作为美国的T+1结算.S. 距离2024年5月的实施只有一步之遥, it is essential that firms ensure a vigorous and synchronized testing program is in place to verify that they can operate successfully within the new compressed settlement timeframe.
Based on early indications we are seeing within 存’s testing program, which was 于2023年8月14日发射, firms are increasingly leveraging the industry’s environment to administer end-to-end 帖子-trade testing and to assess readiness.
随时了解有关美国经济的vns6060威尼斯城官网和见解.S. T + 1项目
While it is encouraging to see that firms around the world are ramping up efforts to ensure that their systems and 帖子-trade processes are fit for purpose for the May implementation date, organizations must also consider the complexities around cross-border trades, including the impact of time zone differences on foreign exchange (FX).
There have been extensive firm-level discussions across the industry contemplating the various courses of action to manage the time zone issue, given that the time to settle trades will be cut to one business day or less. 同样的道理, 公司也在密切关注外汇风险, 因为为美国贸易提供资金需要在T+1时间表内完成.
便利外汇结算
The move to T+1 settlement for equity trades means that FX processing must be executed on trade date (T+0) or in the early morning of settlement date (T+1). 跨境贸易, this could be challenging because foreign investors are only able to determine the actual amount of U.S. 在交易确认后购买的美元. 同时, 外汇方面的挑战也带来了结算风险, as foreign investors selling their local currency may not receive the U.S. 美元等值以按时完成交易.
在今天的T+2环境中, cross-currency settlement is addressed when FX trades are processed within the Continuous Linked 结算 (CLS) system, 降低结算风险，提高业务效率. If FX trades cannot be processed and settled in the CLS system to meet the demands of T+1 settlement for equity trades, 外国投资者可以选择利用双边结算, 对于符合cls条件的货币，哪一种可能更昂贵, 比如美国.S. 美元.
This funding option could expose foreign investors to counterparty and settlement risks, as well as negate the benefits of CLS’ multilateral netting mechanism.
“The takeaway from industry discussions is that foreign investors should collaborate with their custodians and FX providers to develop a multipurpose solution.”
行业预融资
交易的融资通常发生在交易匹配之后, 分配, 确认, 确认过程就完成了, 因为在这一点上交易的确切金额是已知的. 使用压缩的T+1结算窗口, there is concern that foreign investors could be forced to pre-fund their trades, potentially creating additional costs or requiring changes to their funding strategies.
Since some emerging markets in Asia may not permit the free flow of their currencies, FX trading for non-CLS eligible currencies can only be traded onshore. This may mean that the time needed to process both FX and equity trades could take more than one day. Foreign investors may consider pre-funding to settle trades in local currencies given settlement time constraints. 这不是一个最佳选择, 除了额外的交易成本, 此外，还存在分配充足现金储备的压力.
实施变更管理
应对外汇挑战, foreign investors should take a holistic and well-coordinated approach to harmonize the execution of both FX and equity trades to ensure timely settlement. A comprehensive review of existing processes can help to inform decisions. 例如, FX fulfillment should be given top priority during local operating hours in Asia to ensure timely FX settlement.
另外, Asian firms with a global footprint could consider implementing around-the-clock support across continents or extend coverage during U.S. operating hours to facilitate processing and on-time settlement of FX and equity trades. One ideal solution would be for firms to integrate automated processing of FX and equities trades on one platform to address cut-off time concerns. 另外, leveraging up-to-date electronic standing settlement instructions (SSIs) from an online global, golden-sourced database can support timely transaction settlement and minimize trade exceptions or fails due to incorrect data.
当印度从2022年2月开始分几个阶段进入T+1时, industry participants explored solutions to address the shortened processing window and mandatory pre-funding concerns. While India did not turn into a mandatory pre-funding market 帖子 T+1 implementation, what we learned from India’s financial markets is that it is up to foreign investors to work with their intermediaries, 包括全球和本地托管人及银行, to agree on the most suitable approach to meet their FX requirements.
考虑到每个当地市场的特点, an industry-wide solution to manage FX trades may not be feasible at this point. The takeaway from industry discussions is that foreign investors should collaborate with their custodians and FX providers to develop a multipurpose solution. 降低风险, 这些vns6060威尼斯城官网应具备基本的货币管理标准, 包括主要交易地点的运营设施, 全天24小时获取批发外汇定价, 流动性管理能力. 同时, firms should assess whether increased levels of automation can help accelerate the FX lifecycle. Doing so will help firms best prepare for the May 2024 implementation date.
本文最初发表于 WatersTechnology 2023年12月14日.