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Where Can We Take You? United States

Where Can We Take You? • Article • November 19, 2025

Desert road with car ahead in the United States.

Regulators in the U.S. have been incredibly busy lately, and so too has the post-trade industry. Whether it is the looming rollout of mandatory clearing for U.S. Treasury and repo transactions, the recent passage of the GENIUS Act, ongoing discussions about the market structure bill, the Depository Trust & Clearing Corporation’s (DTCC) modernization agenda, or the debate about expanding trading hours, custodians are having to adapt and update their processes.

In this latest edition of our “Where Can We Take You” series, Marcello Topa, Global Head of Advocacy for Investor Services at Citi, speaks to Chris Ravn, NAM Custody Head, about the regulatory and infrastructure changes sweeping through the U.S.


	Marcello Topa Global Head of Advocacy Investor Services, Citi	Chris Ravn North America Head of Custody Investor Services, Citi

Topa: The US has recently amended its clearing rules. Can you shed a bit more light on this?

Ravn: We have seen a lot of Black Swan events strike our industry over the last decade – starting with the 2014 Flash Crash and 2019 repo market spike, right through to Covid and the regional banking meltdown in 2023.¹ Each of these episodes triggered a degree of volatility in the US Treasury (UST) market – a nominally safe haven for investors – prompting regulators to intervene.

Today, UST transactions are either settled bilaterally or centrally cleared at the DTCC’s Fixed Income Clearing Corporation (FICC), the US’s sole Covered Clearing Agency (CCA).²

However, in late 2023, the Securities and Exchange Commission (SEC) announced that market participants, including broker-dealers and institutional investors, will now need to centrally clear certain UST cash and all repo transactions via a CCA. Initially, the rules were supposed to go live in December 2025 for UST cash, and June 2026 for repos, but the deadlines were delayed by a year to give firms additional time to comply.³

Given the significant implications for many of our custody clients, we are actively engaged in comprehensive support initiatives. Our efforts have included client education, operational preparation, fostering partnerships with our Markets colleagues who offer clearing services, and establishing direct connectivity to the CCPs. To further aid understanding and compliance, we have published a series of thought leadership articles and hosted senior FICC executives to directly address our clients’ questions.

Topa: Can you please give an overview of the digital asset landscape in the US at the moment, especially with all of the regulatory changes that are going on?

Ravn: Following the recent political changes in the US, there has been a 180-degree shift in the regulatory attitudes towards digital assets – in fact, President Trump signed an Executive Order in March 2025 promising to make the U.S. the crypto capital of the world.⁴

A few months later in July 2025, the GENIUS Act was signed into law. In addition to defining what a payment stablecoin actually is, the GENIUS Act also creates a licensing and regulatory framework for domestic payment stablecoin issuers and standards for foreign issuers when participating in the US’s payment stablecoin market.⁵ The rules also provide greater clarity around the custody and safekeeping requirements for stablecoin-related assets.⁶ Hot on the heels of the GENIUS Act is the market structure bill, which is currently under negotiation. Whereas the market structure bill will focus on other digital assets and could potentially update some longstanding securities rules.

Several crypto-custody rules and guidelines have evolved over the last nine months in the US. In early 2025, the SEC’s Staff Action Bulletin (SAB) 121 – a Biden-era SEC guideline that required custodians holding crypto assets to register them as being liabilities on their balance sheets – was scrapped.⁷ In March 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter 1183, which reaffirmed that crypto-asset custody services are a permissible activity for national banks and eliminated the supervisory non-objection process for crypto-asset activities.⁸ More recently in July 2025, the Federal Reserve, the Federal Deposit Insurance Corporation (FDIC) and the OCC published a joint letter outlining their risk management expectations for banks offering crypto-asset safekeeping.⁹

In response, more custodians are beginning to launch crypto-custody services for institutional clients, including Citi, which plans to start offering such services in 2026.

Topa: Tell me about the DTCC’s modernization plans.

Ravn: The DTCC’s modernization plan is a critical next step in how the US’s financial markets will operate behind the scenes. For decades, the system was built for a different time, a different volume of trading, and a much simpler mix of products. With the industry pushing for faster settlements, greater resilience, better data, extended trading hours and the ability to handle new products like tokenized assets, the DTCC has launched a number of multi-year programs, including initiatives like Project Ion and their Future of Clearing workstreams.

The DTCC is looking to re-platform their core clearing functions, stripping away operational complexity, and introducing exciting new capabilities, such as capturing trades during extended hours and providing much richer, machine-readable data. A big win here is their plan to upgrade client connectivity to a strictly ISO 20022 format, using messaging and file channels, with testing kicking off in 2026 and full implementation expected by 2027.

On the settlement side, the DTCC is going to support partial deliver orders, expand the data fields in member messages, and simplify complex settlement workflows. In clearing, their Universal Trade Capture (UTC) service will benefit from having extended trading hours to support the increased volumes and growing number of trading houses. The DTCC is also improving how Exchange Traded Funds (ETFs) with options components are cleared, working between the NSCC and the Options Clearing Corporation. All of these changes are designed to build a more dynamic and resilient trading environment. The goal is to maximize liquidity and significantly reduce counterparty risk, ensuring the market can handle whatever comes next.

Topa: Looking further ahead, what other big infrastructure changes do you see happening in the US?

Ravn: The US equity markets are witnessing a growing momentum shift towards extended trading hours, with discussions around 24/7 or 24/5 operations gaining traction, largely driven by the accelerating retailization of equities. Proponents argue that continuous trading would significantly enhance global investor access to the US market, thereby boosting liquidity and refining price discovery.

Major exchanges, including Nasdaq and CBOE Global Markets, are actively exploring the introduction of 24/5 trading, while the NYSE aims to extend weekday trading on its Arca Equities Exchange to 22 hours daily. These initiatives, signaling a coordinated move towards near-continuous weekday trading, are contingent on regulatory approvals and the readiness of critical market infrastructure.

The implications of these changes are far-reaching for the post-trade industry, and it is not yet fully prepared for such a shift. Extended trading hours would fundamentally alter intraday liquidity patterns, increase the volume of settlement instructions outside traditional banking windows, and necessitate advanced intraday risk management tools for margining and fail-management.

Infrastructure providers like the DTCC must extend message handling, ensure 24-hour operations or robust end-of-day cutoffs, and guarantee continuous reporting and surveillance. Furthermore, settlement cycles, reconciliation timing, and liquidity buffers will require a complete overhaul to prevent liquidity bottlenecks.

While exchanges have submitted applications and published timelines, and the DTCC has incorporated support for longer trade capture into its modernization roadmap, full operational readiness depends on extensive, coordinated efforts.

This is a hugely exciting initiative, but there is still a lot of work to be done.