---
title: "CFTC Staff Issues No-Action Letter on Daily Settlements Through Trust Companies"
description: "Derivatives clearing organizations may use trust companies for daily member settlements if they satisfy settlement bank requirements, the agency said."
url: https://basisdesk.news/news/cftc-no-action-letter-trust-companies-daily-settlements
published: 2026-11-05T18:16:43.953Z
modified: 2026-11-05T18:16:43.953Z
section: Regulation & Policy
author: Basis Desk Newsroom (AI-generated, source-verified)
sentiment: neutral
tickers: []
tags: [cftc, clearing, derivatives, settlement, trust-companies, regulation]
license: Quote with attribution to Basis Desk (basisdesk.news). Not financial advice.
---

# CFTC Staff Issues No-Action Letter on Daily Settlements Through Trust Companies

Derivatives clearing organizations may use trust companies for daily member settlements if they satisfy settlement bank requirements, the agency said.

## At a glance

- **What happened:** The CFTC Division of Clearing and Risk issued a no-action letter on Nov. 5, 2026, addressing the use of trust companies for clearing settlements.
- **Why it matters:** Derivatives clearing organizations can conduct daily member settlements via trust companies by treating them under settlement bank rules.
- **Who is affected:** Derivatives clearing organizations, their clearing members, and trust companies seeking to process daily settlements.
- **Takes effect:** 2026-11-05
- **What's next:** No next step announced.
- **Status:** guidance
- **Primary source:** [CFTC Staff Addresses Use of Trust Companies for Daily Settlements](https://www.cftc.gov/PressRoom/PressReleases/9322-26) — CFTC Press Releases

## Key points

- The CFTC Division of Clearing and Risk released a no-action letter on Nov. 5, 2026 [1].
- Derivatives clearing organizations can use trust companies for daily settlements with members [1].
- Clearing organizations must treat the trust companies as settlement banks under CFTC rules [1].

## Editorial remark

- **Context:** The CFTC Division of Clearing and Risk issued the guidance to evaluate whether trust companies qualify to conduct daily clearing member settlements under existing agency frameworks.
- **Impact:** Derivatives clearing organizations and clearing members can utilize trust companies for settlement, provided those entities comply with standard settlement bank rules.
- **Watch:** Market participants will monitor further implementation details or formal rule updates from the CFTC clearing division regarding settlement banking entities.

The Commodity Futures Trading Commission's Division of Clearing and Risk issued a staff no-action letter on Nov. 5, 2026, clarifying the operational use of trust companies by derivatives clearing organizations [1].

Under the position detailed in the letter, a registered derivatives clearing organization is permitted to use a trust company to conduct daily settlements with clearing members [1]. To rely on the relief, the clearing organization must treat the trust company as it would treat an authorized settlement bank under applicable CFTC regulations [1].

## Regulatory Requirements for Clearing

The staff guidance formally evaluates whether trust companies satisfy daily clearing and settlement functions between derivatives clearing organizations and their participating members [1]. The Division of Clearing and Risk stipulated that compliance hinges entirely on the clearinghouse holding the trust company to the standard CFTC requirements governing settlement banks [1].

## FAQ

**What did the CFTC staff no-action letter decide?**

The Division of Clearing and Risk stated that derivatives clearing organizations may use trust companies for daily member settlements if treated as settlement banks under applicable rules.

**What condition must derivatives clearing organizations satisfy?**

The clearing organization must treat the trust company in the same manner as it would treat an authorized settlement bank under CFTC regulations.

## Sources

1. [CFTC Staff Addresses Use of Trust Companies for Daily Settlements](https://www.cftc.gov/PressRoom/PressReleases/9322-26) — CFTC Press Releases, 2026-11-05

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Basis Desk Newsroom · AI-generated, source-verified · https://basisdesk.news/about/how-we-use-ai