Intercontinental Exchangereason 02 of 4it owns a thing that cannot be built or permitted twicederived 2026-09-01accession 0001571949-26-000011
ICE's clearing houses occupy a regulatory-mandated position in derivatives markets. The EMIR 3.0 Active Account Requirement actually reinforces ICE's position by requiring EU participants to use an EU-authorized CCP—which ICE Clear Netherlands now is—creating a compliance-driven barrier that competitors without EU authorization cannot easily overcome. The 26% increase in CDS clearing notional demonstrates growing centralization of credit risk through ICE's infrastructure.
the thesis · admitted · the reason above is the thesis, not printed twice
no findingread · nothing bore on it
It held on this filing. No finding was written because nothing in it bore on the reason — the sentences it was read against are below.
the evidence · every sentence checkedthree sentences · whole, uncut
the claims it rests on
“ICE operates ICE Clear Europe for CDS clearing, ICE Clear Netherlands for euro-denominated short-term interest rate derivatives, and multiple futures clearing houses”
“Notional value of CDS cleared was $16.1 trillion for the six months ended June 30, 2026 versus $12.8 trillion in the comparable prior period”
“EMIR 3.0's Active Account Requirement mandates EU market participants establish accounts at an EU central counterparty for euro-denominated short-term interest rate derivatives”