The impact of accelerated settlement on the broad financial ecosystem was the topic of a recent FIS Global panel featuring 约翰亚伯, 存执行董事, 结算服务. Abel加入了一个由业内同行组成的杰出小组, 包括汤姆·普莱斯, SIFMA常务董事, 操作, Technology and BCP; Robert Walley, 主要, 德勤 & Touche LLP; and moderator, Susan Crozier, FIS Global Head of 监管 and Industry Affairs.
A shortened settlement cycle of T+1 or even T0 has been discussed for years, since even before the industry moved from T+3 to T+2 in September 2017. 然而，存最近的白皮书，Advancing Together: Leading the Industry to 加速解决,，于2021年2月上映, 是否重新引起了人们的兴趣, active dialogue and now the creation of industry working groups to discuss the impact and implications of an abbreviated settlement cycle on the financial ecosystem.
《T+1之旅
Market volatility in 2020 and the meme stock frenzy of early 2021 generated intense interest in the trade lifecycle from both Capitol Hill and regulatory agencies. 美国的听证会.S. House Financial 服务 Committee underscored the importance of shortening the settlement cycle.
今年早些时候， 存, ICI和SIFMA began an exploratory discovery process for T+1 with the ultimate goal to reduce risk, modernize systems as well as gaining operational and capital efficiencies.
德勤 & Touche worked with the industry in 2017 to develop a roadmap to T+2 and is playing a similar role in the current process. An industry T+1 Steering Committee was formed to provide overall guidance and support to the effort. 除了, industry working groups with robust industry participation were formed to determine the impacts and challenges of shortening the settlement cycle. 韦利评论, 每天有多达200人参加电话会议, this is more than just accelerating the cycle — it's about modernizing settlement functions both within the industry and within member firms.”
缩短周期的挑战
在评估缩短周期的影响时, the industry is looking at approximately 20 functional areas across six dimensions that include very specific functions, 比如证券借贷, 大宗经纪和外汇. 类似于移动到T+2, 有大量的工作要做, preparation and testing that need to be accomplished with a goal of full industry engagement.
While the move to T+1 generally entails changes to business processes, 不一定是底层技术的改变, the compressed timeline presents unique opportunities for 存 and the industry to reexamine the timing of end of day events. 存’s 机构贸易处理 (ITP) business automates 帖子-trade life cycle events between 6,在52个国家的000家vnsr威尼斯城官网登入公司. 这些关键的贸易功能, 包括分配, 确认和肯定, 在交易日结束后开始. Ensuring there is ample time for these functions to occur before starting the next business day will impact the existing processing schedule.
Abel explained how 存’s current process begins after the trading day ends, which means all functions will need to happen between the end of the trading day and the beginning of 存’s night cycle. To accommodate the move to T+1, the industry has proposed moving processes to later in the day.
| |
当前(T + 2) |
新(T + 1) |
| 直接转矩夜间循环开始 |
8:30PM s - 1 |
要不是s - 1 |
| 肯定截止 |
十一点半s - 1 |
9:00 s - 1 |
| 企业可获得的直接转矩输出 |
散尽s - 1 |
结算日期1:30AM |
| |
|
|
在移动到T+1时，结算减-1将成为交易日期
|
时间调整, 虽然看起来微不足道, may represent a substantial change and impact on certain members throughout the industry. Each component and function in the trade lifecycle may need to be reviewed holistically to understand the interdependency between the various components and potentially modified. 另外, 修改需要在行为的背景下进行审查, 技术和监管影响. 可以利用自动化来提高效率. 鼓励会员审查和利用行业解决方案, 例如贸易促进计划的中央贸易配对平台, 如果有.
Another challenge facing the industry is the discussion of moving to night of trade settlement or even real-time gross settlement. While the technology is currently available to support for some products, and T+1 and T0 settlement is used today by 直接转矩 and NSCC for millions of transactions every day, 这不是整个行业都能达到的.
Obstacles to a T0 settlement include funding with an FX conversion and securities lending. 普赖斯指出，过渡需要彻底, diligent and pragmatic with coordination of processes and behaviors of the buy and sell side. The industry’s primary goal is to create efficiencies without introducing any additional risk to markets.
对市场参与者的影响
The entire financial ecosystem will be impacted by the shortened cycle and participants agreed that the best way for firms to prepare is to be engaged. 亚伯补充说, “The industry working groups are key — there is tremendous engagement and dialogue as we work to understand challenges and craft solutions.”
监管指引
While the move to T+1 is industry driven and not a regulatory mandate, 存, ICI和SIFMA已向监管机构寻求指导. Using the 2017 move as a roadmap, regulatory partners will need to identify all rules to be adjusted. 具体而言，工作组已要求SEC审查 15 c6-1规则，采用T+2结算周期. Other areas that will need regulatory review include securities lending, 拨款及确认, 客户文件(招股说明书), 以及确认的时间 规则10 b-10, which requires information to be delivered to customers at or before completion of the transaction.
缩短结算时间，提高效率
美国.S. 证券行业是世界上流动性最强的市场, and any change must be made without introducing any additional risk to the system. 通过消除一天的结算周期, 风险也相应降低了, leading to margin reduction and achieving greater capital efficiencies. There is also funding efficiency as investors will have quicker access to funds, 向行业标准迁移时的处理效率, normalizing and creating more common data standards across the ecosystem, and using technology enablers that coordinate multiple market functions.
Abel这样总结了讨论, “Industry consensus has been that T+1 provides a host of benefits to the industry and is a manageable effort.”