ACG
Master Institutional Readiness Assessment
A short diagnostic for firms transacting in U.S. Treasuries. It maps your trading footprint, technical posture, and legal exposure to a clear compliance pathway ahead of the December 31, 2026 FICC mandatory-clearing deadline. Speak or type your answers.
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Section I
Market Access & Volume Dynamics
Objective: Identify the firm's trading footprint to quantify liquidity and operational risk.
Question 1: What is the firm's average daily volume (ADV) in U.S. Treasury Cash and Repo transactions?
Why we ask
The mandate specifically targets "eligible secondary market transactions". High-volume firms face exponential increases in margin calls and operational risk.
Question 2: Does the firm operate as a 'Sponsoring Member' or an 'Indirect Participant'?
Why we ask
The requirements for a Sponsoring Member (Direct) are vastly different from an Indirect Participant (Buy-side). We need to know if we are building the "Engine" (Direct) or the "Bridge" (Indirect).
Question 3: What percentage of Repo activity is currently 'Inter-Affiliate'?
Why we ask
This is a "hot zone" for 2026. If internal volume is high, the firm likely requires the SIFMA-requested exemptions to avoid "trapping" liquidity.
Question 4: What is your current 'Done-Away' execution vs. 'Done-With' ratio?
Why we ask
Under the new mandate, many firms are historically "Sponsor-Locked" (Done-With), meaning they must trade and clear with the same dealer. If the bank intends to retain execution across multiple dealers while centralizing clearing (Done-Away), they require a significantly more complex tech and credit architecture that ACG must engineer.
Question 5: What percentage of your Treasury flow involves 'exempt' counterparties (Central Banks, Sovereign Entities, or International Financial Institutions)?
Why we ask
Transactions with these entities are specifically excluded from the mandatory clearing requirement. Identifying this segment allows us to "disqualify" these volumes from your FICC margin modeling, potentially saving millions in unnecessary collateral obligations.
Question 6: Do you currently engage in Treasury 'Basis Trades' (Cash vs. Futures)?
Why we ask
These trades are high-leverage and high-sensitivity. If they aren't centrally cleared, the bank faces a "liquidity trap" where they cannot offset margin between the CCP for futures and the CCP for cash. This question identifies a prime opportunity for Cross-Margining as a capital reclaim strategy.
Question 7: How much of your Repo book consists of 'Open' or 'Evergreen' repos versus 'Fixed-Term' repos?
Why we ask
Central clearing traditionally favors fixed-term, standardized contracts. Open repos -- which allow for daily renegotiation -- introduce operational friction in a cleared environment. We need this to determine if your settlement logic needs a radical rebuild or if you should shift your funding strategy to more "clearing-friendly" products.
Question 8: What is the geographic location of your primary trading desks and affiliates (Extraterritorial Nexus)?
Why we ask
The mandate has "Extraterritorial reach". If you are trading U.S. Treasuries through a non-U.S. affiliate, you may be caught in time-zone gaps and netting enforceability issues currently being challenged by the IIB relief requests. We need this to map your jurisdictional risk.
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