正如整个行业的市场参与者所预期的那样，美国政府将采取行动.S. 5月28日转为T+1结算, 2024, operational readiness is now top priority for firms with trade relationships in the U.S. While many of the larger firms have commenced T+1 testing since the kick-off of the Depository Trust and 清算 Corporation (存)’s programme on August 23, 2023 – with no significant operational issues reported so far – many of the smaller firms are just now beginning to recognize the impact that T+1 is likely to have on their organizations.
相关:T+1的启动状态检查
How can we ensure that moving to the new settlement cycle will be seamless on day one? And how do we ensure that the intricacies of the US 帖子-trade processing chain, 对运营效率至关重要, 是否被全球各种规模的公司清楚地理解?
在美国，肯定是什么意思.S. 交易后的处理?
根据他们各自的时区，美国以外的公司.S. will have less than one business day to process and settle their trades in a T+1 settlement timeline.
准备，非美国.S. 公司必须首先了解美国独有的确认程序.S. ——及其对贸易后加工的影响. 确认书是投资经理或买方公司的确认, 托管人, or prime broker that the trade details submitted by the broker align with their own. 在美国.S., affirmation takes place prior to the transmission of settlement instructions to The Depository Trust Company (直接转矩) via the 存 system called TradeSuite ID，处理交易的确认和电子确认. 相比之下，在美国以外的许多市场.S., 确认过程嵌入在存款系统中, akin to pre-settlement matching between the local broker and the local 托管人 (acting on behalf of the buy-side firm).
有哪些常见的假设?
There are several options on how buy-side firms can execute affirmation: they can either self-affirm or delegate the task to their 托管人s or prime brokers. 更好的是，他们可以求助于技术来自动确认. 不管期权是什么，买方公司都有确认义务.
It’s important to remember that “affirmation” is not the same thing as “settlement”. Affirmation is the step that occurs just before the settlement instruction is sent to 直接转矩 via 存’s TradeSuite ID.
相关:存评论行业肯定进展
因为时间紧迫, 所有确认应在美国东部时间交易当日晚上9点前完成, 直接转矩第一批T+1结算处理截止时间. 但是错过东部时间晚上9点的截止时间并不等同于交易失败.
Trades can still be sent to 直接转矩 for settlement after 9pm ET – by 11:30pm via the Night Delivery Order. The final cut-off time for sending trades to the 直接转矩 is 3:20pm ET on T+1 – leveraging the Day Delivery Order. 在第一个确认截止日期之后结算的交易成本更高. 例如, trades settled via a night delivery costs three times more for the deliverer and two times more for the receiver. 随着贸易量的增加，这些成本加起来可能会相当大.
什么是规管责任?
当美国证券交易委员会(SEC)通过最终的T+1规则时, it instituted new requirements around same-day affirmation (SDA) practices for broker-dealers to help ensure timely settlement in a T+1 environment. 重要的是, the requirement for broker-dealers is that they take certain actions so that 100% of all trades are affirmed as soon as technologically practicable and no later than the end of trade date, and as reinforced by FINRA [the US Financial Industry 监管 Authority] in a recent regulatory notice.
根据目前的T+2结算结构，大约74.5% of trades are affirmed by 9pm ET on trade date – according to 存’s latest analysis dated February 2024.
Firms across the globe run the risk of incurring reputational damage and additional costs due to trade fails or settling trades via delivery orders and non-compliance. Improvement in affirmation rates – aided by technology – can help to reduce the likelihood of trade failure and provide needed efficiency.
进一步, firms should note that the SEC examination division recently issued a risk alert titled Shortening the Securities Transaction 结算 Cycle.
如何解决剩下的问题?
Firms must identify the best approach to manage several cross-border considerations brought about by time-zone disparities. 第一个, resources will be required during off-working hours to process trades on Saturdays and local public holidays and to resolve trade mismatches, and other issues that may arise as trades move through the allocation-confirmation-affirmation sequence. 取决于问题的复杂性和投资授权, 前面, middle or back offices may be required to work collaboratively to clarify and fix trade exceptions.
在一个紧凑的结算周期，最小的误差空间, firms should leverage solutions that automate affirmation and settlement instructions once a centrally matched trade between a buy-side firm and broker occurs, 消除人工或第三方参与. This not only helps to pave the way to settlement finality but also supports faster exception resolution and volume fluctuations.
第二个, firms must review alternatives available to handle foreign exchange (FX) transactions to mitigate settlement risks and avoid pre-funding. Automated solutions to expedite the FX lifecycle are especially useful for firms with high FX volume.
Third, firms should establish best practice for securities landing and inventory management. Digital capabilities are available in the market today to help monitor securities movement to efficiently manage sale notifications and recalls.
最终, 采用先进的, automated operating model – either by enhancing existing systems or relying on available third-party solutions – is pivotal to T+1 success. The urgency to remove operational risks associated with manual intervention is even more crucial in Asia-Pacific given that migrating from T+2 to T+1 reduces the processing time for cross-border trades to just a few hours in some locations. T+1的成功取决于公司内部的效率，无论大小. 通过共同努力和提高自动化, the industry can reap all the benefits that an accelerated settlement cycle can bring, 包括降低资本要求和降低风险.
本文最初发表于 资产 2024年4月17日.