Government debt: the collateral chain

WHO HOLDS GOVERNMENT DEBT? · Part 4

A fund’s lender may itself borrow against the same bonds. Behind the collateral, a sequence of contracts, rights and deadlines determines how long funding remains available.

On December 23, 2025, three companies announced a transaction in the plumbing of the US government bond market. BNY Securities Finance and Federated Hermes had used a new service offered by FICC, the DTCC clearing house. Its name, Collateral-in-Lieu, sounds like a line on an administrative form. Its purpose is more substantial: when a repo already contains securities that provide protection, why tie up additional resources elsewhere? The announcement identified neither the loan amount nor the specific legal fund providing cash. It reported a first transaction and claimed a more efficient use of collateral. ^[1]

Eleven days earlier, the Securities and Exchange Commission had approved the arrangement. Its order sets out the participants’ obligations, the treatment of defaults and the conditions for accessing the securities. FICC’s rulebook dated August 26, 2026 provides an operative cross-check. Together, these documents show a change taking place behind government borrowing: the way investors lend to each other against public debt. ^[2][3]

The first three parts followed the bond’s issuance, the intermediary’s balance sheet, and the fund buying it with borrowed money. The next step is to examine the lender. That lender may also be borrowing. Securities then move between accounts while claims, deadlines and legal rights accumulate around them. Assessing the chain requires knowing who supplies the cash, for how long, and what each participant is entitled to recover.

The cash behind the loan

A money market fund pools investors’ cash for investment in short-term instruments. Repo is one outlet: the fund supplies cash against securities, with a subsequent reversal agreed between the parties. A New York Fed analysis published on September 28, 2026 places money funds’ private repo lending at roughly $1 trillion in January 2021 and $3 trillion in January 2026. These rounded figures are amounts outstanding, not money advanced over the course of a year. ^[4]

The money fund needs a place for its cash. At the other end of the market, a relative-value fund needs cash to finance its portfolio. A dealer structures transactions around their different requirements. Here, “dealer” means a market intermediary, often part of a banking group. It can lend to one customer and finance that claim with another counterparty. The New York Fed describes the connections by separating securities transfers, their operational management and the clearing of obligations. ^[5]

This adds another dimension to the question of who holds government debt. The bond buyer carries the economic exposure. The cash provider makes a shorter commitment secured against those securities. The intermediary connects the two. Each participates for a different reason, with a different incentive to stay.

Aggregate data identify groups of participants. They do not trace each dollar through named counterparties. Attributing the money funds’ roughly $3 trillion entirely to hedge funds would go beyond the evidence. An explicit illustration lets us follow the obligations without inventing a private transaction.

A $100 million portfolio supports two loans

A fund buys $100 million of bonds. As in the previous episode, it borrows $99 million in repo and contributes $1 million towards the purchase. The separate $1 million futures initial-margin deposit and $1 million cash reserve used in that earlier example remain outside the chain shown here. The fund still has $3 million of its own resources; we are isolating purchase financing.

The dealer advances the $99 million. To do so, it borrows $98 million from a money market fund and adds $1 million of its own cash. Securities received from the relative-value fund secure this second repo. The illustration holds bond prices constant and leaves out coupons, interest and margin movements to make the financing obligations visible.

The purchase is therefore supported by $98 million from the cash provider outside this chain, $1 million from the dealer and $1 million from the buyer. Yet the two repo contracts contain $197 million of gross principal, $99 million on one side and $98 million on the other. That sum measures successive claims. The underlying bond portfolio is still worth $100 million.

This distinction matters when reading market totals. Adding loans along a chain can help measure the commitments of its members. Treating their sum as the amount of government bonds involved would inflate the underlying portfolio. Looking only at the $100 million of securities, meanwhile, would conceal the payments owed between intermediaries. Each measure answers a different question.

The Financial Stability Board emphasises both the efficiency of collateral reuse and the connections it creates. Intermediation connects funding and investment needs that do not always match directly. With it, funding availability depends on several relationships operating together. ^[6]

Ownership moves; the exposure remains

Language about “pledging collateral” can suggest that the securities remain locked in the original holder’s name. French law governing pension livrée, the domestic form of repo, provides a different structure. Article L. 211-27 of the Monetary and Financial Code describes an outright transfer of ownership with reciprocal, irrevocable commitments to repurchase and return the securities at an agreed date and price. ^[8]

The accounting treatment follows the financing. Article L. 211-32 keeps the securities on the seller’s balance sheet and records the debt to the buyer as a liability. Legal title can therefore move while the bond remains recorded by the party financing it. This French treatment illustrates the distinction; a US transaction still requires examination of its own contract and applicable accounting standards. ^[9]

In our chain, the securities received by the dealer support its own borrowing. At maturity, equivalent securities must be returned under the agreement. That contractual obligation matters more than following an individual paper certificate. ICMA, the bond-market trade association, distinguishes repo’s transfer of ownership from rehypothecation, the reuse of pledged assets. Its explanation should be read alongside the law, rather than treated as a universal legal assurance. ^[11]

Within the European Union, Article 15 of the Securities Financing Transactions Regulation sets conditions for reuse. They include written information on risks and consequences, prior express consent to a right of reuse or express agreement to title transfer, and compliance with agreed terms. The information must address, among other things, the consequences of the collateral recipient’s default. Stricter restrictions can also apply. ^[10]

This is where the documentary problem becomes apparent. A map linking “bank”, “fund” and “custodian” cannot establish whether a security may be transferred again, on what terms, or for whose benefit. Answering those questions for a particular portfolio would require the executed agreements and their annexes. Public sources reveal rules and categories of transaction. They do not disclose every negotiated clause.

The dealer’s calendar

Give our two loans different maturities. The dealer advances $99 million for thirty days, while borrowing its $98 million for one day. At the first deadline, it owes the principal on the shorter loan, plus the contractual interest excluded from this illustration. Its claim on the fund will not mature until day thirty.

Even with a perfectly stable bond price and a solvent customer, the dealer must obtain cash. It can arrange another loan, use alternative funding or draw on liquid resources. The portfolio does not have to fall in value for this task to arise. The mismatch in commitments creates it.

That alone does not entitle the dealer to demand early repayment of a firm thirty-day loan. Default, margin and termination provisions must be assessed separately. An open repo, which has no fixed maturity, has a different structure again: termination follows the agreed notice provisions. Treating it as interchangeable with any loan renewed overnight would erase an important contractual distinction. ^[12]

The Office of Financial Research examined maturities across nine dealers’ portfolios on three dates in June 2022. Its November 2024 brief matches collateral received and reused across four maturity buckets. These statistical matches, by dealer and CUSIP security identifier, use allocation conventions; they do not trace every contract individually. $48.68 billion sits in a particular combination: securities received against loans lasting eight to thirty days, then reused to obtain overnight funding. The sample spans several repo segments and collateral categories, rather than Treasuries alone. ^[7]

Regrouping the published cells gives $172.93 billion where funding falls into a shorter bucket than the loan, against $72.28 billion in the opposite direction, a ratio of 2.39. Same-bucket matches account for $359.12 billion. Even those can contain different actual dates: two transactions labelled “eight to thirty days” need not mature together. ^[7]

These are observations from a limited historical sample, not a measure of positions in October 2026. They make a financing choice visible. An intermediary can give its customer more time than it obtains from its own lender. It provides a service while retaining the task of refinancing. Evaluating its resilience would then require its liquidity resources, other funding providers and committed facilities.

Zero haircuts and negotiated protection

The loan amount relative to the securities’ value is another negotiation. In our example, advancing 99 against 100 of collateral produces a 1% financing discount, or haircut. It leaves a cushion for the lender if the securities must be sold at an unfavourable price. At the next link, the dealer borrows 98 against the same 100, implying a 2% haircut.

In August 2025, the OFR published results from its collection on non-centrally cleared bilateral repo. On a daily-average basis from January 2 to May 30, 2025, across all collateral types, 56% of outstanding balances had a zero haircut, 34% a positive haircut and 10% a negative one. Excluding affiliated counterparties, the zero-haircut share was 42%. A negative haircut here means the cash lent exceeds the securities’ value. Excluding affiliates changes the denominator; it does not show a decline over time. ^[13]

A zero haircut describes the relationship between cash and securities within the transaction. Other protections may apply to the portfolio, the counterparty or an agreement allowing several obligations to be closed out together. A Federal Reserve study on proportionate margining considers these offsets and the risks faced on both sides. The original holder of the security, now borrowing cash, also needs the asset returned. ^[14]

The next question is what legal rights and resources the lender relies on when the visible haircut is small. An attractive economic hedge on a trading screen provides legal protection only to the extent that it can be used under the governing contracts. Comparing haircuts outside that broader portfolio context supplies a reason to investigate, rather than a complete ranking of risk.

Commercial incentives deserve scrutiny nonetheless. In a thematic review published on October 5, 2023, the UK’s Prudential Regulation Authority identified practices in which certain important clients’ haircuts were not subject to independent risk approval, alongside the influence of market conventions and commercial pressure. That historical review concerned the firms examined. It did not provide a list of institutions to accuse of the same conduct today. ^[15]

The question remains current. In a piece published on July 17, 2026, Bank of England deputy governor Sarah Breeden recognised the value of portfolio offsets while stressing legal robustness, stress assessment and governance. Attractive financing helps win customers. Its protection must still work when the positions involved stop moving conveniently together. ^[16]

Existing collateral, additional margin

Return to the transaction announced in December 2025. It belongs to a structure in which a cash lender can use both a collateral-management agent and central clearing. Those are different functions. A tri-party agent manages accounts and the agreed transfers. A central counterparty interposes itself in the obligations it accepts, applying its own protection framework. A custodian’s presence alone does not make it the guarantor of a loan. ^[5]

In FICC’s Sponsored GC service, the lender accepts securities from an eligible pool. The initial exchange of cash for securities settles away from the clearing house. The return leg is novated once submission, matching and initial-leg settlement conditions are met: the original return obligations are replaced with obligations involving FICC under its rules. The earlier structure described by the SEC could combine collateral already delivered to the lender, a guarantee from its sponsor, the member providing access to FICC, and additional margin resources. ^[2]

Collateral-in-Lieu offers another route for the relevant cash lender obligations. The lender grants FICC a security interest in the securities held in its tri-party account. The rulebook governs the use of that protection in place of certain requirements separately involving the sponsor and margin. The clearing house can rely on the transaction’s existing collateral. Access conditions and provisions for additional resources remain. ^[2][3]

A second, independent illustration makes the calculation clear: $100 million in cash against $102 million in securities. The minimum 2% CIL haircut is defined relative to the initial cash amount. It therefore requires $2 million of additional securities. Relative to the $102 million of collateral, that difference is approximately 1.96%. The denominator explains the difference from the convention used in our first scenario. The rulebook requires at least thirty business days’ notice of changes to the required haircut and excludes already novated trades from those changes. That boundary separates future financing terms from accepted commitments. ^[3]

The operators’ claimed saving comes from reducing additional resource requirements when this protection can be recognised. It could make some transactions cheaper or support more activity with given resources. The launch announcement measures neither the effect on prices nor its market-wide scale. It cannot support a quantified claim about the collective benefit. ^[1]

The security interest also depends on careful legal engineering. The rulebook annex governs custodian instructions, collateral withdrawals and the effects of default notices. Transfers and releases must respect the prescribed settlement conditions. FICC’s rights do not amount to unrestricted access to the securities while ignoring cash owed to the lender. The arrangement is designed to permit completion of the transaction despite a participant’s failure. ^[3]

The change in protection is the key point. In our first chain, collateral reuse supports a second repo and supplies additional financing. Under CIL, a security interest for the clearing house uses securities already present to protect the cleared transaction. Asset circulation and the allocation of rights serve different purposes. A diagram showing one bond connected to several corporate logos would conceal that distinction.

Settlement of accepted obligations

What does this architecture offer the investor holding government debt? Better-organised performance of accepted obligations, subject to the clearing house’s rules and resources. A fund seeking to keep its portfolio beyond maturity still needs the next financing transaction. The contract ending today and the possible contract starting tomorrow remain separate decisions.

Consider the dealer’s $98 million again. Effective clearing can support completion of today’s transaction. It cannot compel the money fund to lend again thirty seconds later. The clearing house can facilitate transfers and manage accepted risks without taking responsibility for all its members’ future plans. Confusing reliable settlement with a revolving credit commitment would erase the calendar we have just reconstructed.

That calendar meets the timetable of US market reform. The SEC set compliance dates of December 31, 2026 for covered cash-market transactions and June 30, 2027 for eligible repos. As of October 11, 2026, both are still ahead. Eligibility conditions matter: the requirement does not apply uniformly to every transaction involving US government debt. ^[18]

The move into clearing is not a smooth upward progression. In an August 20, 2026 post, the OFR reported a 72% peak at year-end 2025, followed by a plateau around 62%, for fixed-term Treasury repos between non-affiliated counterparties. Its observations run through April 23, 2026. Across the broader universe of all Treasury repo, the plateau is close to 46%. Those shares describe different populations. The fixed-term, non-affiliated subset approximates the reform’s scope; it does not account for every regulatory exclusion. ^[19]

A retreat from a year-end peak cannot, on its own, establish the reform’s outcome. Funding choices, changes in the market’s composition and calendar effects can all contribute. Nor can that pattern be attributed to CIL simply because its launch occurred around the same time. The published observations do not isolate the service’s causal contribution.

Commercial arrangements are still adapting. On July 30, 2026, SIFMA published a model clearing agreement for done-away transactions, in which the executing intermediary and clearing provider can be different firms. A template helps parties negotiate responsibilities. It does not establish that every investor has found a provider, or that the agreements ultimately signed have identical terms. ^[20]

Protection has a funding cost

Requiring more margin can look prudent when examining one transaction. The next questions are where the necessary assets will come from, when they will be available and how the requirement will change the price or duration of credit. Protecting one lender meets the functioning of the wider market at precisely that point.

In its feedback statement published on April 1, 2026, the Bank of England set out the debate on gilt repo resilience. Responses raised the costs of haircut floors and possible migration of activity. Several issues attracted little quantitative evidence. Work planned for 2026 and possible proposals in early 2027 do not constitute an adopted minimum haircut. ^[17]

The Financial Policy Committee record published on September 30, 2026 confirms that work on central clearing and minimum haircuts is continuing. Proposals are still envisaged for early 2027; policy development remains under way. ^[21]

The objections deserve testing even when raised by participants with a commercial interest in favourable financing. Depending on its calibration, a rule making longer loans much more expensive could encourage shorter borrowing. This conditional argument describes an effect to test. It would strengthen one cushion while increasing the frequency of refinancing. Conversely, accepting every proposed portfolio offset without scrutiny could make protection depend on correlations that weaken under stress. The comparison must include these competing effects without inventing their numerical importance.

The name of a bondholder can no longer carry the whole explanation of demand for government debt. It needs to be accompanied by a funding chain and a calendar of rights. The bond can remain sound while a lender wants its cash back. An intermediary can honour its customer’s contract while searching for replacement funding. A clearing house can protect accepted obligations without promising to extend them.

The next episode will follow the moment when this architecture creates a specific demand: deliver additional cash or securities by a particular deadline. One distinction already improves the reading of the market: collateral requirements and funding duration are negotiated separately. The chain’s resilience depends on how they fit together.

Method and scope

This episode draws on institutional publications, market rules and legislation accessed on October 11, 2026. The $100 million transactions are hypothetical. The OFR matrix’s 16 cells were transcribed and regrouped by maturity bucket; the cells below the diagonal sum to $172.93 billion and those above it to $72.28 billion, giving 172.93 / 72.28 ≈ 2.39. The diagonal totals $359.12 billion; all 16 cells total $604.33 billion. No interviews, executed private contracts or confidential portfolios are represented as obtained. CIL’s operators supplied the launch announcement; the SEC approval and FICC rulebook were used to cross-check the mechanics. Date, coverage and collection limitations are stated in the text, captions and references below.

Sources and reading notes

1. [1] DTCC / BNY / Federated Hermes. DTCC’s FICC and BNY Launch Collateral-in-Lieu ServicePublication : December 23, 2025. Period / scope : First trade announced on December 23, 2025.https://www.bny.com/corporate/global/en/about-us/newsroom/press-release/dtccs-ficc-and-bny-launch-collateral-in-lieu-service-via-bnys-global-collateral-platform.html Joint participant announcement. BNY Securities Finance and Federated Hermes are named, but no trade amount or specific legal fund is disclosed. Claimed benefits are not independently measured outcomes.
2. [2] SEC. Order approving SR-FICC-2025-019, Release 34-104374APublication : December 12, 2025. Period / scope : Regulatory approval dated December 12, 2025; CIL design.https://www.sec.gov/files/rules/sro/ficc/2025/34-104374a.pdf Final approval order, not merely a proposal. The Sponsored GC start leg settles away from FICC; the end leg is novated. Exceptions and additional resources remain.
3. [3] FICC / DTCC. Government Securities Division Rulebook, as of August 26, 2026Publication : August 26, 2026. Period / scope : Rulebook version dated August 26, 2026, accessed October 11.https://files.dtcc.com/download/assets/FICC-GSD%2BRulebook%2B%E2%80%93%2B2026-0826%2BFinal.pdf/b6c07124ceb411f09c9062cd3fe05a01 Operative rulebook cross-check. CIL minimum uses initial cash as its base; changes require advance notice and do not apply to already novated trades. Custodian instructions and lien enforcement are constrained. Targeted reading, not an exhaustive audit of 381 pages. Current rulebook cross-check: FICC Government Securities Division Rulebook.
4. [4] Federal Reserve Bank of New York. Who’s Borrowing and Lending in Repo Markets?Publication : September 28, 2026. Period / scope : Private MMF repo lending: January 2021 and January 2026; rounded values.https://libertystreeteconomics.newyorkfed.org/2026/09/whos-borrowing-and-lending-in-repo-markets/ Approximately $1tn and $3tn in private lending outstanding. These are stocks, not annual flows or loans directly attributable solely to hedge funds. Authors’ views.
5. [5] Federal Reserve Bank of New York. Follow the Cash! Microstructure of Repo MarketsPublication : September 29, 2026. Period / scope : Repo market structure; observations published through Q1 2026.https://libertystreeteconomics.newyorkfed.org/2026/09/follow-the-cash-microstructure-of-repo-markets/ BNY acts as agent in uncleared tri-party repo. Separate collateral management from CCP counterparty risk. The older haircut statistic repeated in the post is not used; the OFR 2025 collection is preferred.
6. [6] Financial Stability Board. Vulnerabilities in Government Bond-backed Repo MarketsPublication : February 4, 2026. Period / scope : International review; main stocks at end-2024 and cited historical studies.https://www.fsb.org/uploads/P040226.pdf Reuse improves efficiency while creating interdependencies. Measurement conventions preclude treating every gross amount as unique securities. Global totals are not added to US data.
7. [7] Office of Financial Research. Repo Market Intermediation: Dealer Cash and Collateral Flow Management across the U.S. Repo Market, Brief 24-07Publication : November 14, 2024. Period / scope : Nine dealers; average of June 15, 22 and 30, 2022. Figure 8, matched reused collateral outstanding.https://www.financialresearch.gov/briefs/files/OFRBrief-24-07-repo-market-intermediation.pdf All 16 Figure 8 cells are transcribed. Their rounded sum is $604.33bn: lower triangle $172.93bn, upper triangle $72.28bn, diagonal $359.12bn. Maturity buckets do not identify exact maturity dates. No extrapolation to 2026.
8. [8] Légifrance. Code monétaire et financier, article L211-27Publication : undated page; version specified below. Period / scope : Version in force since January 3, 2018; accessed October 11, 2026. Event / version: January 3, 2018.https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000035727159 French law specifies outright title transfer and reciprocal repurchase/resale undertakings.
9. [9] Légifrance. Code monétaire et financier, article L211-32Publication : undated page; version specified below. Period / scope : Version in force since January 10, 2009; accessed October 11, 2026. Event / version: January 10, 2009.https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000020096114 The seller retains the security on its balance sheet and records a liability. French law illustrates the legal/accounting distinction; it does not settle every IFRS or US GAAP case.
10. [10] ESMA / Union européenne. SFTR, Article 15: Reuse of financial instruments received under a collateral arrangementPublication : undated page; version specified below. Period / scope : Regulatory text accessed October 11, 2026; Regulation (EU) 2015/2365.https://www.esma.europa.eu/publications-and-data/interactive-single-rulebook/sftr/article-15-reuse-financial-instruments Written risk information and express agreement, followed by conditions on exercise of reuse. Stricter sectoral and national rules remain applicable.
11. [11] ICMA. FAQ 10: What is “rehypothecation” of collateral?Publication : undated page; version specified below. Period / scope : Technical explanation accessed October 11, 2026; publication date not established.https://www.icmagroup.org/market-practice-and-regulatory-policy/repo-and-collateral-markets/icma-ercc-publications/frequently-asked-questions-on-repo/10-what-is-rehypothecation-of-collateral/ Interested industry source used for contractual conventions. Precise legal treatment depends on contract and jurisdiction; checked against SFTR and the FSB.
12. [12] ICMA. FAQ 12: What is an open repo?Publication : undated page; version specified below. Period / scope : Market convention accessed October 11, 2026; publication date not established.https://www.icmagroup.org/market-practice-and-regulatory-policy/repo-and-collateral-markets/icma-ercc-publications/frequently-asked-questions-on-repo/12-what-is-an-open-repo/ An open repo differs from a rolled overnight repo. Termination follows agreed notice; it does not make a fixed 30-day loan freely recallable.
13. [13] Office of Financial Research. Are Zero-Haircut Repos as Common as Advertised?Publication : August 12, 2025. Period / scope : Non-centrally cleared bilateral repo outstanding, all collateral; January 2–May 30, 2025.https://www.financialresearch.gov/the-ofr-blog/2025/08/12/are-zero-haircut-repos-as-common-as-advertised/ 56% zero, 34% positive, 10% negative. The zero share is 42% after affiliates are excluded: a different denominator, not a time trend. The separate 65% hedge-fund figure is documented but not foregrounded here.
14. [14] Federal Reserve Board. Proportionate margining for repo transactionsPublication : February 14, 2025. Period / scope : Methodological analysis by R. Jay Kahn and Matthew McCormick; not a new rule.https://www.federalreserve.gov/econres/notes/feds-notes/proportionate-margining-for-repo-transactions-20250214.html Both sides of repo face default risk. A uniform floor may miss portfolio offsets and securities-driven trades. This article’s hypothetical examples are separate.
15. [15] Bank of England / PRA. Fixed income financing thematic review: letter to Chief Risk OfficersPublication : October 5, 2023. Period / scope : Supervisory review published in 2023, including lessons from the 2022 LDI stress.https://www.bankofengland.co.uk/prudential-regulation/letter/2023/fixed-income-financing-thematic-review Anonymised findings at reviewed firms: commercial pressures and insufficient controls. They do not identify a named bank or establish that no remediation occurred later.
16. [16] Bank of England. Gilt edged resilience: strengthening liquidity provision in the repo marketPublication : July 17, 2026. Period / scope : Sarah Breeden article based on May 28, 2026 remarks; chart data subsequently updated. Event / version: May 28, 2026.https://www.bankofengland.co.uk/bank-insights/2026/gilt-edged-resilience-strengthening-liquidity-provision-in-the-repo-market Recognises portfolio-margining benefits while requiring robust legal documents, governance and stress tests. A central-bank position, not a causal estimate of reform effects.
17. [17] Bank of England. Enhancing the resilience of the gilt repo market: discussion paper feedback statementPublication : April 1, 2026. Period / scope : Feedback on the September 2025 consultation; work planned for 2026–27.https://www.bankofengland.co.uk/paper/2026/discussion-paper/enhancing-the-resilience-of-the-gilt-repo-market-discussion-paper-feedback-statement The consultation concerns potential reforms. Cost and activity-migration objections supplied limited quantitative evidence. No universal UK haircut obligation is portrayed as adopted.
18. [18] SEC. SEC Extends Compliance Dates and Provides Temporary Exemption for Rule Related to Clearing of U.S. Treasury SecuritiesPublication : February 25, 2025. Period / scope : Compliance timetable, cross-checked with SIFMA documentation from July 2026.https://www.sec.gov/newsroom/press-releases/2025-43-sec-extends-compliance-dates-provides-temporary-exemption-rule-related-clearing-us-treasury December 31, 2026 for eligible cash transactions; June 30, 2027 for eligible repos. These dates do not imply universal worldwide clearing. Timetable cross-checked against the SEC implementation page updated September 23, 2026: Treasury Clearing Implementation.
19. [19] Office of Financial Research. Central Clearing in Treasury Repos Plateaued in Q1 2026Publication : August 20, 2026. Period / scope : July 1, 2025–April 23, 2026; two distinct denominators.https://www.financialresearch.gov/the-ofr-blog/2026/08/20/central-clearing-treasury-repos-plateaued/ Non-affiliate fixed-term subset: 72% year-end 2025 peak, then about 62%. All Treasury repo: approximately 46% at the plateau. Simplified eligibility proxy, rounded values predating October. No causal attribution to CIL.
20. [20] SIFMA. SIFMA Publishes U.S. Treasury Done-Away Securities Clearing AgreementPublication : July 30, 2026. Period / scope : Model-agreement publication on July 30, 2026.https://www.sifma.org/news/press-releases/sifma-publishes-u-s-treasury-done-away-securities-clearing-agreement A clearing provider can differ from the executing broker. Industry source; the template’s existence establishes neither universal adoption nor guaranteed crisis access. No claim to have audited executed client contracts.
21. [21] Bank of England. Financial Policy Committee Record – September 2026Published September 30, 2026. Meeting of September 25; paragraph 32, gilt repo reform.https://www.bankofengland.co.uk/financial-policy-committee-record/2026/september-2026 Central clearing and minimum haircuts under development, with possible proposals in early 2027.