从事资本市场行业从业30余年, I often engage with the industry and speak at events on a number of topics including the upcoming 美国将于2024年5月28日向T+1过渡.
从我最近的演讲和与客户的谈话中, it was good to hear that APAC firms who have US-based trading counterparties are aware of the US move to T+1, and most have spoken with their brokers and custodians to form a plan of action for the upcoming transition.
相关:了解你的T+1盲点
对于那些在美国有大量交易的公司, many have embarked on a holistic review across systems and processes and have identified enhancements to meet compressed settlement timelines. 其他人, 尤其是那些销量较低的公司, are considering making necessary changes after assessing the actual impact of T+1 帖子-transition, 这可能会使合规更具挑战性.
因为这个行业离T+1实施还有不到一个月的时间, 企业必须考虑成功的关键，以确保平稳过渡, 包括测试, 了解美国的肯定过程, 为即将到来的实施周末做准备.
确保平稳过渡
When the US Securities and Exchange Commission (SEC) adopted the new rules, 它指出，机构交易必须进行分配, 确认, and affirmed as soon as technologically possible and no later than end of trade-date, 简称“同日誓词”.
亚太地区, SDA would loosely translate to completing pre-settlement matching on trade date, 这在中国和印度已经是常态了吗, and which would be a must-have for any market contemplating to accelerate their settlement cycle.
While achieving a higher SDA rate may have been challenging a decade ago, there are automated technology solutions already available to help firms successfully achieve SDA to ensure timely T+1 settlement.
相关:T+1前行业肯定进度分析
理解肯定的作用
In US 帖子-trade processing, affirmation is a critical step in facilitating settlement. Affirmation signifies agreement between the investment manager and the broker on the trade details as a precursor to settlement.
The buy side affirmation task is performed by an institutional investment manager or delegated to a custodian or prime broker to agree to the trade confirmation details sent by the broker. The affirmed trade then activates the delivery of settlement instructions to the US depository, 存托信托公司(直接转矩). This process is akin to the pre-settlement matching or pre-matching workflow in APAC.
鉴于缩短的结算时间, non-US investment management firms must engage their custodians and/or prime brokers on which party and which workflow will best position them to complete the affirmation process as quickly as possible.
It is important to note that to achieve SDA and T+1 settlement timelines, 直接转矩 recommends trade allocations be done as soon as practicable but no later than 7:00 PM Eastern Time (ET) on trade date, and the US T+1 Industry Steering Committee recommends trade confirmation and affirmation be completed by 9:00 PM ET on trade date (T). Doing so will provide sufficient time for managing exceptions ahead of the T+1 settlement deadline.
Given that custodians will have a separate set of deadlines for pre-settlement processing before the allocation and affirmation cutoff times, non-US investment management firms will need to adjust their internal operations and associated systems by leveraging straight through processing to meet these recommended deadlines as well as to allow for sufficient time to address and resolve pre-settlement exceptions. 像这样, removing manual processing and human intervention in the processing of trades will be a crucial part of the T+1 equation.
把I点起来，把T划掉
5月28日的倒计时还在继续, there are a few helpful reminders for non-US investment management firms:
- Collaborate with your regional and US brokers and prime brokers on the changes needed to enable them to comply with SECvns6060威尼斯城官网满足SDA要求的修订规则.
- 与您的保管人讨论合适的确认模式, 无论是近期还是长期, 以及评估对公司行为的潜在影响.
- Determine how funding and foreign exchange (FX) transactions should be processed and work with your custodians and FX providers to find the optimal funding and FX solution, 包括外汇兑换时间.
- Agree with your intermediaries on the timing of recalls and a fallback mechanism, should a recall not be met on time for firms involved in securities lending activities.
- 确保你符合 修订顾问法案规则2024-2 通过保存收到的确认记录, 拨款和确认已经发出, 完整的日期和时间戳-美国的要求.S. 美国证券交易委员会注册投资顾问.
- Confirm with your system providers that their processes and support are ready to manage the changes required for T+1 and that workarounds are in place to quickly address operational issues, 如果有任何.
为T+1转换周末做准备
为了确保在2024年5月28日顺利切换到T+1, 存发布了一份 全面的T+1转换指南 详细介绍存在T+1转换过程中将采取的步骤, along with changes that will be effective upon implementation of the T+1 settlement cycle.
The guide includes materials on 存’s timeline to convert its production environment from T+2 to T+1 settlement cycle, 详细介绍了T+1的系统和处理变化, and shares information on client support during the T+1 conversion period.
该指南还指出，有组织的证券交易所(NYSE, 纳斯达克(NASDAQ)和美国金融业监管局(FINRA)已同意不执行2024年5月28日的规则, as an Ex-Date for corporate action distribution events to avoid complicating the migration process.
觉醒的日期
28 May 2024 is not the end date for T+1 preparations; rather it is an awakening date for all of us to fully appreciate the magnitude of the impact and benefit that accelerated settlement brings. We are all working incredibly hard to make the conversion weekend as successful as possible while also being prepared for contingencies.
在我们接近T+1筹备旅程的尾声之际, firms should ensure readiness and be prepared to handle the potential spikes in trade exceptions and fails during the transition. The T+1 implementation date for the US is right around the corner – the time to finalize preparations is now.
本文最初发表于 亚洲监管 2024年4月30日.