US & UK Authorities Hold Tabletop Exercise on Central Counterparty Resolution Planning

Key Takeaways

• Senior officials from the SEC, FDIC, CFTC, Federal Reserve Board, and Bank of England held a tabletop exercise on Sept.
• 3, 2026, to discuss the hypothetical resolution of central counterparties (CCPs).
• The meeting focused on information sharing and communication arrangements to support financial stability.
• It introduces no new requirements, but it signals continued cross-border supervisory attention to CCP resilience, which matters for firms with significant clearing exposures.

Deep Dive

Senior officials from the SEC, FDIC, CFTC, Federal Reserve Board, and Bank of England held a tabletop exercise on Sept. 3, 2026, to discuss the hypothetical resolution of central counterparties (CCPs). The meeting focused on information sharing and communication arrangements to support financial stability. It introduces no new requirements, but it signals continued cross-border supervisory attention to CCP resilience, which matters for firms with significant clearing exposures.

The release states that participants reviewed recent joint work, in particular the information sharing and communications arrangements meant to support financial stability if a CCP were resolved. They also acknowledged the importance of continued dialogue, shared analyses, and policy discussions on CCP resolution. The release gives no details on the scenarios tested, findings, or policy proposals. No deadlines, comment periods, or effective dates are mentioned, and the release does not say when future meetings or outputs will occur.

For compliance and risk professionals, the practical implications are indirect. Firms that are clearing members or clients of CCPs in either jurisdiction, or that operate across both, should expect continued coordination among authorities on CCP recovery and resolution. Over time this could lead to further policy development affecting loss allocation, default management, liquidity, and continuity of access to clearing services. Cross-border coordination also suggests that U.S. and UK approaches to resolution may remain aligned, which affects firms with operations in both markets.

Recommended actions include:
- Monitor follow-up publications from the participating agencies, including any policy proposals on CCP resolution.
- Review exposures to CCPs, including default fund contributions, initial margin, and potential loss allocation or assessment rights under CCP rulebooks.
- Confirm that internal contingency plans address a CCP default or resolution scenario, including liquidity needs and operational continuity.
- Brief senior risk and treasury stakeholders that this is a routine, no-action update, while keeping CCP resolution on the watch list.

Overall risk impact is low in the near term because no new obligations arise. Medium-term risk remains in the form of potential policy changes and the inherent concentration and systemic risk associated with CCPs.

Source: Securities and Exchange Commission