Operational Resilience / Outsourcing in United States

What Changed

The primary regulatory modification addresses a single-day exception to standard options exercise procedures: CEA Cut-Off Time Acceleration: The normal 5:30 p.m. ET deadline for submitting Contrary Exercise Advice was compressed to 10:00 a.m. ET on January 9, 2025. Exercise Instruction Acceptance Window: Members could not accept exercise instructions for either customer or non-customer accounts after 10:00 a.m. ET on that date. OCC Processing Unchanged: The Options Clearing Corporation's proc

What You Need To Do

• *Update Internal Procedures
• *System Configuration
• *Staff Communication
• *Customer Notification
• *Submission Coordination

Key Dates

References

• [1] finra.org
• [2] finra.org
• [3] finra.org
• [4] finra.org
• [5] finra.org
• [6] finra.org
• [7] finra.org
• [8] sec.gov

What Changed

Removal of Settle Prep Day: NSCC Rule 50 amended to eliminate the settlement preparation stage from ACATS, effective October 17, 2025, streamlining the process for all securities transfers.[original notice] Mutual Fund/Options Synchronization: Eliminates the extra day for processing mutual funds and options via Fund/SERV, aligning their settlement with other assets; also removes the second day of Fund/SERV pending acknowledgment.[original notice] Overall Timeline Reduction: Full ACATS transfers

What You Need To Do

• Operational Readiness
• Exception Handling
• System Updates
• Contact FINRA/NSCC

Key Dates

References

• [1] ftfnews.com
• [2] finra.org
• [3] advisorfinder.com
• [4] finra.org
• [5] sec.gov
• [6] finra.org
• [7] finra.org
• [8] sec.gov

What Changed

The final rule introduces the following substantive amendments: *Exceptions for Swaps Intended to be Cleared (ITBC Swaps)** Swap dealers and major swap participants are exempted from certain External Business Conduct Standards and swap trading relationship documentation requirements when executing swaps that are intended by the parties to be cleared contemporaneously with execution. Such swaps are deemed void if rejected from clearing. *Prime Broker Arrangement Exemptions** Swaps executed purs

What You Need To Do

• *Immediate Actions (Pre-Implementation)
• *Implementation Actions (Upon Effective Date)
• trade disclosure systems to remove PTMMM generation and delivery requirements
• based operations, review implications of superseded Staff Letter No
• *Ongoing Compliance

Key Dates

References

• [1] cftc.gov
• [2] cftc.gov
• [3] isda.org
• [4] gibsondunn.com
• [5] sifma.org
• [6] skadden.com