With just over six months to go before the implementation of the 结算 Discipline Regime (SDR) market participants need to have advanced their preparations for the regulation in time for implementation in February 2022. 在这里, 马特•约翰逊, ITPvnsr威尼斯城官网登入管理存总监, 介绍特别提款权准备的一些要点, including where market participants should be in their preparations and how automating 帖子 trade processes pre-settlement can assist with timely settlement.
The 结算 Discipline Regime is the component of the Central Securities Depository Regulation (CSDR) that aims to improve settlement efficiency in Europe with a view to reducing risk. 在特别提款权, market participants will be liable to pay penalties or charges against each transaction which fails to settle under the mandated T+2 timeframe. A penalty will be charged daily based on the asset class/security type and notional value of the transaction up until the buy-in process is initiated.
进一步, a mandatory buy-in process will take place for any financial instrument which has not been delivered within a specified period of the intended settlement date to fulfil settlement. Illiquid securities will be required to be bought-in within seven business days of the intended settlement date while liquid equities will be required to be delivered within four days.
The industry has made significant progress in their preparations in that most firms understand what SDR is and have a good understanding of how it will likely impact them. 但卖方和买方在准备方面存在很大差距.
市场参与者目前应处于SDR准备的哪个阶段?
到现在为止, 此时距离SDR的实施还有8个月, the majority of market participants should understand where there are automation gaps in their 帖子 trade processes. Firms should have analysed their current level of failed transactions and understand the volume of failed transactions, 他们会失败多久, 为什么.
交易失败的时间长短至关重要, 失败持续的时间越长, 买入的风险越高. This is a highly significant issue for small asset managers as many claim to have a much lower rate of fails than larger firms. 然而, a recent piece of analysis by a large custodian found that while smaller asset managers do have a lower rate of fails, the fails tend to drag on for longer than for bigger firms that have more resource to chase custodians or have budget/resource to rectify failed trades. 交易失败的时间越长，被处以高额罚款或买入的可能性就越大.
你认为大多数市场参与者都在这一点上吗?
The industry has made significant progress in their preparations in that most firms understand what SDR is and have a good understanding of how it will likely impact them. 但卖方和买方在准备方面存在很大差距.
一般来说，卖方准备得很充分. Many of them have spent a significant amount of time with trade associations to get a thorough understanding of what SDR will mean for from a resource and budget perspective. 他们也有非常成熟的特别提款权战略和专门的CSDR团队.
而买方公司也与行业vnsr威尼斯城官网登入密切合作, from a practical perspective they don’t have comparable resources to be able to spend on SDR preparations. Smaller buy-side firms need to stay engaged with their broker and custodian communities who can provide support and help them to navigate the regulation. 在存, we advise clients on how best to streamline their 帖子 trade processes which can assist in timely settlement.
Also critical to successful SDR preparation is that firms need inter-company engagement between front, 中、后台功能. They all need to be aware of their respective roles and how they will interact daily to ensure they operate seamlessly when SDR goes live.
防止失败和避免CSR惩罚的6大方法
The time is now to maximize your current investments in 机构贸易处理’s suite of services and to focus efforts on the prevention of failure.
How does the level of awareness and preparation for SDR vary between in-scope market participants in different regions?
鉴于这是一项欧洲法规，不出所料，该地区对此的认识是最高的. 然而, 这往往因市场参与者的规模而异——公司越大, 他们意识得越清楚，准备得就越充分.
在美国.S.， CSDR认知度高. 尽管这是一项欧洲法规, 它将对美国公司产生重大影响, 尤其是那些拥有欧洲投资策略的公司.
在亚太地区, 因此，我们没有看到人们对特别提款权的兴趣达到美国那样的程度, 那里的监管意识不高. 然而, in some Asia markets this is because there are already established strict settlement discipline regimes in place such as in Taiwan and South Korea.
What areas of 帖子 trade preparations for SDR are causing market participants the biggest problems?
在SDR的一些领域，市场仍在等待更详细的监管指引. 行业vnsr威尼斯城官网登入向监管机构提出了一份公开的问题清单，在某些情况下, 他们仍在等待反馈. If there is a significant disparity between a firm’s interpretation of regulation and what was intended by regulators, 公司可能需要对他们的方法做出重大改变.
购买过程也是一个引起关注的领域. 该规定要求买入必须通过买入代理发起. Firms need to have selected and onboarded a buy-in agent by the time the regulation is implemented. 如果不这样做，那么市场参与者可能会违反监管规定.
Also of concern is that there are a small number of firms where there is a persistent lack of 帖子 trade automation which will impact timely settlement. SDR将于2022年2月上线, 那些仍然使用手工交易后流程的公司将是受影响最大的.
What are the key 帖子 trade processes market participants should implement to avoid CSDR late settlement penalties?
为法规做准备, 在交易后, 预结算过程需要尽可能自动化. 这意味着使用警报, the industry’s largest database of standing settlement instructions (SSIs) so that clients have access to the most up to date information reducing the risk of settlement fails dues to inaccurate or incomplete instructions. 通过警报 Global Custodian Direct, 完全托管人或主要经纪人管理的工作流, clients can ensure that SSIs in the system come directly from and are maintained by source data providers.
利用存的中医平台, clients can enrich their trades with SSIs from 警报 automatically through the 警报 Key Auto Select (AKAS) functionality allowing them to agree on the economics and place of settlement on trade date, 实现及时准确的交易匹配. 如果有贸易例外, 存异常管理器可以实时识别这些异常, 使客户端能够快速解决问题, 因此，最大限度地减少延迟结算.
如果你能给准备上市的市场参与者一个建议，你会说什么?
预防胜于治疗. 一笔已结算的交易不会受到处罚，也不能被买入, 因此，通过自动化交易后预结算过程, 你会大大增加及时解决的机会.
本文首次发表于 网络传播论坛, 问题7.