The Neutral Clearing Playbook
A Plexo framework for evaluating whether a clearing arrangement distributes governance, control and commercial incentives transparently.
By Anton Titov, Founder · Plexo Institute
Four tests—governance, compliance, regulatory fit and operating incentives—help evaluate a named clearing arrangement.
“Neutrality” is not a settled market law. It is a practical question: can participants inspect who sets rules, bears risk, controls data and benefits commercially?
In This Framework
Neutral clearing is a verifiable architecture, not a positioning claim.
Four Plexo tests: governance, compliance baseline, regulatory alignment and operating incentives.
The Visa example: a historical change in ownership and governance, not a claim that one model inevitably wins.
Six questions that make a network’s governance and operating claims inspectable.
What's Inside
Four checkpoints for reading the playbook before the deeper chapters.
The framework uses historical examples as context, then asks how a named clearing arrangement allocates decision rights, controls, regulatory obligations and commercial incentives. It is a Plexo methodology, not a ranking of all payment networks.
This framework asks four questions of a named arrangement: who sets rules and settles conflicts; how participant controls are evidenced; which legal and supervisory perimeter applies; and whether the operator’s commercial incentives conflict with its members.
CLS, Swift, ACH and Visa illustrate different ownership, operating and oversight models at stated dates. They do not establish that every durable network has the same four properties or that an arrangement failing one test cannot operate successfully.
Visa describes its pre-IPO history as an association owned by member financial institutions; the 2008 IPO converted the network into a publicly traded company. The network did not collapse, but the governance model changed from member ownership to public-company accountability. For this framework, the case is useful because it separates network durability from member control: a rail can remain large while member governance leverage is structurally reduced.
If an issuer controls the settlement asset and network rules, participants should inspect how conflicts, access, asset choice and switching are governed. A venture-backed operator should make its ownership, incentives and member protections clear. A network with unresolved regulatory status should disclose the applicable legal perimeter and restrictions.
These are risks to examine, not predictions that a particular ownership structure, funding source or legal status determines its future.
The question is not whether a network calls itself neutral, but whether a participant can independently inspect: governance documents; admission and exit rules; treatment of settlement assets; relevant permissions; the published rulebook; and commercial boundaries with members.
Plexo does not score a network into a predicted outcome from these questions. The answers identify evidence gaps and potential conflicts that must be resolved for the intended route.
What Neutrality Means
Neutrality is a claim about decision rights, controls and commercial incentives that participants should be able to inspect.
In this framework, neutrality does not mean that every participant has identical rights or that conflicts disappear. It means the arrangement discloses how rules are made, enforced and changed; who can access data and assets; and how commercial conflicts are handled. Whether that structure is sufficient depends on the members, legal setting and intended route.
| Source indicator | What it shows |
|---|---|
76 | CLS Bank settlement members after U.S. Bank joined CLSSettlement in 2025; CLS has operated since 2002 under member-owned governance. |
11,500+ | Swift institutions, with Belgian cooperative governance and multi-jurisdiction oversight. |
Test 1: Governance and Decision Rights
Inspect who owns the arrangement, sets rules, changes them and resolves conflicts.
CLS, Swift, ACH and Visa have used different ownership and governance models at different times. Member ownership can be one way to align participants, but it is not a guarantee of fairness or durability; commercial or public-interest structures can also work. The test is whether decision rights, conflicts, member remedies and change control are documented and acceptable for the intended route.
Ownership Decides Whether Clearing Stays Neutral
Member governance, open rules, and non-compete constraints stop the hub from taxing or steering members.
Participants can discipline the hub
Rule makers also bear routing, pricing, and access consequences.
Neutral clearing test
Can the hub help members clear without competing with their edge?
Revenue can steer the network
A hub with its own margin agenda can tax members or bias routes.
Clearing arrangements can set membership criteria, control standards, cut-offs, pricing, protocols and dispute processes. Those choices can distribute benefit and risk unevenly.
A member-owned structure may give participants formal influence; a third-party owner may offer other safeguards such as independent oversight, contractual protections or regulated governance. Neither model decides the outcome by itself. Inspect voting rights, reserved powers, conflict processes, fee setting, data rights and exit options.
Visa was a bank-owned association before its 2008 IPO converted it into a publicly traded company. The network did not collapse. It continued to operate at global scale. But member banks no longer owned the rule-making institution in the same way. The transformation is a clean historical example of the tradeoff between commercial scale and member governance control.
Test 2: Control Baseline and Evidence
Identify which controls the arrangement verifies, monitors and leaves with each participant.
A participant failure can create operational, legal or reputational consequences for others, depending on the arrangement and law. A documented control baseline, monitoring and escalation process can reduce uncertainty, but it does not transfer or remove each participant’s own legal duties.
An arrangement may use attestations, independent assessments, contractual warranties, monitoring or other controls. The appropriate evidence depends on its legal role and the jurisdictions involved.
For a stablecoin clearing route, determine: participant due diligence; Travel Rule and data capabilities where applicable; sanctions and AML/CFT control allocation; custody and redemption responsibilities; and incident, continuity and cyber procedures.
The question is not whether the network says “compliant”, but whether the rulebook identifies each control owner, evidence source, exception process and regulatory boundary. Related reading: Travel Rule On-Chain (IVMS-101) explains one relevant data requirement.
Test 3: Legal and Regulatory Fit
Establish which permissions, oversight and participant obligations apply to the named arrangement.
Named payment arrangements can operate under different legal structures and oversight models. CLS, Swift and ACH provide examples of distinct governance and supervisory contexts. Their status is not transferable to a new network or jurisdiction. A proposed stablecoin arrangement needs its own legal analysis and current evidence of relevant authorisations, exclusions or participant obligations.
- Direct supervision or designation: a law or authority may directly regulate the arrangement.
- Participant-led obligations: the arrangement may rely on obligations of participating regulated entities, while still requiring its own legal analysis.
- Function-specific regimes: payment, custody, issuer, data or other rules may apply to parts of the route.
These categories are analytical aids, not a substitute for jurisdiction-specific advice. The decisive question is which entity performs which function, under what permission, and how the rulebook and contracts allocate responsibility.
Test 4: Operating Incentives and Commercial Boundaries
Map whether the operator and participants have aligned or conflicting commercial incentives.
An arrangement may provide shared infrastructure, commercial services, or both. A non-compete commitment may reassure some members, while another model may be acceptable if pricing, data rights, service boundaries and governance are transparent. The actual effect on participation must be evidenced, not assumed.
| Example | What to inspect | Why it is relevant |
|---|---|---|
CLS Bank | Published governance, membership and service boundaries | A dated example of an established arrangement |
Swift | Published cooperative governance and operating role | A dated example of a messaging and standards organisation |
ACH | Operating roles, participant rules and payment-system context | A U.S. example with public-sector and private-sector components |
Post-IPO Visa | Ownership and governance change following the 2008 IPO | A historical example that ownership and member control can change |
A product can support a shared operating function, add a commercial service or do both. The effect on members depends on pricing, data, access, governance and the alternatives available to them.
For a stablecoin arrangement, identify whether compliance coordination, directory, netting, conversion, customer service or liquidity provision is supplied by the network, a member or another party. Then assess contractual conflicts and member remedies.
Do not assume that a “rail-only” or commercial model is automatically better; inspect its documented incentives and observed participant behaviour.
What Fails the Playbook
The framework identifies risks to test, not categories of networks destined to fail.
Issuer control, investor incentives and unresolved regulatory status can create governance or operating risk. Their relevance depends on the documented rulebook, asset structure, permissions, participant protections and intended route.
Where one entity controls both the settlement asset and network rules, participants should inspect asset choice, access, fees, data rights, switching, governance and remedy. A conflict may exist, but it is not established merely by common ownership.
Historical card-network examples provide context for changes in ownership and governance. They do not predict the outcome of a current stablecoin network.
A private operator may have investor, growth and revenue incentives that members should understand. It may also offer contractual protections, regulated governance or transparent economics.
The test is whether member rights, pricing, data use, exit terms and conflict processes are disclosed. “Commercial” is not evidence of failure, and “neutral” is not evidence of member protection.
Unclear regulatory status can create legal, counterparty and operating risk. An arrangement should disclose its functions, permissions, restrictions and the responsibilities that remain with participants.
This framework does not treat a general label such as “decentralised” or “regulated” as sufficient. A named route needs current legal analysis, enforceable participant terms and documented control allocation.
What a Neutral Stablecoin Clearing Network Looks Like
The architecture is specific and verifiable.
Plexo uses the four tests to make an arrangement’s claims inspectable. The question is not “does it call itself neutral?” but “can a participant verify its decision rights, control allocation, legal perimeter and commercial boundaries from current documents?”
- Decision rights: who owns, votes, appoints, vetoes and resolves disputes?
- Admission and exit: what standards, discretion, suspension and remedy apply to participants?
- Asset treatment: how are settlement assets chosen, supported, converted, substituted and governed?
- Legal perimeter: which permissions, oversight and participant obligations apply in each relevant jurisdiction?
- Rulebook visibility: can a participant obtain the current rules, fees, control allocation and change process?
- Commercial boundaries: what services, data uses and customer relationships can conflict with a participant?
These are six questions, not a numerical prediction of durability. They show what evidence a participant needs before relying on a claimed neutral arrangement. Related reading: What Is a Clearing Network? covers the functional architecture.
Counter-Arguments & Limitations
The strongest challenges focus on speed and multi-stablecoin feasibility.
This framework does not claim that cooperative governance or multi-asset support is required for every use case. The central question is whether the proposed model’s trade-offs are explicit and acceptable to its participants and regulators.
A commercial network may make decisions faster than a member-governed arrangement, while member governance may give participants more formal influence. Neither fact predicts market success.
For the intended route, compare decision speed, change control, member protections, capital, legal permissions, operating reliability and incentives. A network does not need to convert to a cooperative model merely because it serves an institutional use case; the relevant safeguards must instead be evidenced.
A clearing arrangement must specify which settlement assets it accepts and how it handles conversion, liquidity, risk, legal claim and failure. Supporting several assets can introduce fragmentation or bias; selecting one asset can introduce a different dependency.
The framework therefore asks for documented asset-treatment rules rather than treating multi-asset support as a requirement. Project Agora is research context for tokenised commercial-bank deposits and wholesale central-bank money; it does not prove production readiness for a stablecoin clearing design.
About This Framework
Scope, disclosure, and method.
Plexo develops clearing-network architecture for licensed financial institutions. This framework states the questions Plexo believes an arrangement should answer before participants rely on it. Readers should treat it as a builder's methodology, not a neutral observation or a claim that one governance model is universally correct.
Historical examples are drawn from the official materials listed below and apply only at their stated dates. The four tests and six questions are Plexo's synthesis for examining governance, controls, legal fit and operating incentives. They do not measure private motives, predict scale or establish a universal historical pattern. A live network requires a current review of its rulebook, participant terms, permissions, operating model and route-specific evidence.
About the Author
Relevant Reading
What Is a Clearing Network? - the functional architecture behind the playbook.
The Routing Error - how bilateral routes can add contractual and operational complexity.
Six Pathways - the full stratified settlement landscape.
The $1B Settlement Graveyard - a perspective on lessons from previous network attempts.
References
CLS Group, CLS welcomes U.S. Bank to CLSSettlement (Sep. 2025).
Swift, operational and governance disclosures (reference vintage: 2025).
Federal Reserve, Automated Clearinghouse Services.
Visa Inc., Form S-1 filing (2008).
Bank of England, CHAPS operational disclosures.
BIS Innovation Hub, Project Agora.
References
6 references- CLS welcomes U.S. Bank to CLSSettlement — CLS Group
- Swift operational and governance disclosures — Swift
- Automated Clearinghouse Services — Federal Reserve Board
- Visa Inc. Form S-1 filing — U.S. Securities and Exchange Commission
- CHAPS operational disclosures and TARGET2 governance framework — Bank of England; European Central Bank
- Project Agora — BIS Innovation Hub