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

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