19 June, 2023
The move to shorten the settlement window for securities transactions in the US and Canada by May 2024 aims to tackle instances of market volatility, such as meme stock mania and the COVID-19 pandemic. The transition is the next step in the inevitable journey to real-time settlement. The Association for Financial Markets in Europe (AFME) has also launched a task force to consider whether Europe should follow suit and move to a T+1 settlement cycle. Shortening the settlement cycle has many benefits for financial market participants—transitioning to T+1 can help firms improve operational efficiency, mitigate risk and improve capital and liquidity utilisation.
Trading firms, financial institutions, broker-dealers, custodians, and other market participants in Ireland, with positions in the US and Canadian markets, will be impacted by the SEC's transition to a T+1 settlement cycle. But are firms prepared?
As firms prepare for the T+1 transition, migration plans should consider the potential challenges. They should also provide enough time for market participants—including brokers, investors, and custodial banks—to upgrade their systems and operational processes to minimise trade failures or other related disruptions due to the new compressed timeline.
Firms facing funding challenges will benefit from a shortened settlement window via improved cash flows, leading to increased liquidity in the market and ultimately giving investors quicker access to funds. The market will inevitably see a reduction in counterparty risk, and market participants will see a reduction in the amount of collateral required to cover their potential exposure to market and counterparty risk during the settlement period.
The transition to T+1 will strike a balance by reducing the potential for procyclical behaviour in the market while maintaining appropriate levels of risk-based margin. Depository Trust & Clearing Corporation (DTCC) risk model simulations estimate a 41% reduction in the volatility component of the National Securities Clearing Corporation (NSCC) margin requirement. This could result in billions of dollars of savings for member firms, according to a DTCC white paper.
The transition is also an opportunity to modernise post-trade processing systems through technology adoption and the automation of manual processes. This could significantly reduce operational risk, increase productivity and reduce friction for market participants.
While an increase in initial buy-ins, earlier up-front close-outs and up-front implementation costs are possible in the transition to T+1, the industry expects a long-term cost reduction for market participants and, ultimately, the costs borne by end investors.
By adopting these recommended practices and implementing behavioural changes across the industry, all market participants have an opportunity to standardise and synchronise processes to facilitate greater transparency and attain real-time access to critical data across the financial ecosystem.
The Securities Industry and Financial Markets Association (SIFMA) has outlined its key considerations on T+1 settlement for businesses:
Firms should assess the impact of the T+1 settlement cycle on their business model. While business models are unlikely to be significantly affected by changes in the trade processing lifecycle there may be staffing and workload considerations to take into account. Teams may need to acquire different skill sets to effectively utilise automation tools for these processes.
Firms must consider the various implications for specific product types impacted by industry-level requirements or sub-requirements. For example, there will be better alignment of portfolio shares with mutual funds that currently settle T+1, which can help firms from a cash management perspective. On the flip side, exchange-traded funds (ETFs) often contain underlying securities from different jurisdictions, which can lead to settlement delays in the T+2 cycle. The move to T+1 will make these challenges even harder to overcome.
Firms should ensure that any vendor or dependent service bureau has the support needed to implement end-to-end T+1 trade flows and processes and complement asset service providers in providing up-to-date record-keeping functionalities concerning corporate actions and distributions.
Market participants should review trading venue-specific requirements to changes in the settlement cycle and the impact on ex-date. Also, foreign investors may be deterred from trading in U.S. financial markets if they are unable to pre-fund their trades.
Firms should assess the operational process, procedure and policy changes impacted by the T+1 implementation. Risk management and regulatory compliance must be maintained. Failure to appropriately transform trade processes and relevant systems for the new settlement cycle may compromise their ability to execute and settle trades in accordance with regulatory guidance.
All market participants should evaluate the shortened settlement cycle’s impact on internal and external stakeholders. For example, clients and investors in Europe and Asia may be required to pre-fund cash positions and deposit securities before trading. They will also be impacted by foreign exchange and time zone differences, which will complicate US and Canadian post-trade processing. All of which points to the benefit of Europe and other jurisdictions following a similar transition timeline.
Market participants will want to assess existing technology and schedule updates and testing to support T+1 implementation, given the inevitable move to real-time settlement. Firms should evaluate and enhance technology platforms supporting corporate action announcements, pricing, stock records, securities lending, liquidity management, global markets, options settlement, and primary offerings to avoid operational and data-related issues.
Firms should establish a governance structure and centralised project management office (PMO) to coordinate efforts across different groups and business functions, including operations, technology, finance and risk management.
Firms still handle these processes manually and a shortened settlement cycle will require greater automation. They must also consider the future state of their workforce arrangements, including potentially modifying employees’ working hours, finding alternatives for late settlement instruction inputs and implementing testing processes for end-to-end trade flow to ensure all standard settlement instructions (SSIs) are accurate.
T+1 will affect funding due to the shortened timeframe to complete the settlement cycle. It will also reduce the amount of margin broker-dealers are required to post, free-up liquidity and allow for more efficient capital management.
More frequent contact and demands from clients are expected—particularly for firms with large institutional client bases, given that the time for trade allocations and delivery of cash or securities will be reduced. To ensure all SSIs feed through the entire trade lifecycle, significant client testing will be required for end-to-end trade flow processes.
Firms should carefully consider the opportunities to make more substantial changes with one eye on real-time settlement in the future. For example, firms can enable straight-through processing (STP), such as the trade affirmation process. By reducing manual pre-settlement processes, increased STP rates will help firms prepare for real-time settlement in the future.
Our teams are well-equipped to help you transition to T+1 settlement smoothly. Our operational, technology and regulatory experts can develop all your requirements with a sustainable and long-term approach focusing on:
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