US debt: the hedge funds’ leveraged bet

For decades, US Treasury securities have served as the asset investors expect to sell when they need cash. That expectation remains fundamental to the global financial system. Yet the market’s resilience increasingly depends on something less familiar to the public: hedge funds that buy Treasury bonds using short-term borrowing while taking offsetting positions in derivatives. Their trades help make the market work. They also create a point at which stress in funding can spill straight into the price of government debt.

A Federal Reserve study released on 22 June 2026 estimates large hedge funds’ Treasury cash–futures basis trades at about $830 billion in September 2025. Another $305 billion of long Treasury exposure is attributed to swap-spread arbitrage. The positions are reconstructed from regulatory filings. Their dates, scope and measurement method are essential to interpreting the numbers. ¹

The risk emerges at a specific point: the investor supporting Treasury-market liquidity needs to raise cash for itself. The International Monetary Fund’s October 2026 Global Financial Stability Report supplies the framework. Funds can narrow price gaps in normal conditions; leverage and concentrated positions can amplify dislocations when intermediaries lose capacity. This conditional mechanism needs to be followed through the financing chain. ²

The buyer of Treasury futures creates a buyer of Treasury bonds

Start with an asset manager that wants exposure to US interest rates. Instead of buying a portfolio of bonds outright, it may buy Treasury futures. A future is a contract whose value tracks specified deliverable Treasury securities. The investor can obtain sizeable duration exposure, meaning sensitivity to interest-rate changes, by posting margin rather than paying the full cash price of the underlying bonds.

Demand can push futures above their fair value relative to deliverable bonds. A hedge fund sells the future and buys a Treasury eligible for delivery, seeking the spread after funding and delivery costs. A repurchase agreement, or repo, commonly funds the purchase: the fund receives cash against securities and agrees to buy them back. The price difference represents the financing charge. A dealer often links the fund to cash lenders such as money-market funds.

That division of labour performs a valuable service. Asset managers get a liquid and capital-efficient instrument. Hedge funds arbitrage the pricing discrepancy, buying Treasury securities along the way. Dealers and cash lenders finance the bridge between the futures and bond markets. The strategy has helped absorb Treasury supply and keep futures prices aligned with cash-market prices, including through episodes of quantitative tightening. The Federal Reserve documented the contribution and its measurement difficulties in March 2024. ³

Method and limitations

The asset manager buys futures; the hedge fund sells them and holds cash bonds financed by repo. Dealers draw on sources including money market funds. Arrows describe relationships and refinancing rather than measured amounts on each link. The 830 billion dollar estimate refers to positions in September 2025, published by the Fed in June 2026.

A narrow pricing advantage can still support an enormous trade because the cash bond is usually bought with borrowed money. Repo haircuts, the margin of collateral value withheld by the lender, can be very small, sometimes zero for particular arrangements. Futures also carry a margin requirement much lower than their total notional exposure. The opportunity is therefore magnified by leverage. So is the dependency on uninterrupted repo financing and the ability to meet changes in futures margin.

The two legs can generate cash demands at different times and counterparties. Hedge ratios, conversion factors and the cheapest-to-deliver bond affect the position. The US futures regulator’s leveraged-fund short category includes other strategies. The Fed therefore treats that public proxy as capable of overstating the basis trade itself. ³

Reconstructing the $830 billion estimate

The Fed’s June 2026 study goes beyond publicly available futures positions. Phillip Monin uses the monthly observations contained in quarterly SEC Form PF filings from large qualifying hedge funds. The method combines long Treasury securities, short Treasury derivatives and net repo borrowing at the individual fund level. After classifying likely basis traders, the estimated position is bounded by the smallest of those three exposures. The approach identifies a plausible economic structure in regulatory data. It does not reconstruct every executed transaction or reveal the positions of individual funds to the public. ¹

For September 2025, the Fed allocates about $2.4 trillion of long Treasury exposure among seven uses. Basis trades at $830 billion and swap-spread arbitrage at $305 billion represent slightly less than half. Other uses include curve positions and maturity-matched trades. $245 billion represents Treasury securities held as liquidity buffers. Rounded categories sum to $2.395 trillion. ¹

Method and limitations

Seven mutually exclusive categories in the Fed decomposition share a 0 to 900 billion dollar scale. Rounded amounts sum to 2395 billion, close to the stated 2400 billion. These are exposures rather than losses or annual transaction volumes. The liquidity buffer consists of unencumbered Treasury securities counted within long positions, rather than a cash-currency balance.

Concentration deserves as much attention as the headline number. By September 2025, the top 50 funds ranked by gross Treasury exposure held approximately 90% of the exposures in the population analysed, up from 84% at the start of 2023. Gross Treasury exposure among the large funds reached $4 trillion, with $2.4 trillion long and $1.6 trillion short. Gross exposure is a notional risk measure, not an assertion that $4 trillion of bonds are held outright and financed with the funds’ own capital. ¹

Another widely quoted estimate, $631 billion, comes from the Bank for International Settlements in December 2025. It measures an upper bound for the swap-spread trade, inferred from long Treasury exposures left unmatched by reported short positions in the second quarter of 2025. The Fed’s $305 billion, by contrast, is a strategy-level estimate for September 2025 derived from a different classification method. Treating the two numbers as interchangeable would be poor analysis. Their gap is a useful warning about the information that public aggregates conceal. ⁴¹

The Office of Financial Research offers another reconstruction. Its 19 August 2026 analysis estimates $2 trillion in cash Treasury holdings at year-end 2025, roughly 7% of the $28.9 trillion of marketable debt used as the denominator. It starts from Form PF exposures and subtracts futures and options positions. The Fed’s approximately 8.5% for September 2025 uses privately held Treasuries as its denominator. The ratios retain their separate dates and methods. ⁵¹

Repo financing has become part of the rates story

A more revealing transformation sits behind Treasury prices. In May 2026, economists at the Dallas Fed analysed how leveraged Treasury strategies affect the plumbing of US monetary policy. Hedge funds’ net repo borrowing, defined as repo cash borrowed less cash lent through reverse repo, stood at roughly $1.8 trillion at year-end 2025. The study equates that to about 6% of the marketable Treasury notes and bonds in its reference universe. The figure must be kept separate from the Fed’s approximately $3 trillion in gross repo cash borrowing in September 2025, and from the $830 billion basis estimate. They refer to different measurements and dates. ⁶¹

To finance these trades, dealers pull in liquidity from money-market funds and other lenders, then advance it against Treasury collateral. Intermediation consumes bank balance-sheet capacity. When multiple hedge funds want to borrow large sums against similar assets, secured funding prices can move higher relative to administered central-bank rates. The Dallas Fed estimates that the expansion of leveraged Treasury relative-value activity over the past decade is associated with a widening of repo funding spreads of roughly 10–20 basis points. The authors explicitly warn against interpreting those coefficients as clean causal estimates: Treasury issuance, asset managers’ futures demand and reserve conditions affect both the funding market and trade incentives. ⁶

Method and limitations

Long positions rise approximately from 0.6 to 2.4 trillion dollars between 2014 and end 2025. Net repo of 1.8 trillion at end 2025 measures borrowing less repo lending. The 10 to 20 basis point spread relationship over the decade is an econometric association reported by the Dallas Fed. Denominators and periods remain separate, and isolated causality is unresolved.

The change matters well beyond hedge fund performance. Money-market rates feed into financing costs across the economy. SOFR, based on secured overnight Treasury repo transactions, offers a view of one part of the system’s cost of cash. Yet an isolated rise in SOFR cannot tell an observer that basis trades are breaking down. Quarter-end balance-sheet management, shifts in bank reserves and Treasury settlement flows can influence the same rates. The mechanism has to be diagnosed across several markets at once.

The funding trade-off is subtle. Hedge funds make Treasury markets more flexible by buying securities that other investors do not immediately want to hold. In return, they often need fresh cash every day or at the next repo maturity. The US government gains a source of demand for bonds whose financing structure may become fragile precisely when buyers are scarce.

March 2020 and April 2025 tell different stories

The market has already supplied two valuable stress tests. In March 2020, the pandemic triggered a dash for cash across global markets, including an extraordinary sell-off in Treasuries. Subsequent research identified the rapid unwind of basis positions as one contributor. Funds selling their cash bonds while repurchasing short futures to close trades could add to Treasury selling at a time when dealer inventories and risk tolerance were constrained. That channel was part of a wider liquidity crisis; it would be inaccurate to attribute the whole episode to hedge funds. ³⁷

In April 2025, tariff announcements were followed by higher long Treasury yields and reduced market depth. The Dallas Fed found basis-trade positions relatively stable, with pricing indicators more resilient than in 2020. New York Fed official Roberto Perli instead reported swap-spread unwinds that likely amplified the rise in longer-term yields. ⁷⁸

The Fed’s June 2026 reconstruction suggests around $60 billion of swap-spread positions were unwound in April 2025, followed by another $40 billion in May. Estimated exposures subsequently recovered towards $305 billion by September. These figures measure inferred reductions in a strategy’s exposure, not directly observed net forced sales of Treasury bonds. That qualification matters when explaining price moves: dealers’ market-making conditions, investor flows and other strategies also influence yields. ¹

Method and limitations

The 2020 panel qualitatively describes basis-trade unwinds amid a broad dash for cash; it contains no invented series. The 60 and 40 billion reductions in 2025 are estimated swap-spread position changes, distinct from measured forced net bond sales. Cash–futures basis indicators are described as relatively stable during that episode.

The comparison directs attention to position structure, lenders and dealer capacity. The July 2025 Dallas Fed analysis finds that the basis trade can be more sensitive to reduced intermediation capacity than to a funding-rate increase alone. Its sensitivity exercise excludes margin risks, a central boundary when interpreting the resilience observed. ⁷

A liquidity call can arrive before the economic hedge pays out

Consider a hypothetical fund with $100 million in Treasury bonds. A repo lender applies a 1% haircut, making $99 million of repo financing available against that collateral. The fund needs to supply the remaining $1 million. If the lender lifts the haircut to 3%, holding the bond’s value constant and changing no other conditions, available financing falls to $97 million. The fund must find another $2 million to maintain the position. The example leaves out futures margin, changes in bond prices, other portfolio cash and the fund’s ability to obtain replacement financing. It is arithmetic, not a market observation or forecast.

Method and limitations

The displayed cash contribution finances only the bond leg. For a 100 million bond unchanged in value, a 1% repo haircut permits a 99 million loan and requires 1 million of cash. At 3%, the loan falls to 97 million and the cash contribution rises to 3 million, requiring 2 million extra. Futures margin, price changes, costs and the manager’s reserves are excluded. Inputs are hypothetical.

Real positions can face several pressures at once. Futures clearing may demand variation margin. Bond prices can move. The relative spread being arbitraged may widen instead of converging. Repo creditors can increase haircuts or refuse to roll overnight loans. The hedge fund then has to use cash buffers, raise financing elsewhere, sell unrelated assets or reduce the trade. Across many funds, similar defensive actions can generate a loop: Treasury sales worsen market liquidity, falling collateral values constrain repo and additional liquidity calls prompt further asset sales.

The IMF’s October 2026 report examines the asymmetry. When dealer capacity is constrained, leveraged positioning is associated with greater pricing dislocations. One estimate associates a one-standard-deviation increase in positioning with a 1.5-basis-point increase at the 90th percentile of the cash–futures basis over eight weeks, leaving the median unchanged. This describes a conditional distribution and depends on intermediation capacity. ²

That distinction also explains the risk of relying exclusively on a fund’s risk model. A portfolio can appear well hedged for ordinary interest-rate changes. A combined shock to funding access, collateral values and dealer balance sheets creates a different form of exposure: one in which the investor must survive the cash demands long enough for the relative-value thesis to work.

The bank is still in the middle

Hedge funds are commonly described as part of the nonbank financial system. Their financing nevertheless runs through major banks and securities dealers. These intermediaries provide repo lending, execute derivatives, manage collateral and offer prime-brokerage services. If a large hedge fund loses access to cash, the immediate consequences may be felt by the brokers financing it. They can respond by changing terms for other customers, amplifying the shock across portfolios that initially appeared unrelated.

The IMF estimates about $13 trillion of global hedge-fund gross assets in early 2026, against $4 trillion in 2013, and more than $40 trillion of gross notional exposure, including derivatives. Those measures overlap. A separate measure describes prime-broker concentration: in December 2025, the five leading providers served funds representing roughly two-thirds of covered assets under management. Assets of funds with several brokers are divided equally among those providers for the calculation. This is a client-asset measure, distinct from a share of lending. ²

The balance-sheet constraints facing dealers create a policy dilemma. Tight restrictions may constrain intermediation when investors most need it, while very loose financing terms can encourage ever-larger positions relying on uninterrupted short-term credit. The answer involves the design of margin and collateral requirements, the transparency of exposures and banks’ ability to intermediate stress without jeopardising their own liquidity.

Cross-border structures further complicate monitoring. Funds may be domiciled in the Cayman Islands, Ireland or Luxembourg while their trading desks, investors and lenders operate in other jurisdictions. Authorities can see part of the exposure through national data collections without necessarily having a consolidated, timely view of all the links. The IMF explicitly identifies these gaps as a barrier to assessing systemic risk. ²

Central clearing reshapes the funding chain

The SEC’s schedule sets 31 December 2026 as the compliance date for eligible cash Treasury transactions and 30 June 2027 for eligible repo transactions. Scope depends on defined transactions and participants. A central counterparty stands between the parties and can net offsetting transactions, potentially reducing bilateral exposures and dealer balance-sheet needs. It brings its own margin and operational requirements. ⁹

On 30 October 2026, the SEC granted conditional exemptions for certain inter-affiliate repos and transactions involving qualifying non-US counterparties. Limits and attestations constrain that relief. The reform’s coverage must therefore be read against the updated framework. ¹⁵

In January 2026, the OFR simulated the framework it was studying on January–August 2025 repos, holding transactions and behaviour fixed. 45% of average daily outstanding was already centrally cleared; coverage would have reached 77% in that exercise. Exceptions left 23% outside scope. This is a historical counterfactual under a framework preceding the October relief. ¹⁰¹⁵

Method and limitations

The observed 45% and simulated 77% are shares of the average dollar amount of Treasury repo outstanding from 1 January to 30 August 2025. The OFR figure does not net opposing repos. The scenario holds transactions and behaviour fixed under a modelled rule scope. This is a counterfactual rather than a promise about the eventual cleared share. SEC added exemptions on 30 October 2026 and operational relief on 4 November. Eligible-transaction deadlines remain 31 December 2026 for cash and 30 June 2027 for repo.

An OFR brief published in March 2026 cites an estimate that about 75% of hedge-fund Treasury repo activity was outside central clearing. Its population and reference period differ from the whole-market 45% figure. The sponsored-repo analysis covers, among other evidence, October 2019–October 2024 and describes dealers’ incentives to clear repos when managing balance-sheet constraints. ¹¹

A further SEC order dated 4 November 2026 conditionally facilitates the customer-reserve treatment of Treasury margin delivered by a broker on a net omnibus basis for multiple customers. It affects resources the intermediary must mobilise. Outcomes for individual funds depend on contracts, margin requirements and implementation. ¹⁶

Central clearing also concentrates default management and can generate substantial margin-liquidity demands in volatile markets. Dealer balance-sheet gains and funds’ cash needs must be assessed together. The Financial Stability Board’s 9 July 2025 recommendations call for stronger leverage data and oversight, building also on its work on collateral-call preparedness. ¹²

The Federal Reserve has a circuit breaker, with important limits

The Fed’s Standing Repo Facility is designed to support monetary policy implementation and orderly market functioning by providing collateralised funding to eligible counterparties. Those counterparties include primary dealers and qualifying depository institutions. A hedge fund does not receive a direct facility line simply because it holds Treasury collateral. A fund may benefit indirectly if the dealer that finances it has more reliable access to liquidity, but that transmission depends on credit decisions, collateral terms and the type of disruption. ¹³

A liquidity facility can help market functioning and absorb a cash-flow shock. Fund solvency, the profitability of an arbitrage and investor withdrawals remain separate issues. Transmission runs through eligible intermediaries, their collateral and their willingness to pass funding onwards.

The IMF’s case for credible backstops is consequently compatible with its recommendation for tighter monitoring and better calibrated leverage controls. Liquidity support and sound collateral discipline tackle different sides of the problem. The first concerns the functioning of core markets under stress. The second concerns how much stress market participants can create before an emergency begins. ²

Refinancing conditions determine the stress test

The evidence supports a structural vulnerability. Hedge funds have become material Treasury buyers. The basis trade embeds dependence on short-term borrowing and futures margin. Dealers connect the funds to cash lenders while operating under capital and liquidity constraints. Concentration means a relatively small number of large participants can matter at market scale. The Fed, OFR, BIS and IMF reach related conclusions using distinct but partly overlapping data. ¹²⁴

The adverse scenario requires several conditions to reinforce each other: a major Treasury rate shock, disrupted repo access, rising collateral or derivatives margin calls and insufficient dealer capacity to absorb selling. In that setting, forced deleveraging could deepen price swings and spill into other funding markets. The mechanism has empirical and historical support. Its probability over any particular horizon in November 2026 cannot be estimated credibly from the public evidence reviewed here.

The resilience of basis positions in April 2025 supplies a useful counterweight. The Federal Reserve’s May 2026 Financial Stability Report described sound banks and robust dealer intermediation on the information then available. In October, the IMF noted a more recent moderation in its indirect basis-trade footprint indicator. Those observations help calibrate monitoring. ¹⁴²

A more useful risk dashboard would put the leveraged-fund Treasury futures short, net repo borrowing, delivery-option-adjusted cash–futures basis, repo haircuts and financing spreads, and cash Treasury market depth side by side. Persistent joint deterioration would strengthen the forced-unwind hypothesis. Stable positioning, accessible repo finance and resilient market depth would weaken it. Public data cannot presently connect all those variables at high frequency for every large fund and counterparty.

For the Treasury, leveraged buyers make it easier to distribute an enormous volume of debt. For the financial system, those buyers introduce funding requirements that may have to be renewed just when the appetite to lend weakens. That is the fault line to watch: who has the balance-sheet capacity and spare cash to hold the bonds after the investors financing them decide to step back?

Further reading

Our investigation into government-debt buyers who borrow places these funds among other bondholders. The analysis of repo and collateral circulation explains the secured financing at the centre of the trade.

Method and limitations

Documentary review closed on 5 November 2026. Position sizes are institutional reconstructions with specified periods and definitions. The investigation compares Fed, BIS, OFR and IMF research and updates the legal framework using the SEC orders of 30 October and 4 November. Several institutions reuse Form PF, so their publications are not independent datasets. Fund and counterparty information remains lagged and incomplete.

The detailed Fed decomposition primarily covers September 2025. End-2025 measures from the OFR and Dallas use other reconstructions and denominators. Econometric associations retain their conditions and causal limitations. These amounts do not provide a crisis probability on 5 November or losses for a named bank. No real-time market quotation or yield forecast is used.

The haircut example assumes securities worth $100 million at a fixed price: (1 − 1%) × 100 = $99 million of financing, then (1 − 3%) × 100 = $97 million, requiring $2 million of additional cash. It excludes futures margins, price movements and the fund’s own buffers. The opening artwork is conceptual; figures distinguish estimates, mechanisms and illustrative assumptions.

Editorial licence: CC BY 4.0.

Sources and references

1. S01 · Federal Reserve / Phillip Monin · 2026-06-22 · Accessed: 5 November 2026FEDS Notes: Decomposing Hedge Funds U.S. Treasury Exposures
   Passages and scope

   Note dated 22 June 2026, mainly September 2025 data. Sequential decomposition of large funds’ Form PF Treasury exposures. Rounded categories: $830/305/395/375/245/175/70bn, sum $2,395bn. The $245bn category represents Treasury securities held for liquidity, per the appendix. Estimated swap-spread position reductions of $60bn in April and $40bn in May 2025 are distinct from net bond sales.

2. S02 · IMF · 2026-10-12 · Accessed: 5 November 2026GFSR October 2026 chapter 2 Hedge Funds and Financial Stability
   Passages and scope

   October 2026 GFSR, chapter 2. Figure 2.5, printed p.29: prime-broker concentration using December 2025 AUM split among providers. Box 2.2, p.38: a conditional 1.5bp association at the 90th percentile over eight weeks for a one-standard-deviation positioning increase, median unchanged. Gross assets and notional exposures overlap.

3. S03 · Federal Reserve · 2024-03-08 · Accessed: 5 November 2026Quantifying Treasury Cash-Futures Basis Trades
   Passages and scope

   Note dated 8 March 2024. Cash/futures arbitrage, financing, delivery options and limitations of the CFTC leveraged-fund short proxy. March 2020 sales occurred within a multi-cause stress episode.

4. S04 · BIS · 2025-12 · Accessed: 5 November 2026Sizing up hedge funds relative value trades in US Treasuries and swaps
   Passages and scope

   December 2025 Quarterly Review box. Indirect $631bn upper bound for swap-spread strategies in Q2 2025. Residual long positions can include other uses; scope differs from the Fed’s $305bn September estimate.

5. S05 · OFR Berg Stemp · 2026-08-19 · Accessed: 5 November 2026Hedge Funds Cash Treasury Holdings Reach 2 Trillion
   Passages and scope

   Article dated 19 August 2026, year-end 2025 data. Estimated cash holdings reconstructed from Form PF exposures minus futures/options positions: $2tn, about 7% of the selected $28.9tn of marketable debt at market value.

6. S06 · Dallas Fed Kahn McCormick · 2026-05-28 · Accessed: 5 November 2026Rising hedge fund leverage affects monetary policy implementation
   Passages and scope

   Article dated 28 May 2026. Estimated net repo borrowing of $1.8tn at end-2025; long exposures about $0.6tn in 2014 and $2.4tn at end-2025. Associated 10–20bp widening in selected repo spreads over the decade, with the authors’ explicit causal reservation.

7. S07 · Dallas Fed Ramaswamy et al · 2025-07-15 · Accessed: 5 November 2026How sensitive is Treasury cash-futures basis to funding condition shifts?
   Passages and scope

   Analysis dated 15 July 2025 comparing March 2020 and April 2025. Basis resilience and intermediation capacity. The funding-sensitivity exercise excludes margin risks.

8. S08 · New York Fed Roberto Perli · 2025-05-09 · Accessed: 5 November 2026Recent Developments in Treasury Market Liquidity and Funding Conditions
   Passages and scope

   Speech dated 9 May 2025. Roberto Perli reports swap-spread unwinds likely to have amplified the increase in long yields. Attributed interpretation, distinct from direct measurement of forced sales.

9. S09 · SEC · Schedule checked 5 November 2026 · Accessed: 5 November 2026Treasury Clearing Implementation
   Passages and scope

   Implementation schedule and scope checked on 5 November 2026. Eligible cash transactions: 31 December 2026; eligible repo transactions: 30 June 2027. Scope, exemptions and participants belong together.

10. S10 · OFR Cenicola Heilbron Mann Paddrik · 2026-01-29 · Accessed: 5 November 2026How Will Central Clearing Impact the Repo Market?
    Passages and scope

    Study dated 29 January 2026 using January–August 2025 data. Shares of average daily outstanding Treasury repo amounts: 45% observed, 77% in a static regulatory scenario. Fixed transactions and behaviour, before October 2026 relief; offsetting repos are not netted in Figure 2.

11. S11 · OFR Karunamuni Mann · 2026-03-03 · Accessed: 5 November 2026Hedge Fund Participation in Cleared RepoOfficial supporting document
    Passages and scope

    March 2026 brief citing an estimate of 75% of hedge-fund Treasury repo activity outside clearing. Sponsored-repo analysis covers October 2019–October 2024, including 2024Q3 Form PF comparisons. Some repo comparisons include limited non-Treasury collateral. Publication date is distinct from the estimate’s observation period.

12. S12 · Financial Stability Board · 2025-07-09 · Accessed: 5 November 2026Leverage in Nonbank Financial Intermediation: Final report
    Passages and scope

    Final report dated 9 July 2025. International recommendations on data, leverage, counterparties and cooperation, building also on collateral-call preparedness work. These are recommendations.

13. S13 · New York Fed · Criteria checked 5 November 2026 · Accessed: 5 November 2026Standing Repo Counterparties
    Passages and scope

    Current standing-repo counterparty criteria and approved institutions. Banks and primary dealers meeting the relevant requirements; hedge-fund status by itself does not confer direct access.

14. S14 · Federal Reserve · 2026-05 · Accessed: 5 November 2026Financial Stability Report, Leverage in the Financial Sector
    Passages and scope

    May 2026 Financial Stability Report, leverage section. Assessments of banks and dealers using information then available, including 2025Q3 data and early-2026 surveys. The assessment retains its date.

15. S15 · SEC · 2026-10-30 · Accessed: 5 November 2026Order 34-106789: inter-affiliate and non-US repo reliefOfficial supporting document
    Passages and scope

    Order dated 30 October 2026 and official release. Conditional relief for selected inter-affiliate and qualifying non-US repos, with limits and attestations. Exemptions are distinct from compliance dates; the framework postdates the January OFR scenario.

16. S16 · SEC · 2026-11-04 · Accessed: 5 November 2026Order 34-106821: customer reserves and Treasury margin
    Passages and scope

    Order dated 4 November 2026. Conditional Item 15 customer-reserve treatment where broker Treasury margin is delivered on a net omnibus basis. Operational intermediary relief subject to applicable safeguards; individual fund margin or cost outcomes require assessment.