与美国.S. Securities and Exchange Commission (SEC) decision confirming a May 28, 2024, compliance date for the move to T+1, the one-year countdown is now on for firms to ensure readiness.
对冲基金, the first step in their T+1 preparations should be to engage with their sell-side counterparties – both prime brokers and executing brokers. This is because registered brokers will be required to comply with the T+1 mandate and meet Same Day Affirmation (SDA) objectives which means they may need to modify their expectations around counterparty conduct and their operational processes, resulting in an update to broker policies. This could impact their hedge fund clients, requiring them to implement greater automation in the allocation and confirmation process to enable brokers to meet their T+1 requirements.
今天, buy-side market participants allocate block trades to underlying accounts and send those details to their executing broker and prime broker. On completion of the allocation process, each trade is confirmed by providing a detailed record of a transaction, 包括交易的内容, 交易日期, 成本, and the net value which is then affirmed by the investment manager, designated custodian or prime broker. 为T+1做准备, sell-side firms will need to successfully complete these activities on trade date, so that matched and agreed transactions can be submitted into the settlement process prior to the accelerated settlement timeframes. 没有自动化这个过程, T+1 is less likely to be achieved and the possibility of trade fails will increase.
As hedge fund firms consider their readiness, they should pay particular attention to middle- and back-office processes supporting the 帖子-trade lifecycle, 即分配, 确认, 和肯定. Automation for these areas of the 帖子-trade lifecycle have traditionally had less technology investment compared to the front office, where processing speeds can be in milliseconds. To achieve the 帖子-trade efficiency which executing and prime brokers may require of hedge fund clients in order for them to comply with T+1, automation across middle - and back-office operations is critical. 对大多数公司来说, switching from manual to automated processes for matching and confirmation is the most effective way to achieve this. The good news is that automated central matching solutions that can enrich trade details with standing settlement instructions and enable same day affirmation are available. It is recommended that market participants look into investing in and leveraging such a solution.
而对于大多数对冲基金来说, preparation for T+1 will be compliance with the potentially updated policies and processes of their executing and prime brokers, hedge funds that are SEC Registered Investment Advisers (RIA), T+1 brings with it a record-keeping obligation. This requires an RIA to record the time and date stamp of transactions and to achieve confirmation/affirmation in line with T+1 expectations. 对于这些实体, T+1 is a compliance issue and hence for them, 帖子-trade automation is even more imperative if they are going to meet the new requirements.
5月28日, 2024, T+1 implementation date now set, market participants must begin to prepare immediately. Hedge funds will benefit from understanding what they can do to prepare. 对于大多数, the first step will be checking in with their brokers on their 帖子-trade capabilities and requirements and considering adding automated 帖子-trade solutions that enable them to control their firm’s achievement of efficient 帖子-trade pre- settlement processes. For RIAs, they need to ensure they can comply with the mandated T+1 requirements. 这两种情况, 帖子-trade automation will be the most effective route to fulfilling their obligations. 现在是实现自动化的时候了.
本文原 发表于AlphaWeek 2023年8月15日.