短短5分钟, 我们将通过新思路探索贸易后vnsr威尼斯城官网登入的世界, 洞察力片段, 新兴的趋势, 以及发人深省的问题. 在这一集里, 肖恩·麦肯蒂, 存执行董事, 机构贸易加工vnsr威尼斯城官网登入管理, talks about the impact that T+1 will have on the buy side and what they can do to prepare.
记录:
介绍
从美国存, 你现在听到的是第5段, the bite-sized post-trade financial services podcast that tackles an industry topic or trend in just 5 minutes. 请收听存高管分享他们对如何成长的看法, 繁荣, 保护全球金融市场. 五分钟有很多东西要发现，让我们开始计时吧.
肖恩·麦肯蒂
Hi, 我是肖恩·麦肯蒂, I lead the Matching and Agreements business for 存 Institutional Trade processing, 也被称为ITP. 你们可以想象, 考虑到我们在行业中的角色, I'm spending a lot of my time these days talking to our clients about the impacts of the shortened settlement cycle, 向T+1的转变，特别是ITP如何帮助实现这一目标. 作为这些对话的一部分, 我一直被问到T+3和T+2之间的关系, 这发生在2017年, 不同于T+2和T+1. 在我看来, 有两个非常明显的区别, 特别是当它涉及到买方时. My favorite T+1 quote that I've heard or read is that: "In the move to T+2 we lost a day in the settlement cycle, 但在从T+2到T+1的过程中，我们失去了结算周期中唯一的一天." So, 我们目前有一个完整的工作日来清理异常, 有效地减少到美国和美国之间的5个小时窗口.S. market close at 4:00 PM and the new 直接转矩 affirmation cut off which is 9:00 PM Eastern. That window for exception handling is drastically reduced and that's going to put significant pressure on both the buy side and the sell side to handle any exceptions that might occur in that shortened window.
The other very important difference that I want to talk about is the impact on the buy side. People that I've spoken to largely view that move from T+3 to T+2 as somewhat of a non-event with little impact on the buy side. We think that shortening to T+1 will have a significantly greater impact on the buy side for two reasons. In addition to the core piece of the regulation that reduces the settlement cycle to T+1, there are two additional components of this regulation that will impact the buy side either directly or indirectly. The first is this new—and I apologize for getting technical and lawyerly—but the new Exchange Act 15c6-2 which basically mandates same day affirmation. 虽然这在技术上是卖方监管, it states that brokers will need to have policies and procedures in place to ensure that their clients are affirming trades, 在技术上可行的情况下尽快，不迟于交易结束日期. The second regulation—again very relevant to the buy side and this is a direct impact to the buy side—is the Advisors Act 204-2 which outlines record keeping requirements for registered investment advisors or RIA's. 这一规定需要RIA, 他们是15c6-2项下合同的当事人, 对收到的确认书进行记录和保存, 拨款和确认已发送, 每个都有日期和时间戳. This is a new piece of regulation that we think will significantly impact buy side. I'll come back to the 204-2 requirement either in this podcast or if we don't have time maybe we'll come back to that specifically with a follow up one.
让我先谈谈15c6-2和肯定. It's a sell side regulation, but it will have significant impact on the buy side. Our largest sell side clients are already talking to ITP about leveraging our ITP数据分析 tools to monitor client’s affirmation rates and their compliance teams are in the midst of drafting policies and procedures for the requirement; or for the regulation that speaks to things like warning letters when clients drop below a certain affirmation percentage and even potential penalties. 所以这一切将如何发展还有待确定. I can tell you for certain that the broker compliance teams are taking this regulation very seriously and will need to look hard at who they're trading with and how those parties are complying.
这对买方有何影响? Well, today many buy side clients have outsourced that affirmation process to their custodians. ITP正在倡导这项新规定, the best practice for the buy side is really to take back that responsibility as the affirming party. 我们已经介绍了中医中的工作流程，称为匹配指令或简称M2i., that makes it really very easy for existing buy side clients and existing 中医 clients on the buy side to do just that. 那么M2i是做什么的? Match to Instruct streamlines what is currently a multi-step process of allocation matching in the middle office and then confirmation affirmation in the back office. We consolidate that down into a single process where the matching 中医 between the IM's allocation and the EB's confirmation is the affirmation of the trade. 当这种贸易得到肯定时, it flows directly down from 中医 to the 直接转矩 and is staged for authorization and settlement. 如果这一切都发生在晚上9点之前, 然后它会在几秒钟内再次从中医直接流向直接转矩. 这是一个非常高效的工作流程.
We have seen tremendous uptake again with T+1 as a tailwind of this workflow in the past year to the point where we're now approaching nearly 100 buy side clients live and those buy side clients are experiencing affirmation rates again prior to 9:00 PM, 新的切断, of 98.6%. Contrasting the affirmation rates in the 中医 Match to Instruct model versus the legacy confirm Affirm model, 我们看到了98.晚上9点前6%. We're still seeing affirmation rates in the mid 40's by 9:00 PM for that confirm affirm model. So, there's a huge gap that would need to be closed for clients that choose to continue to have the custodian affirm on their behalf. We really just think that Match to Instruct is a much more efficient model and really a light lift for the buy side and something you should really consider.
So hopefully I've shared some information today that's helpful to you as you prepare for this T+1 transition. 如果您想了解更多vns6060威尼斯城官网中医匹配指示工作流程的信息, please reach out to your relationship manager or salesperson or you can always find more on eagle1027.com.
谢谢.
结尾部分
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