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The financial world is in a constant state of evolution, with regulatory bodies like the U.S. Securities and Exchange Commission (SEC) continually seeking ways to enhance market efficiency, stability of the capital markets, and investor protection. One such recent development is the change from the standard securities settlement cycle to T+1 settlement, a significant change poised to streamline stock trading processes and reduce risks in the market. This new rule becomes effective May 28, 2024.
Traditionally, stock trades in the United States have settled on a T+2 basis, meaning transactions are finalized two business days after the trade date. This time lag has been a longstanding feature of the market infrastructure, allowing for various back-office processes to be completed, such as the clearing and reconciliation of trades.
However, in an effort to modernize and expedite these processes, the SEC has introduced T+1 settlement, shortening the settlement cycle from two days to just one. Under this new regime, trades executed on a particular day would be settled the next business day.
Reduced Counterparty Risk: With shorter settlement times, the window of exposure to counterparty risk is significantly reduced. This means that buyers and sellers are less vulnerable to default by their counterparties during the settlement period, enhancing overall market stability.
Enhanced Liquidity: By accelerating the settlement process, T+1 settlement frees up capital more quickly, allowing investors to deploy funds into new opportunities sooner. This increased liquidity can lead to more efficient capital markets and better price discovery.
Lower Margin Requirements: Shorter settlement times can potentially reduce margin requirements for market participants, as the need to collateralize trades over an extended settlement period diminishes. This could make trading more accessible to a broader range of investors and reduce costs associated with maintaining margin accounts.
Mitigation of Operational Risks: T+1 settlement minimizes operational risks associated with longer settlement cycles, such as failed trades and discrepancies in trade confirmations. By shortening the timeframe for trade settlement, there is less opportunity for errors to occur, promoting greater reliability and accuracy in transaction processing.
While the transition to T+1 settlement offers numerous benefits, it also presents challenges that market participants must address:
Operational Adjustments: Brokerages, clearing firms, and other market intermediaries will need to adapt their systems and processes to accommodate the shorter settlement cycle. This may require significant investments in technology and infrastructure upgrades.
Increased Workload: The compression of settlement times could lead to a more intense workload for back-office staff, particularly during periods of high trading volumes. Firms may need to bolster their resources to handle the increased demand effectively.
Regulatory Compliance: Market participants will need to ensure compliance with regulatory requirements related to T+1 settlement, including reporting obligations and risk management protocols. Failure to adhere to these standards could result in sanctions or penalties from regulatory authorities.
As an RIA, the SEC's new T+1 settlement rule presents few challenges for RIAs in terms of operational adjustments, risk management, and compliance obligations.
Operational Adjustments: The effect on RIAs is minimal but they may need to adjust their internal operational processes to accommodate the shorter settlement cycle. This could involve upgrading technology systems (not required for Firms working with tru), revising trade execution and reconciliation procedures, and enhancing communication channels with custodians and clients. As mentioned in the previous section, the largest lift will be on brokerages, clearing firms, and other market intermediaries.
Risk Management: RIAs need to assess and adapt their risk management frameworks to account for the compressed settlement timeframe and ensure adequate safeguards are in place to protect client assets. tru is continuously providing you with this service.
Compliance and Regulatory Oversight: As we all know, RIAs are subject to regulatory oversight by the SEC and must ensure compliance with the new T+1 settlement rule and related regulatory requirements. This may involve updating compliance policies and procedures and implementing enhanced monitoring and reporting mechanisms. This will be done for you by your Compliance Team at tru.
Please review any communications you have received from your custodian closely and review any questions with them as each custodian may have different updates or requirements.
The SEC's transition to T+1 settlement marks a significant milestone in the ongoing evolution of financial market infrastructure. By shortening the settlement cycle, this initiative aims to enhance efficiency, reduce risks, and improve overall market resilience. While implementation may pose challenges for industry participants, the long-term benefits of T+1 settlement are expected to outweigh the initial adjustment costs, paving the way for a more agile and robust trading ecosystem.
Please contact your tru CCO or email compliance@tru-ind.com with any questions.