今年2月，美国政府宣布.S. Securities and Exchange Commission (SEC) 2024年5月28日宣布 as the 实现ation date for the move to T+1 settlement for transactions in US cash equities, corporate debt and unit investment trusts.
就在这个声明之后, / (1,500 global 客户 and industry participants joined 存的 latest "加速到T+1系列虚拟论坛, 2023, to learn from a panel of industry experts about how global custodians can support a T+1 environment.
Related: Discover More from the 加速到T+1 Series
Below are highlights from the discussion:
关键日期和规则
With the 实现ation date for US T+1 settlement set for 五月 28, 2024, 一些重要的日期包括:
- 2023年8月14日星期一: 存的 bi-weekly testing schedule begins. (存的 完整的测试日程表, updated to reflect latest details and announced 实现ation date, is available on UST1.org)
- 2024年5月24日星期五: 美国T+2结算的最后一天
- 2024年5月28日星期二: 美国T+1结算的第一天
- 2024年5月29日星期三: 特别双结算日(与 activity from two trading days settling on a single day)
The Canadian market has indicated it plans to move to T+1 on the same day as the US. However, Memorial Day in the US, Monday, 五月 27, 2024, is not a holiday in Canada. The Canadian market is still finalizing its T+1 实现ation plan.
The move to T+1 affects all firms that trade in the US, not just custodians. 例如, Broker-Dealers need to develop processes that reasonably ensure trade allocation, confirmation and affirmation of institutional transactions as soon as technologically practicable but no later than the end of trade date. Registered Investment Advisers need to develop and 维护 records of each confirmation received. Central Matching Service Providers (CMSPs) need to establish, 实现, 维护, and enforce polices that facilitate straight-through processing. A complete list of the requirements included in the SEC T+1 Rule can be found 在这里.
保管人以客户为中心
Although custodians are not part of Rule 15c6-2, they need to ensure their own 客户 are sending instructions on a timely basis or self-affirming by the required time. 重点关注的领域包括:
- 客户端准备: Most larger asset managers and broker-dealers have their plans well underway, 然而, many mid- and small-tier firms are lagging.
- 非美国资产的影响: Firms need to understand misalignments due to changes in ADRs and ETFs that contain non-US securities.
- 新规的影响: 所有 客户, 甚至包括美国以外的客户, need to review the rules to ensure a complete understanding of their commitments to ad在这里 to the new regulation.
为变化做准备
Training and outreach are key to ensuring a successful transition, both within and outside the US. Removing a full 24-hours from the trade lifecycle will require firms across the globe to make significant operational and technical changes. 客户可以通过以下方式开始准备工作:
- 评估运营模式
- Finding the causes of exception processing as the window to correct failed trades is small
- Considering outsourcing w在这里 appropriate
- Considering the adoption of industry standards and solutions
- Evaluating systems for securities lending and focus on inventory management
- Engaging with custodians, industry associations and working groups
Whether a firm uses their custodian for affirmation or self-affirms, proper instructions are vital. 存的 中医与指令匹配(M2i) is a building block for both the buy and sell side, allowing automated affirmation and creating a more efficient model that reduces the need to repair and the risk of fails.
全球T+1未来
Given the global nature of today’s securities markets, misalignments will inevitably happen. The best remedy is to be well-prepared, as the move to T+1 in the US has sparked discussions around the globe. 印度已经进入了T+1, while Canada will move with the US and Mexico has initiated conversations. The UK has also formed an industry task force with initial findings expected by the end of the year and further discussions are anticipated in Europe. Australia, Japan, Hong Kong and Singapore are watching the situation closely.
所有 firms need to assess now to truly understand the end-to-end impact of the move. By understanding the rules and what is expected and ensuring that technology, 对软件和供应商进行测试, firms can be ready to go for next 五月’s 实现ation date.
虚拟论坛系列的下一个活动
The next event in this highly successful virtual series will be held on March 14, 2023, w在这里 行业准备 会是讨论的主题吗. The event will feature an update from a panel of experts who will discuss new industry research on how global firms are preparing for T+1. 有兴趣的公司可以 注册在这里.
视图 UST1.org for all news, documentation and information related to the industry's effort to accelerate the U.S. 证券结算周期.