reality that traditional and tokenised assets will coexist for the foreseeable future, and that mobility across both, seamlessly and in real time, is what will allow firms to operate continuously rather than within fixed settlement windows. BNY’s Global Collateral platform is designed to support that mobility.
Many of the practical gains lie in reducing friction across the mobilisation process. Each step, from identification and qualification criteria to substitution and settlement, can add time and complexity. Firms that streamline these processes through automation and more integrated workflows are likely to be better placed to mobilise collateral quickly, reduce excess buffers, and respond more effectively to margin calls, settlement demands, and other time-sensitive obligations.
Together, these constraints make collateral mobility increasingly central to liquidity management, funding efficiency, regulatory readiness, and central clearing.
Preparing for the next phase
The next phase will test whether firms can translate regulatory preparation and infrastructure investment into a more coordinated approach to collateral management.
As these capabilities shift from differentiators to requirements, the institutions best positioned for the period ahead will be those that can embed them across their operating model and respond efficiently as obligations arise across venues and time zones.
For BNY, these developments point directly to the role of the Global Collateral platform which is designed to help institutions manage collateral obligations across both cleared and uncleared markets for an increasingly flexible range of trade types — from a single platform.
By bringing these workflows together, the platform drives efficiencies across collateral allocation, mobilisation, and optimisation, positioning clients not just to meet today’s requirements, but to adapt as market structures continue to evolve.
At the same time, the SEC extensions to central clearing implementation deadlines, now set for 31 December 2026, for eligible cash Treasury transactions and 30 June 2027, for eligible repo transactions, have given firms more time to prepare, but that window is narrowing.
According to The ValueExchange’s 2026 U.S. Treasury Central Clearing Pulse Survey, 86 per cent of firms are confident they will be ready for the upcoming deadlines, although firms are comparatively less confident in their readiness for the repo implementation timeline. But readiness varies considerably by firm type and region, with dealers ahead of buy side participants, and non-US jurisdictions less confident than those in the US.
Alongside these regulatory changes, the shift toward 24/7 trading, faster settlement, and growing collateral volume is increasing the importance of mobility and optimisation — and raising the stakes for trusted and resilient infrastructure that can keep pace. As firms look ahead to 2027, the challenge is shifting from having eligible collateral to deploying it effectively.
SEC Rule 15c3-3: Equity eligibility expansion
The updates to SEC Rule 15c3-3 represent a major change to securities lending markets in the US. The most significant aspect of the rule change is the expansion of equity collateral eligibility in certain securities borrowing transactions, giving firms more flexibility in how they deploy available collateral and optimising the use of existing asset pools.
For some market participants, the changes may also influence how those transactions are structured. Notably, the expansion aligns the US with international markets where equities are already widely accepted as collateral today.
Implementing those changes, however, requires careful coordination across operations, liquidity, and collateral management. With the updated rule now in place, firms are assessing how newly eligible equity collateral can be incorporated into their funding and securities finance activity.
Managing equity collateral through bilateral arrangements can be operationally intensive and difficult to scale. Participants must independently deliver eligible equity collateral to each counterparty and continuously manage mark-to-market obligations throughout the lifecycle of every transaction, which may create inefficiencies for both borrowers and lenders.
These processes can be streamlined through triparty, which helps to address the operational inefficiencies by offering independent valuation, sophisticated eligibility criteria, and supporting collateral allocation across collateral liabilities in the trading portfolio.
BNY’s Global Collateral platform — a proven triparty infrastructure supporting US$8.2 trillion in balances across 1,700 clients globally — enables firms to incorporate eligible equities into funding and securities finance activity at scale.
Collateral in a broader clearing landscape
As the market moves closer to mandatory US Treasury clearing, firms will need to manage collateral, liquidity, and clearing demands in a more tightly coordinated way. That challenge is becoming more complex as the US Treasury clearing landscape broadens with the launches of CME and ICE’s US Treasury central counterparties (CCPs).
While broader participation across CCPs may create new efficiencies and netting opportunities over time, it also introduces complexity in evaluating and operationalising multiple clearing frameworks.
As clearing activity grows, margin demands are becoming larger, drawing on the same high-quality liquid assets (HQLAs) that firms rely on for funding and liquidity management. This makes it essential to understand not only how much collateral is available, but where it is held, how quickly it can be accessed, and whether it can be deployed effectively against clearing obligations as they arise. As a result, the market has looked to create efficiencies around the margin and capital requirements created by mandatory clearing.
This has led to innovative new clearing models, including the Fixed Income Clearing Corporation’s (FICC’s) Sponsored GC Collateral-in-Lieu (CIL) model, accessible on the BNY Global Collateral platform, which addresses a specific inefficiency in sponsored clearing known as double margining, where cash lenders post margin to their sponsoring member who then posts margin to FICC on the same transaction. Instead of collecting initial margin, CIL uses a lien on the US Treasury collateral delivered at the start leg of the repo, eliminating double margining and removing the Sponsoring Member guarantee requirement — reducing capital pressure on intermediaries and lowering the cost of participation for cash providers.
FICC launched the CIL service in December 2025, which supports the triparty collateral mechanics, eligibility testing and settlement workflows the model requires. In addition to FICC clearing models, BNY’s Global Collateral platform will be connected to clearing models with CME and ICE, allowing market participants to choose from different clearing models and centralise their collateral management across clearing obligations.
Why collateral mobility matters in a 24/7 environment
Evolving requirements and a rapidly growing asset pool mean that collateral availability alone is no longer enough. In many cases, the decisive factor is whether firms can access and mobilise assets efficiently.
Access and mobilisation depend first on visibility across fragmented asset pools, which continue to present a common constraint. Many institutions hold collateral across multiple accounts, legal entities, custodians, and servicing models, each with its own rules, settlement cycles, and access considerations. Without a consolidated view of what is available and where, firms can find it harder to identify the most efficient source of collateral for a given obligation and may instead rely on larger precautionary buffers.
Location remains central to the challenge. Collateral may exist in the right form, but if it sits in the wrong account, with the wrong custodian, in the wrong venue, or in the wrong jurisdiction, it may not be available when needed. This is where collateral mobility becomes critical, enabling firms to reposition assets from where they are held to where they are needed. When that process is disjointed or highly manual, delays, substitution costs, and operational risk can increase; when it is more integrated and automated, firms are better positioned to manage collateral proactively.
The shift towards 24/7 markets is making this challenge more acute. As operating windows extend, the time available to identify, mobilise, and deliver collateral narrows — and the cost of delay grows. BNY’s always-on initiative is designed to meet that challenge directly. As one of the largest custodians of US Treasury securities, holding approximately one-third of the market, BNY is building the infrastructure for clients to trade, settle, and finance Treasuries around the clock, on both traditional and digital rails.
This dual-rails strategy reflects the reality that traditional and tokenised assets will coexist for the foreseeable future, and that mobility across both, seamlessly and in real time, is what will allow firms to operate continuously rather than within fixed settlement windows. BNY’s Global Collateral platform is designed to support that mobility.
Many of the practical gains lie in reducing friction across the mobilisation process. Each step, from identification and qualification criteria to substitution and settlement, can add time and complexity. Firms that streamline these processes through automation and more integrated workflows are likely to be better placed to mobilise collateral quickly, reduce excess buffers, and respond more effectively to margin calls, settlement demands, and other time-sensitive obligations.
Together, these constraints make collateral mobility increasingly central to liquidity management, funding efficiency, regulatory readiness, and central clearing.
Preparing for the next phase
The next phase will test whether firms can translate regulatory preparation and infrastructure investment into a more coordinated approach to collateral management.
As these capabilities shift from differentiators to requirements, the institutions best positioned for the period ahead will be those that can embed them across their operating model and respond efficiently as obligations arise across venues and time zones.
For BNY, these developments point directly to the role of the Global Collateral platform which is designed to help institutions manage collateral obligations across both cleared and uncleared markets for an increasingly flexible range of trade types — from a single platform.
By bringing these workflows together, the platform drives efficiencies across collateral allocation, mobilisation, and optimisation, positioning clients not just to meet today’s requirements, but to adapt as market structures continue to evolve.
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