The U.S. Securities and Exchange Commission (SEC) recently proposed rule changes to accelerate the settlement cycle to T+1. 如果采用规则变更，则U的周期为T+1.S. 股票交易可能在2024年实施. 为了帮助企业规划和准备转向T+1结算周期， DTCC推出了一系列虚拟论坛 to help clients and the industry understand some of the potential impacts of the transition to a T+1 Settlement Cycle on specific DTCC processes.
相关:从加速到T+1系列中发现更多
在本系列的第4篇文章中, Matt Schill, DTCC高级vnsr威尼斯城官网登入管理总监, 主持了一个由Natasha Singh-Mohamed组成的小组, DTCC副主任, NSCC Operations; Christopher Thiebaut, 贝莱德董事, Head of U.S. Corporate Actions; and Steven Gale, 北方信托公司副总裁, Asset Servicing, 讨论T+1结算周期对企业行为的影响.
The group opened the discussion with an outline of key considerations around the complexities of the Notice of Guaranteed Delivery (a.k.a. (对某些公司行为的保护). 交货保证功能的一大挑战, 哪些不是标准化的，也不是强制性的, is that shortening the settlement cycle makes the process riskier and more manually intensive than it was ever intended for. Some impacts of the voluntary corporate action event process under a T+1 scenario discussed on the panel included:
- 债务的最后期限和时间安排
- 加速结算周期如何缩短保险/保障期限
- 代理之间的自愿企业行为事件沟通过程, DTCC和其他行业参与者
CNS Implications
对DTCC处理计划的更改, 包括夜间周期, will affect submission times of protect instructions for Continuous Net Settlement (CNS) eligible voluntary events. The new process for a T+1 settlement means long members will enter protect instructions from 9:45 - 10:45 p.m.在夜间周期开始之前，晚上11点半开始.m. on trade date.
Electing on input date provides the long member with the highest priority to receive CNS allocations during the night cycle. 在夜间周期之前, short members can view potential liabilities; after the night cycle, long members are able to view potential protects and view if they have received any CNS allocations during the night cycle.
Singh-Mohamed指出, 一旦潜在的责任已经发布, CNS will not accept additional trades that settle on Cover/Protect Expiration Date for any security undergoing a voluntary event. 它们将由北卡罗来纳大学以贸易换贸易的方式进行处理.”
中枢神经系统的建议
由于在T+1周期中减少了一天来平衡CNS交易，DTCC建议:
- 参与者使用夜间周期前的中枢神经系统位置文件/报告
- Identify their final CNS positions and if they are a long member input their protect instructions in CNR on input date before 10:45 p.m.
- For same day settling trades received on Cover/Protect Expiration Date where NSCC is making them trade-for-trade balance orders, 参与者应该利用新的, real-time summary and balance order messaging to identify counterparties earlier so they can pass liabilities to each other earlier on Cover/Protect Expiration Date
处理痛点的企业行动
- 压缩时间: Managing expectations and implementing both operational and technical changes are all needed to move to T+1. 为自愿的公司行动事件, both reconciliation and timely settlement of trades on securities undergoing a corporate action is critical. Taking a comprehensive approach that will allow each firm’s system to consume the corporate action event announcement create client entitlements, 进行贸易对账以确定负债, and then ultimately tie-in the client instructions to DTCC all in a timely fashion is key to reducing risk, said Thiebaut.
- 持股地点: Already a key concern for global custodians in the current T+2 settlement cycle, determining where their firm’s inventory is located is paramount to day-to-day operations since it determines the both the nature of and timelines to be considered per corporate action event. 迁移到T+1将增加这些担忧，因为某些关键的权利日期. Capturing and sending messages in near real-time can help global custodians meet deadlines, and the automation of instructions using DTCC’s Voluntary Reorganization Instructions (VRI) process through ISO 200022 and API calls will help create efficiencies and mitigate risks.
- 行业合作根据Gale的说法, 每个人都需要支持他们的流程, 有更多的审查, oversight, 以及他们所服务的所有市场的意识, 包括欧洲和亚太地区. 注意到并非所有国家都在同步转向T+1结算周期, it is important that consideration is given to this fact as it relates to complex processes such as the corporate action event. Firms should use systematic messages that flow across the lifecycle wherever possible to eliminate the need for manual intervention. And consistency across the corporate action event lifecycle is just as important—with events, event specific dates and ultimately instructions differing per custodian for the same event. The industry needs to continue to collaborate to standardize these event processes and therefore industry trade groups like the ISITC Corporate Actions Working Group and the SIFMA Corporate Actions Forum where topics like these are discussed play such a critical role in the move to the T+1 settlement cycle.
Next Steps
Firms should start planning early and look across systems and business processes that could be impacted; create an inventory of applications may be impacted by the move to T+1 and review documentation from the T+2 migration to identify nuances within previously updated systems.
Testing will be key, and firms should look at test environments to begin that process. DTCC will be distributing two testing papers; the first will be a high-level testing plan and second, 描述DTCC测试的更详细的测试计划. 这些论文将于2022年下半年发布.
Lastly, trade fail management and exception processing due to trade fails may be on the uptick during the initial move to a T+1 settlement cycle. Leveraging newer services like DTCC’s ClaimConnectTM to foster straight-through claim processing, transparency and automation in a very cost-effective manner will help the industry limit exposure and ultimately provide full exception processing support during the onset of the migration.