随着US T+1的实施将于2024年5月28日快速临近, investment management firms now have less than four months to make crucial decisions concerning their 帖子-trade pre-settlement process. The more automated and efficient this part of the trade processing chain is, 交易在T+1上结算的可能性就越大. 随着公司做好准备, they must understand and act in the following seven areas to ensure preparedness.
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第一个, investment managers must decide how to make their trade 分配 process as efficient as possible. 在交易执行后, buy-side market participants allocate block trades to underlying accounts and send those details to their executing broker. 分配过程完成后, 每笔交易都通过提供详细的交易记录来确认, 包括交易的内容, 交易日期, 成本, 净值是多少?. 目前, many buy-side firms submit significant portions of 分配s after the US close and concentrated in a 2-hour window. Firms must assess how they can accelerate the 分配 process to make U.S. 最后期限. 同时, 在T+1就位后, investment managers should consider implementing an intra-day 分配 model which involves automating the 分配 process.
第二个, 投资经理必须密切评估他们的交易确认程序, during which the details of the transaction are affirmed by the investment manager or their designated custodian. Investment managers will need to decide whether to outsource this activity to the custodian or whether they want to take on the accountability of conducting this process themselves. 在美国, 贸易肯定, 这使机构能够确认经纪人的确认, 是贸易加工的关键部分吗. T+1结算周期内, this process will need to be completed by 9pm ET on the trade date in order to settle via the most efficient workflow at 存, 允许最小的异常处理时间.
At present, there are no penalties for affirmation not taking place by 9pm. 然而, T+1的实现, trades that are not affirmed by 9pm on trade date will be processed in the next day’s day cycle, 哪个比夜间周期贵得多. 因此, investment managers will need to consider how time zones may impact their 帖子-trade capabilities and whether they will need to work with an outsourced provider to meet the requisite 最后期限 and, 如果是这样的话, 这些服务将如何提供给他们.
综合帐户的困难
第三，投资经理必须了解他们的肯定率. 在美国, 这并不总是直截了当的, as many custodians work on an omnibus account structure which makes it difficult to assess the affirmation performance of individual investment managers. 要解决这个问题, 存 has partnered with several custodians to encourage investment managers to obtain their own TradeSuite ID vs using their custodian’s ID, a practice commonly occurring today especially with investment managers outside of the US. 这将使识别基础投资经理成为可能, as well as provide them with a better view of their overall affirmation rates.
第四, 投资经理应该了解托管人的截止时间, as most custodians have cut-off times considerably earlier than those at NSCC and 直接转矩. 在亚洲, 例如, market participants have the following morning to perform the affirmation process. 在欧洲，情况未必如此. 因此, market participants must understand custodian 最后期限 and decide now how they will approach time zone coverage and whether they will require a third-party to perform the affirmation process for them.
第五, investment managers should explore and adopt standardized and automated standing settlement instruction (SSI) solutions. Accurate SSIs guarantee that trade settlement instructions are sent for the correct settlement accounts. 然而, 因为ssi是不时变化的数据点, firms not leveraging an automated SSI service from a golden source run the risk of using out of date data. Inaccurate or incomplete SSIs are one of the primary reasons for settlement fails. Automation of SSI enrichment from a golden source data set in the 帖子-trade process ensures that standing settlement instructions are always up-to-date and accurate, 这反过来又有助于及时准确的结算.
The sixth step investment managers should consider is leveraging a workflow that streamlines what is currently a multi-step process of 分配 matching in the middle office and then confirmation affirmation in the back office. By automatically triggering 贸易肯定 and the delivery of 直接转矩-eligible securities directly to 直接转矩 for settlement when a trade match between an investment manager and executing broker is achieved, 公司可以加快结算过程. 事实上, firms who have adopted this workflow to match and affirm US trades are already approaching a 100% same-day affirmation (SDA) rate by 9pm on trade date according to 存 data.
最后, the seventh step is for the buy-side to play an active role in meeting the requirements given the amended recordkeeping Rule 204-2, which states registered investment advisors need to make and keep records of confirmations received and 分配s and affirmations sent, 每个都有日期和时间戳.
一个好消息
随着该行业越来越接近美国实施T+1的日期, investment managers face crucial decisions on how best to increase the efficiency of 帖子-trade processing to ensure timely settlement. The most important decision to make from the outset is to evaluate whether the 贸易肯定, 分配, and matching processes should be managed in-house or whether it is better for this function to be outsourced to a third-party provider. The good news is that automated 帖子-trade solutions are available today and are already delivering risk mitigation, 以及运营效率效益, 对市场参与者和整个行业.
这篇文章发表于 欧洲基金 2024年2月26日.