CFTC Staff Allows Clearing Organizations to Use Trust Companies for Daily Settlements

The Commodity Futures Trading Commission’s (CFTC) Division of Clearing and Risk issued a no-action letter on November 5, 2026, addressing the use of trust companies for daily settlements between derivatives clearing organizations (DCOs) and their clearing members. Under the letter, a DCO may use a trust company for those settlements if it treats the company as it would a settlement bank under applicable CFTC requirements. The letter sets out that condition for DCOs considering trust companies for daily settlement activity.