Many markets are currently considering shortening the post-trade settlement cycle. On May 28, 2024, U.S. securities settlement cycles will move from current T+2 timing to future state T+1 timing. This means that trades currently settling two business days after trade execution will need to settle one business day after trading has been completed. Mexico, Canada, and Argentina will also move to T+1 on May 27, 2024.
The migration to T+1 settlement, especially for the U.S. market, will impact the entire ecosystem of parties involved in the trading of in-scope securities. To continue to support our clients and their readiness through this transition, BBH has compiled Key Steps for Readiness and Frequently Asked Questions to highlight considerations across multiple impacted products. All entities trading U.S. securities in scope of the new T+1 SEC rules will need to independently ensure their operational readiness across these product areas and their compliance with the rules in advance of the effective date of May 28, 2024. A summary of the SEC rules is also included for reference.
Key Steps for Readiness
- Work with DTCC to set up your own Tradesuite ID (“TSID”) (where needed) so it is ready to use before the May 28, 2024 conversion date.
- Update your standing settlement instructions (“SSIs”) in DTCC’s ALERT system (preferably using the Global Custodian Direct service for automated SSI communication), or with your brokers directly, to ensure data within (such as the Tradesuite IDs) are up to date.
- Instruct appropriate account set ups for affirmation processing and Tradesuite IDs with Global Custodians.
- Review where there may be any manual handling needed to support trade instruction and settlement (in particular any non-SWIFT or non-STP instructions).
- Consider adjusting batch cycle processes to move more towards real-time processing.
- Review and monitor trade transaction and settlement activity to identify behaviors and trends potentially impacted by shortened settlement cycles.
- Understand what may need to be tested before the conversion date.
- Work with your BBH contact on updated contact lists/trees in case of escalations or urgent support for trade processing around U.S. settlement deadlines.
- Monitor BBH’s T+1 site which has articles, recordings of webinars, blogs and more covering the shortened settlement cycle and the impacts.
Frequently Asked Questions
Impact on Trade Instructions and Settlements
Q: Which securities are in scope for the T+1 settlement cycle conversion?
A: In general, products that currently settle at the DTC on a T+2 settlement cycle are considered in scope. These products include equities, corporate bonds, unit investment trusts (UITs), and financial instruments comprised of these securities. Products that consist of these instrument types, inclusive of mutual funds, exchange traded funds (ETFs), American Depositary Receipts (ADRs), options, rights, and warrants, will be subject to the new T+1 requirements.
Q: How are DTCC instruction, affirmation and settlement deadlines changing to accommodate a T+1 settlement cycle?
| Process | Current T+2 Settlement Needs | Future T+1 Settlement Needs |
| DTC Institutional Trade Processing (ITP) Affirmation Cut-off | 11:30am EST on S/D -1 (T+1) | 9:00pm EST on S/D -1 (T) |
| DTC Night Cycle batched start time | 8:30pm EST of S/D -1 | 11:30pm ESTon S/D -1 (T) (Authorized transactions will be introduced as Delivery Orders on the night cycle) |
| DTC Close of Business settlement | 3:30pm EST of S/D -1 | 3:30pm EST on S/D |
| DTC Delivery Cut-off for Valued Transactions | 3pm EST on S/D | 3pm EST on S/D |
| DTC Delivery Cut-off for Free Deliverables | 6:15pm EST on S/D | 6:15pm EST on S/D |
Q: What is an affirmation and why are they critical to the T+1 change?
A: An affirmation is the process in which trade instructions and confirmations are verified by the two parties of the trade. Trades that have been affirmed through this process are more likely to settle on time without failing. With a shortened settlement cycle, the SEC has implemented certain rules to support best practices in a shorter time frame.
The SEC’s rule 15c6-2 promotes the completion of allocations, confirmations, and affirmations by the end of trade date for transactions between broker-dealers and their institutional customers. As a follow up, the SEC has also adopted a new rule requiring broker-dealers to either enter into written agreements as specified in the rule or establish and maintain written policies and procedures reasonably designed to ensure the completion of the allocation, confirmation, and affirmation of a transaction.
While regulatory requirements indicate needing to affirm trades on Trade Date, this can be interpreted as completing such affirmations by 11:59pm EST on T0. DTCC then have a set deadline of 9pm EST to receive affirmed trades, and trades affirmed after 9pm EST are considered as Night Delivery Orders (NDO) which are subject to higher processing costs. Trades affirmed on T+1 (or later) are considered Day Delivery Orders (DDOs) which are also subject to higher processing costs.
BBH’s instruction deadline is 7:30pm EST on T0, allowing the possibility to manage any instruction mis-matches, repair scenarios and escalations before the DTCC 9pm deadline.
Q. How can BBH support my chosen affirmation model?
A: BBH can support any client-chosen affirmation method (self-affirmation or custodial affirmation) through one of our four affirmation models, as described below. Once you have chosen your affirmation model, you can work with your BBH client service representative to ensure your BBH account is coded for the appropriate BBH model to support your affirmation processing.
BBH Confirm Matching
- BBH affirms trades on behalf of our clients.
- When we receive the trade instructions, BBH searches for the broker-dealer confirmation and matches these to allow affirmation to happen.
- BBH’s instruction deadline is 7:30pm EST on T0 to allow for time to meet the DTCC 9pm EST T0 affirmation deadline.
- The result of affirmation is considered as trade settlement instructions, which BBH takes to settle the trade with DTCC on T+1.
Self Affirmation With Trade Instruction
- Similar to Direct Affirmations, the client (or a third party) affirms the trades directly.
- BBH also asks for trade instructions to be provided before the affirmation happens, with the same instruction deadline as for BBH Confirm Matching.
- This allows for correct trade referencing and linkage to be maintained.
- The result of affirmation is considered as trade settlement instructions, which BBH takes to settle the trade with DTCC on T+1.
- BBH uses technology to check for duplicated trade instructions and suppresses any duplicate – usually the original trade instructions, to avoid double instructions going to the market for settlement.
Self Affirmation Without Trade Instruction
- The client (or a third party) affirms the trades directly.
- BBH as a custodian does not see the trade until it is affirmed.
- The result of affirmation is considered as trade settlement instructions, which BBH takes to settle the trade with DTCC on T+1.
Multi Affirmation Model
- BBH’s Multi Affirmations model is used when one BBH Custody Account is comprised of multiple underlying Investment Advisors, with some looking to leverage BBH to perform affirmations and others rather choosing to self affirm.
- Accounts coded for this affirmation model will be able to support BBH Confirm Matching and Self Affirmation with Trade Instruction (as listed above) in the same BBH Custody Account.
- Instructions must denote for each TSID if that ID will be used for Confirm Matching or Self Affirmation with Trade Instruction.
- The TSIDs listed as the Institution IDs on all clients’ SSIs must be linked to the corresponding BBH custody account.
- Trade instructions must be sent to accompany all confirms and affirmations received on this account to ensure timely and accurate affirmation processing or support.
Q: What are the most common causes of settlement exception?
A: Trade economics, insufficient positions, or incorrect standing settlement instructions (SSIs) can lead to a settlement exception.
Q: What is the settlement process for a returned security from a borrower?
A: Moving from T+2 to T+1 does not change the process of returning positions out on loan. It just shortens the time to have shares returned to cover a pending DVP.
Q: Is there any scenario where a trade can settle T+2?
A: Versus Payment settlement ends at 3:30pm (EST) at DTCC. A client would need to collaborate with their brokers on how long they will leave a trade open before “buying in” the client. Neither DTCC nor BBH would be involved in closing out a failing trade.
Q: Is there an impact to collateral trade activity?
A: There will be one day less to move collateral (deliver and receive) in support of collateral and trade obligations.
Q: Is there any penalty if the trade fails to settle on T+1?
A: DTCC does not anticipate imposing penalties on unmatched/failed trades after May 2024, but accelerating the settlement cycle to T+1 will require industry participants to migrate to more efficient ways of transaction processing, including further automation and the adoption of industry standard. This includes improvements that promote STP and reduce transaction fails.
Impact on Corporate Actions
Q: Will the corporate action ex-date/record date change following T+1 implementation?
A: Yes, following U.S. T+1 implementation, the ex-date and record date will be the same date.
Q: Are there changes to asset servicing with T+1 settlements?
A: Currently the ex-date calculation for regular way dividend processing is one business day prior to record date. In a T+1 environment, that will change same day to record date. The current cover and protect period of two business days after expiration for voluntary corporate actions will become one business day after expiration.
Q: Will it be possible to have issuers and agents coordinate to refrain from scheduling any corporate action events in the days leading up to and immediately following the transition to T+1?
A: During the industry move from T+3 to T+2 settlement, BBH monitored corporate action events around the conversion date and provided guidance where needed.
BBH will take a similar approach during the move to T+1 settlement and whether issuers and agents will be able to suppress corporate action events around the conversation date remains to be seen. In the T+1 environment, timely settlement of trades and reconciliation will be a key component for any security undergoing a corporate action.
Q: What will BBH do with the security that a client recalls from borrowers in order to proceed for voluntary action?
A: BBH would process the client election to the loan returned position as it would become part of BBH’s custody position. Loans need to be returned by BBH Deadline Date to ensure the election can be protected. Loan positions that have been elected on with non-default instructions are usually not allowed to be returned. For optional events, the non-default option is the option set to apply if no response is received by the holder.
Q: If a PM selects to participate in a voluntary corporate action for a security on loan, does the borrower need to return the security on a particular date? Does this follow normal settlement cycle of security trading?
A: BBH can support sending client elections to lending agents for on loan positions. If clients want the election processed in custody, then the loan would need to be returned to custody by BBH Deadline Date for the event in order to process the client election.
Q: If the corporate action (e.g., subscription of tender offer) involves settlement, does this settlement process need to follow the same settlement cycle of the security or a non-standard settlement cycle?
A: The payment of the corporate event would not follow the settlement cycle. For event eligibility, you would need the position settled by effective date of an event in order to participate, similar to today’s process. For some voluntary events in the U.S., pending positions can result in the concept of a protect, but that is determined on an event-by-event basis.
Q: Does BBH currently send out emails or make phone calls to clients if there is a short-notice corporate action (i.e., next day or same day)? If you do, would you continue to send notification (and timing) after the T+1 settlement date change?
A: Yes, for electable events. If an event is announced in the market with a short deadline (72 hours or less), BBH’s Corporate Actions team will endeavor to e-mail or call clients with all of the relevant details of the event, depending on the client’s location. If contact is not made to a client via phone, BBH will endeavor to send an e-mail. This practice will not change with the implementation of T+1.
Q: Does BBH currently add a “buffer” between the market corporate action deadline and the deadline you would expect your clients to respond by?
A: Yes, in the U.S., BBH’s deadlines are currently 18 hours prior to market expiration and will not be changing following T+1’s implementation.
Q: If an account has a dividend that is set-up to be reinvested, will they be reinvested same day (as the dividend payment date) or day after settlement?
A: In the U.S., BBH does not support DRIPs, but we do support Opt-Out events which result in reinvestment as a default. The reinvestment shares typically pay out two to three days after the cash pay date.
Q: Does BBH send corporate action notifications via SWIFT on a batch cycle or real time? How often are these sent during the day?
A: Notifications are released both in batch and real-time based on the below criteria. Pre-eligibility date notifications (optional service) related to the release of new events are sent on a real time basis. Pre-eligibility date notifications related to the updates of previously released events are sent in daily batches at the end of the day.
- Eligibility date notifications are sent in daily batches at close of business on either eligibility date, eligibility date minus one, offer period begin date minus one or create date depending on the action type. Any batch notifications are released in accordance with the following timeline: Batch notifications are sent at close of business based on market time-zone: Asia at 10:00 EST; Europe at 16:00 EST; and Americas at 19:30 EST.
- Update actions are sent real-time post eligibility date. Updated actions are mandatory for BBH clients for voluntary and mandatory with election event types. Position change post ex-date notifications (optional service) are sent real-time post eligibility date.
Q: Are there any changes that BBH foresees concerning T+1 settlements pertaining to corporate actions?
A: No, we do not expect any systemic or workflow impacts to corporate actions based on T+1. We expect ex and record dates for events to be adjusted by the market once T+1 is implemented, but this information would be announced at the market level and we would announce accordingly.
Impact on Cash Management Services (CMS) and Funding
Q: Will the CMS program support an increase in cash balances that may occur due to the transition to T+1?
A: Yes, CMS remains an outlet for clients’ end-of-day cash balances – which may include cash remaining on account due to trade fails or pre-funding of trade settlements.
Q: Will there be an increased demand for overdrafts/ credit from clients?
A: An increase in trade fails and/or the misalignment of trade settlements and TA flows may result in an increase of credit requests. Although we may see a short-term increase in the request for credit while clients adjust to the shorter settlement period, we expect clients will adjust their operations, where necessary, to fund their settlement activity on a timely basis.
BBH recognizes that clients sometimes require overdrafts and BBH aims to provide these when appropriate. BBH’s Institutional Risk and Credit Committee oversees the extension of credit to our custody clients. In determining whether to permit an overdraft, credit approvers consider a number of factors, including the size of the overdraft relative to the portfolio, the nature of assets in the portfolio, account documentation including lien terms, documented borrowing limits, historical account activity, market conditions, etc.
Impact on Exchange Traded Funds (ETFs)
Q: Will the implementation of T+1 settlement for U.S. securities impact the creation/redemption process for U.S. domiciled ETFs?
A: Yes, the move to T+1 settlement in the U.S. will impact ETF create and redeem settlement cycles in the U.S. Currently, standard ETF creates and redeems generally have a T+2 settlement timeframe. Following the implementation of T+1 settlement in the market, U.S. ETF creation/redemption settlements will generally move to settle T+1, or potentially T0, to align with the settlement of the underlying basket of securities. U.S. ETFs investing in a global portfolio of securities may see other impacts, depending upon the local markets in scope.
Q: Will the implementation of T+1 settlement for U.S. securities impact non-U.S. domiciled ETFs?
A: In Europe, ETF issuers will need to assess the impact on their portfolios of a move to T+1 settlement for U.S. securities. If the fund is made up of 100% U.S. holdings, then it is likely that they will need to move the settlement of the fund’s creations to T+1 settlement to ensure they can comply with UCITS requirements as they relate to borrowing. Redemptions on such funds are also likely to move to T+1 settlement. Where it is a global portfolio of which U.S. are a component, a closer analysis will likely be required to assess the appropriate approach based on the materiality of the U.S. components.
Q: How will the move to T+1 settlement be reflected on the BBH ETF Order Taking Platform?
A: BBH’s AP Servicing team will work with clients to ensure that issuers instruct the update of standard settlement on creations and redemptions to T+1 for impacted ETFs.
Q: Will the move to T+1 settlement impact NSCC files BBH currently receives from third party distributors appointed by its ETF Clients?
A: Yes, where our U.S. ETF clients engage third party distributors/order takers on their ETF products, BBH will need to work with those third parties to ensure that changes to the NSCC create/redeem files are incorporated into their file deliveries to BBH post T+1 live.
Impact on Securities Lending
Q: Does the change to a T+1 settlement cycle disrupt contractual and marketplace alignment?
A: Market opening and close times, reinvestment vehicle cutoffs, and other market deadlines will continue to adhere to their established schedules. While market participants are expected to process loan recalls up to 11:59pm, the effective date of a recall is expected to generally remain 3pm. Legal agreements will supersede any best practice in the marketplace.
Q: How does a shorter settlement cycle impact the recall process?
A: While transitioning to a shorter settlement cycle, it is important to note that the fundamental recall process remains unchanged. Nevertheless, borrowers are urged to enhance their efficiency in sourcing recalled securities due to the expedited settlement cycle. The shift to a T+1 settlement cycle is anticipated to bolster market liquidity. Beneficial owners are advised to promptly transmit sale notifications to their agent lenders before market cutoff on trade date, ensuring alignment of recall due dates and contractual settlement dates for lending transactions.
Q: Does a T+1 environment require full automation for our program?
A: Our lending platform has the capability to automatically issue recall notices. The seamless execution of automated recall issuance relies on the prompt receipt of sale notifications from our clients.
We are making an effort to enhance our operational efficiency by integrating tools for managing negative availability and automating processes in collaboration with external vendors. These strategic enhancements are anticipated to reduce the time frame between receiving a sale notification and initiating a recall. The enhancements are expected to provide further automation in these areas.
Q: Does the move to a shorter settlement cycle increase the risk of sale fails, CSDR penalties, interest penalties on OD and buy-ins?
A: The transition to a T+1 environment does not introduce new penalties. While acknowledging that market risks cannot be entirely mitigated, our refinements to the recall system empower staff to significantly reduce the turnaround time for issuing recalls after a sale file is received. Client sale timing, along with prompt confirmation and delivery of recalled securities by borrowers, is necessary for timely communication and an efficient recall process is essential in reducing sale fail and potential buy-in associated risks. The Rule 204 close-out requirements (buy-ins) are not changing and will apply on failure to deliver SD+3, or T+4.
Impact on Foreign Exchange
Q. Will BBH be able to accommodate same day FX execution and settlement?
A: Yes, BBH will continue to be able to support same day FX’s for both BBH custody and non-custody accounts. Please work with your FX relationship manager to confirm market specific cut-offs.
Q. Are changes to CLS deadlines expected for T+1 conversion?
A: CLS is not changing their deadline. The CLS deadline is 6pm VD-1 EST and clients are recommended to submit MT304 until 5:30pm VD-1 EST.
Impact on Transfer Agency
Q: Will all funds with U.S./Canadian/Mexican asset exposure be required to move to a T+1 settlement?
A: There is no obligation to change the settlement of the fund to match the market, however fund management should consider the impacts to both the investor and the fund of keeping the existing settlement cycle. The fund portfolio composition is important and the fund manager should consider how exposed the portfolio is to U.S. securities. The fund manager should also consider how shortening the settlement cycle will affect investors in different time zones which require sufficient time to organize payment after receipt of the contract note.
Q: Are Redemptions, Transfers, Switches and Distributions affected?
A: The decision to keep or shorten the settlement cycle must be considered with the investor type and location in mind. Should the settlement cycle remain unchanged, the fund manager should have plans in place to settle securities on the market on time while they wait for investor subscription monies to be received at the fund. Regarding redemptions, please consider how funds will be managed when trades are settled on the market sooner than they need to be paid to the investors. Transfers are unaffected. Normal switch rules apply – if there are different settlement cycles on the switch-out class and the switch-in class – the longest settlement period applies to both legs. We do not expect any change to the distribution policy of the fund.
Q: Can the fund move some classes to T+1 and keep other classes on their current settlement cycle?
A: Yes, BBH TA can support more than one settlement cycle for the fund and can also accommodate different settlements for different investor trade types.
SEC Rules Summary The SEC prepared a document outlining the rule changes to allow for T+1 settlement. The main rules are summarized as follows:
The benefits of T+1 include:
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