CFTC trust-company settlement relief

What changed

CFTC staff granted conditional no-action relief for clearing organizations using trust companies for daily settlements on November 5, 2026. Clearing organizations must treat those companies as settlement banks under Regulations 39.14(c) and (d). Nodal Clear requested the relief to support digital-asset collateral movements. Staff’s position does not bind the Commission.

Who it affects

• Clearing organizations and clearing members can assess trust companies for covered settlement arrangements.

What is still open

• Staff retains authority to modify or terminate the relief.
• Clearing organizations must separately satisfy other requirements governing digital-asset collateral.

What it means for an advisor

• Ask clearing providers how they evaluate trust companies and confirm collateral eligibility before changing client margin arrangements.