The move to T+1 is approaching, and firms need to plan, prepare and test. That was the common message from a panel of experts in the latest installment of 存’s 加速到T+1 系列讲座. Prior sessions have covered the gamut of trade processing, from timelines to 存 detailed functional requirements and regulatory issues.
大卫·柯比主持, 存 Head of Americas Relationship Management, the latest session focused on how firms should prepare for T+1 testing, with insight from Bob Cavallo, 据导演, 间隙 & 结算 Product Management, 查克Billikas, 存 Executive Director, Global 集成 and Eleanor Parker, 存管经理, 咨询服务.
Below is a summary of the discussion:
Driving Accelerated 结算
存 has been preparing for a move to T+1 since releasing the 2020 white paper Leading the Industry to Accelerated 结算, which was followed by executive summary sessions, industry working groups, white papers and client webinars. One of the most recent steps towards an accelerated settlement cycle was the 存 T+1测试方法 functional paper that was released in early August, focusing on a high-level testing structure. The paper and latest information on the move to T+1 can be found at UST1.org.
Billikas指出, “We’ve done a lot of work to get where we are today, and we still have more work to do from a 存 and industry perspective.”
It’s Time to Begin Testing
The Securities and Exchange Commission (SEC) has proposed the switchover to T+1 occur on March 31, 2024. 然而, given the magnitude of testing, 存, along with industry partners SIFMA and ICI, have requested that the SEC shift the implementation date to September 3, 2024, which is the Labor Day holiday.
Until further guidance is received from the SEC, 存 is moving ahead with plans to meet the proposed March 2024 date.
“The goal is to give firms an appropriate amount of time to test, and we are cautiously optimistic that the SEC will align around the Labor Day 2024 industry proposed transition date,卡瓦洛说. “If it turns out to be the September date, 存 plans to open its 存 PSE U testing region in the fourth quarter of 2023, but if the March date is ultimately chosen, we will open our testing window for the second quarter of 2023.”
While T+1 testing will not be mandated, 存 recommends that member firms participate in testing to ensure they are prepared. To help firms with their planning and testing processes, 存 has set up three interactive testing sessions utilizing the 存, SIFMA, and ICI T+1 Industry Working group in November 2022 that will provide a view into 存’s plans, key dates and an opportunity to speak with product managers and integration and technology teams.
“The goal of the sessions is help complete a detailed testing document, which we plan on releasing to the industry in the December 2022 or January 2023 timeframe,卡瓦洛说.
Parker added, “There is no one-size-fits-all when it comes to testing. Firms should consider the various processes impacted by the T+1 functional changes and determine their scope of testing.”