Compliance Briefing — May 28, 2024

Executive briefing: On 28 May 2024 the settlement cycle for most U.S. broker-dealer transactions shortens to T+1 under SEC Release No. 34-96930. Market participants must complete allocations, confirmations, and affirmations by the end of trade date and update operations to support faster funding, securities lending, and collateral flows.

Key compliance checkpoints

• Same-day affirmation. Investment advisers and broker-dealers must complete allocations, confirmations, and affirmations as soon as technologically practicable and no later than T (end of trade date).
• Written policies. Investment advisers must adopt procedures ensuring timely completion of post-trade processes; broker-dealers must document arrangements with counterparties.
• Recordkeeping. Maintain records demonstrating compliance with Rule 15c6-2 requirements and exception handling.

Operational priorities

• Technology upgrades. Automate trade matching, allocation, and affirmation workflows, integrating with DTCC ITP platforms and custodian interfaces.
• Funding and liquidity. Adjust treasury processes, securities lending, and collateral management to reflect shortened settlement windows.
• Cross-border coordination. Align foreign exchange and securities settlement in markets still operating on T+2 to mitigate fails.

Enablement moves

• Conduct readiness testing with custodians, asset managers, and broker-dealers to validate same-day affirmation.
• Update client communications and standing settlement instructions to reflect new timelines.
• Implement exception dashboards tracking unmatched trades, late affirmations, and settlement fails.

Sources

• SEC Release No. 34-96930 — Shortening the Securities Transaction Settlement Cycle
• 88 FR 13872 — Final rule publication

Zeph Tech guides trading, operations, and treasury teams through T+1 readiness, spanning workflow automation, policy updates, and exception management.

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