There was a time when institutional investors in Asia had to settle their US securities transactions in five business days following trade completion, 或T + 5. 然后, in 1995, the US Securities and Exchange Commission (SEC) implemented a T+3 settlement cycle, 随后在2017年加速到T+2.
相关:为什么后贸易自动化必须占据中心舞台
All of these were achieved thanks to industry collaboration and technological and process advancements. 快进到今天, 美国证券交易委员会宣布在美国实施T+1和解协议, 5月28日生效, 2024. Shortening the settlement cycle to T+1 should bring many benefits to the industry, 包括降低风险, 降低结算资金要求, 提高资本和流动资金的利用率, 提高了运营效率.
它也将带来独特的挑战.
结算周期缩短一个工作日, firms will have less than 24 hours to complete the required operational tasks prior to settlement. 在没有实时操作处理的情况下, 几乎没有犯错的余地，也没有解决问题的时间.
As the SEC’s new ruling requires broker-dealers and their counterparties to complete allocations, 确认, and affirmations as soon as technologically practicable and no later than by the end of trade date, allocating additional resources to manage 帖子-trade activities is no longer a viable option. 在新的T+1环境中, the industry is proposing that trade affirmations be completed by 9:00 pm US eastern time on trade date to enable same day affirmation (SDA) and trade settlement on the due date.
In a condensed timeframe of T+1, behavioral 流程 need to be updated. That means that fundamental changes need to happen between counterparties, including moving away from manual 流程 like emails and faxes and adopting automation.
操作需求的变化
Let’s first look at how the transition to T+1 will affect the processing of institutional trades.
在美国清算和结算框架中, the processing of institutional trades essentially requires investment managers to allocate block trades accompanied by trade settlement information, 或长期结算指示(ssi), 给他们的经纪人. Brokers confirm the trades by providing a detailed record of the transaction, 包括交易的内容, 交易日期, 成本, 净值是多少?. 然后，肯定过程就开始了, requiring investment managers or their appointed custodians or prime brokers to affirm the trades.
These operational steps will now need to be completed on trade date in order for matched and agreed trades to be seamlessly sent to settlement. 用更少的时间在结算周期, 交易后流程的自动化将是成功的关键.
确保合规, firms should embark on an impact analysis to assess current 流程 and technologies so as to determine whether changes are needed. It will be helpful to consider digital and analytical tools in the assessment 流程 in order to obtain metrics on current operational efficiency rates and gain new insights relevant to T+1. These insights can enable firms to correct or anticipate potential operational obstacles.
还有不到一年的时间，我们都准备好迎接T+1了吗?
最终, adopting increased levels of automation and enabling end-to-end straight through processing (STP) across the 帖子-trade processing lifecycle will be critical in preventing operational breaks and ensuring that trades settling in the US are settled in accordance with a T+1 settlement cycle. 另外, 适用于所有注册投资顾问, using digital tools to archive historical trade records will address new record-keeping requirements.
对亚洲的影响
Firms in Asia will need to remove any friction in their operational 流程 and ensure efficiency across time zones to expeditiously match and settle trades on time when trading in US markets. 除了提高自动化程度, 利用中心化的, automated database of SSIs with up-to-date information on settlement and account details will accelerate STP and should reduce trade mismatches and potential trade failures.
同时, 亚洲的公司必须考虑跨境贸易的融资问题, which typically takes place when trades have reached matched-agreed status.
看看T+1交易结算所需的紧迫时间框架, the industry could take a page out of India’s book on managing foreign exchange (FX) demands when the country moved to T+1 in a phased implementation timeline. 以印度为例, the entire industry came together to address the challenges associated with the FX 帖子-trade workflow, 包括外汇流动性. 考虑到每个地方市场的细微差别, a one-size fits all approach to manage FX financing will not work in Asia.
The recommendation is to review FX requirements at the fund-level or consider a combination of in-house and outsourced solutions, 与指定的保管人及中介人合作. 另外, investment managers could provide standing funding instructions to their custodians to immediately release funds upon trade completion. 这种方法适用于将资金存放在托管人那里的情况.
前面的路
距离美国T+1实施日期不到一年, firms in Asia are racing against time to put in place an operating framework to ensure compliance with the forthcoming mandate. While it may be tempting to address the T+1 operational challenge with incremental adjustments to systems and 流程, 从长远来看，交错修复可能会使公司面临更大的风险和成本.
Traditionally, investments in the middle and back offices have not been a top priority. 也就是说, now is the time to seriously consider a strategic and holistic investment to simplify 帖子-trade processing by building a zero-touch environment from trade execution to settlement finality. 该解决方案将有助于降低运营成本和风险, and can help to future-proof against evolving regulatory obligations and unprecedented events.
企业应该寻求指导并咨询专家, 根据需要, 评估前后证券工作流程, 应对全球市场结算周期的错位, 最重要的是，确定迁移到T+1所需的关键更改.
我们可以从“现在投资”中学到很多, 在实施涉及人员的变更管理时，“以后节省更多”, 流程, 和系统. 现在是准备的时候了.
本文最初发表于 WatersTechnology 2023年6月20日.