Mixed views on deadline for settlement change

Mixed views on deadline for settlement change

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From Pirum’s participation in industry working groups (and as it relates to securities lending activity) the consensus of market participants is that the proposed deadline of mid-2024 for moving to T+1 in the US is an appropriate and natural progression to the continuing operational advancement and efficiency of US market settlements, observes Bob Zekraus, the firm’s chief operating officer and head of the Americas.

“That being said, there is an appreciation and acknowledgment that more work needs to be done to harmonise the market for a move to T+1 settlement,” he says. “The move to T+2 five years ago was more behavioural in nature, whereas the move to T+1 is much more technical and thus requires more time to analyse operational processes with the focus on recalls, affirmation, and increased emphasis on real time automated connectivity between lenders and borrowers compared to the current outdated model of batch processing.”

Zekraus observes that market participants are exploring both existing facilitators and areas of development to help realise the future changes to market structure in an accelerated settlement cycle.

“The consideration for clients to look at the holistic events on the lifecycle of transactions has become of greater importance as businesses look to better manage and mitigate risks and exposures,” he says.

Recall considerations

From a recall perspective, the action for the lender to notify and the ability for the borrower to receive, consume and process recalls automatically become paramount given the shortened settlement cycle and eroding timeline to action, source/cover and collateralise obligations as required. However, it is also intrinsically linked to having straight through processes and automation for additional post-trade events such as mark-to-markets, returns/call backs, contract compare, fund switches and loan reallocation, says Zekraus.

“It is the client participation, budget, and prudent risk management appetite to enhance operational efficiency and move off manual processing that will ultimately transform the market ecosystem by reducing risk from antiquated processes,” he adds.

According to Zekraus, market leaders, service providers, vendors and clients all agree that the industry has a long way to go before having the ability to realise a change of the magnitude of T+0.

“The application and demonstration of further technology enhancements will drive the push for real time gross or periodic same day netted settlements in the markets,” he says. “The pragmatic approach for risk mitigation and appetite will continue to drive change - we feel it is a walk before you run situation.”

Critical processes

More time is always preferable, especially when the change has a direct impact on day-today activities such settlements that feed into other core and critical processes such as the production of NAV and foreign exchange. It would be ideal if T+1 was the only major item that participants had to attend to, but this is not the case. That is the view of Dexter Gall, associate director securities finance at RBC Investor & Treasury Services, who notes that most market participants - in conjunction with various fintech partners - commenced efforts ahead of CSDR.

“The technology is available, but requires changes as well as increased utilisation and integration of existing tools to be better prepared and achieve desirable outcomes,” he says.

Gall describes T+0 as a great goal to aspire to but suggests the extent of the benefits is unclear when balanced against the investment required.

“Most securities finance transactions conducted in North America are on a T+0 basis and extension to other parts of the financial system would likely require technological adoption such as distributed ledger technology,” he adds.

There is a fair amount of trepidation related to the implementation of T+1 as a result of the compressed timelines in the post-trade processes, according to Mike Norwood, head of trading solutions at EquiLend.

“However, in general market participants can see the broader benefits,” he says. “While from a trading perspective shortened settlement cycles are a benefit in that they reduce counterparty risk and lower margin costs, recalls in particular become an issue given the lack of real time sell notifications across the industry.”

Acceleration benefits

Considering the meme stock phenomenon from last year and the increased volatility across the market seen throughout the first half of this year, the benefits of accelerated settlement are as important as ever as the focus on costs of capital and balance sheet/ RMA concerns are becoming increasingly prevalent.

An appropriate level of automation is in place to facilitate shortened settlement cycles, says Iain Mackay, EquiLend’s head of post-trade solutions.

“There are technical solutions available now for participants to embrace and the priority should be with them to understand how they can maximise usage,” he adds. “Managing your positions whilst the trade is open will be crucial to ensure there are no breaks which could impact the return leg settlement. Leveraging unified comparison tools will be essential.”

When asked how market participants feel about the proposed deadline of H1 2024 for moving to T+1 in the US, Chris Rowland, head of custody product at State Street, suggests a more realistic date would be over a three day weekend in September 2024 (Labor Day weekend) or May 2024 (Memorial Day weekend).

“In fact, T+1 was a major topic of discussion at the DTCC advisory council quarterly offsite in May and many members share our concern about the compressed timeline,” he says. “We feel that the industry would need sufficient time to plan for, implement and test changes to our systems, operations, policies and procedures, and also to engage in outreach and education to our client base.”

Potential dislocations Rowland says market participants accept there is a need to make wholesale changes to the existing trade flows and practices and that there is a considerable industry support for moving to T+1, but also warns of concerns on potential dislocations in US markets focusing on ETFs, securities lending, FX funding challenges and increased settlement fails.

“One of the considerations we will need to address in planning efforts are changes to trade matching systems and processes, tighter deadlines for the receipt of client trade instructions and the resolution of any potential pre-trade problems, and the implications of T+1 settlement for various asset servicing functions such as the processing of corporate action events, income distribution and cash funding requirements,” he says. “The implementation of T+1 settlement will also require a reassessment of existing industry processes in foreign exchange, securities lending markets, cross border trading and the operational model for exchange traded funds.”

Rowland believes T+1 can be achieved with existing systems and processes, but that the move is both a market structure and a technology compression event as it broadens what and who will be impacted in the marketplace.

“A move to T+0 has been widely discussed, but we think that this is not the right time given the substantial increase in complexity and disruption of products and process,” he adds. “While conceptual problems can potentially be resolved by agreement among the various industry players, the breadth and complexity involved with same day settlement has wide ranging implications for the entire financial system.”

Same-day settlement would require a fundamental overhaul of the existing clearing, payment and settlement ecosystem for the US market and demand wide scale use of emerging technologies, such as digital ledger technology and instantaneous or near instantaneous payment functionality, to drive further automation and efficiencies.

Industry challenges

While the securities finance community recognises the expected benefits of a move to T+1 settlement in the broader equity market, it presents particular challenges to the securities lending/borrowing business. The potential for timing mismatches between settlement of client sales when stock is on loan and loan recalls from borrowers becomes more acute in a reduced settlement cycle environment.

Providers may need to look at earlier notifications of sales by fund managers and shorter recall timeframes between lenders and borrowers to minimise the impact on settlement rates, says Dane Fannin, global head of securities finance for Northern Trust.

“The T+1 effort will require changes from borrowers, lenders, technology vendors, investment manager and clients to develop more straight-through processing as well as changes to practices such as sales notifications and confirmations/affirmations,” he says.

Fannin observes that improved systems functionality (internally and externally) and stronger STP between fund managers, lenders and borrowers would be beneficial. Involvement of service providers is also important as the lender-borrower community will require extensive and effective utilisation of tools for handling recalls.

“We see demand for T+0 coming primarily from the front office as a risk management measure from a liquidity and exposure risk perspective,” he adds. “For the back and middle office, changing to T+0 would be a much heavier lift, requiring some key rule changes and revamping of the current settlement model, whereas T+1 can be accommodated by practice changes and some automation of current models.”

System requirements

“I would say the securities lending/borrowing community will not be in a position to support T+0 until there is a significant uptick in system capabilities and an ability by market participants to deal with near-real time data in an effective manner.”

Outright US Treasury transactions have been settling T+1 and overnight term repos settle same day on the open leg (T+0), explains Colleen Stapleton, product manager match products - cash and repo at MarketAxess. It is a settlement cycle we have seen in some parts of the market but as all fixed income products move towards T+1, any participants who have not funded their technology will be in a tough spot, which is why it is important to start building now, she says.

“The 2024 deadline seems like a long time away, but it will really be here in no time. Now is the time for analysis, planning and budget allocation to close out the remainder of the year, while 2023 should be allocated to development followed by wrapping up testing and eventual go-live in 2024,” adds Stapleton. “Firms that haven’t begun their automation and STP journeys are at a disadvantage to firms who already have connectivity and standard processes established with STP tools reducing and removing manual work while shortening the time to affirmation and confirmation and settlement readiness.”

Economic considerations

On the question of whether current market conditions are conducive to the move to shorter settlement, she suggests the economic outlook - of a short to medium term bear market - could prevent funding going into technology as market participants attempt to secure their bottom line, which would negatively impact any move towards shorter settlement.

“However, as the Fed aggressively raises interest rates to combat inflation, fixed income products could look more attractive than they did before (due to higher yields) and could affect the volumes traded from a repo and US Treasury perspective,” says Stapleton. “It is therefore important for market participants to be prepared technologically to efficiently confirm, match, and settle these transactions if trading volumes were to rise.”

She reckons there will be limited appetite for T+0 until T+1 is working efficiently and that although this topic has been covered in various meetings, current discussions just raise awareness.

“Funding and revamping legacy platforms to meet the challenge is what will determine the market’s ability to move towards a T+0 cycle,” concludes Stapleton. “If the changes required are made over the next year and we are no longer talking about fax confirmations and end of day batches in 2024, then T+0 won’t nearly be as intimidating as it seems today.”

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