T+1 Starts in May. Are You Ready?

News February 05, 2024 at 03:44 PM
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On May 28, the new standard for trade settlement will become the next business day after a trade, or T+1.

As it stands now, the settlement date occurs two business days after the trade date (T+2), but recent rule amendments from the Securities and Exchange Commission and conforming FINRA rule changes will soon make that cycle one day shorter, FINRA notes in just-released guidance.

The rule amendments, approved by the SEC last Feb. 15, shortened the standard settlement cycle for most broker-dealer transactions.

The May compliance date for the rule is earlier than the Investment Adviser Association in Washington thought it should be, Karen Barr, IAA's president and CEO, told ThinkAdvisor in a recent interview. The rule "is a big deal," she said.

As FINRA explains, the trade date is the day an order to buy or sell a security is executed; the settlement date is the day the order is finalized and on which funds and the securities must be delivered.

This isn't the first time a settlement change has occurred.

"In 2017, the SEC shortened the settlement cycle from T+3 to T+2," FINRA explains. "The move to T+1 reflects improvements in technology that allow trades to settle more quickly. With most trading and banking activity occurring online, extra days to physically deliver securities or funds are no longer needed."

The T+1 rule amendment applies to the same securities transactions currently covered by the T+2 settlement cycle, FINRA states.

These include transactions for stocks, bonds, municipal securities, exchange-traded funds, certain mutual funds and limited partnerships that trade on an exchange.

"The switch to T+1 also means that these transactions will align with the settlement times for options and government securities, which currently operate on a next-day settlement schedule," according to FINRA.

The Change to T+1

Under the new T+1 settlement cycle, most securities transactions will settle on the business day following their transaction date.

"You might not notice a change, as many brokerage firms currently require investors to have the needed funds in cash accounts before making a purchase," FINRA states.

"But if you normally initiate an Automated Clearing House (ACH) payment for your purchases the day after your trade is executed (e.g., you wait for trade confirmation before sending money from a linked bank account), you'll likely need to make payments a day earlier under the T+1 cycle to ensure the payment has posted by settlement date," according to FINRA.

"Simply initiating an ACH transaction doesn't meet payment requirements; the funds must be deposited in your brokerage firm's bank account."

The SEC "cautions that if you hold a physical, paper securities certificate, you might need to deliver it to your broker-dealer earlier to meet the new shorter settlement cycle," FINRA's guidance warns. "However, it's increasingly rare for investors to hold paper securities certificates."

If a client holds their securities in an electronic format with their broker-dealer, the broker-dealer "will deliver the securities on your behalf one day earlier under the new rule," according to FINRA.

Further, FINRA explains that even though margin requirements in margin accounts are computed on a trade-date basis and aren't changing, "the payment period for Regulation T (initial) margin calls also has been reduced by one day to T+3."

"This means that the change in settlement date doesn't change the time periods related to meeting maintenance margin calls, as these are set based on the date the call occurred," FINRA said.

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