T+1 Accelerated Settlement FAQs
Following the SEC’s confirmation of the upcoming transition to T+1 in the U.S. market, the Frequently Asked Questions (FAQs) below have been prepared to provide you with an update on the latest regulatory and market developments.
For more specific information, choose from:
United States and General T+1 Info
We do offer affirmation services to our clients to affirm on their behalf. Under T+1, we will require trade instructions by 8:45 p.m. ET on trade date, so we can affirm on behalf of clients before the 9:00 p.m. ET DTCC cut-off.
We do support matched institutional trades (ID trades), Night Deliver Orders (NDO) and Day Deliver Orders (DDO), and we submit trades to the next available settlement window based on the timing of the instruction.
Yes, BNY Mellon supports multiple affirmation models on behalf of clients who do not want to self-affirm. We can also support the use of third-party affirmation providers and submit trades for ID settlement.
Yes, BNY Mellon is asking clients to get their own TradeSuite ID, specifically an Institution ID. Recent SEC guidance provides more information on regulatory expectations.
The Institution ID identifies all parties to a trade record (buy and sell-side) and should be the same as the parties executing the trade. Each party (institution, broker-dealer, agent or interested party) on the trade should have their own TradeSuite ID number. The custodian is identified under the Agent ID number which is provided separately.
Clients who will use recordkeeping services through DTCC need to use a TradeSuite ID registered in their own name.
Additionally, if a broker-dealer is relying on a TradeSuite ID to satisfy their confirmation disclosure obligations, then the broker-dealer may not rely on TradeSuite ID Numbers 87000 – 88999 to meet any obligations to the institutional client they are trading with.
For clients using DTCC’s Match to Instruct (M2i) service, it is a requirement to have their own Institution ID.
Complete the relevant TradeSuite ID application.
- For guidance and application forms, visit the DTCC Learning Center.
- For setup or admin advice with TradeSuite IDs, see their FAQs.
For application questions, contact DTCC directly. Clients interested in the “ID Only” subscription will not be able to self-affirm or view records, therefore, Registered Investment Advisers governed by the SEC recordkeeping rule are not eligible for this option.
How does a client obtain an “ID Only” TradeSuite ID?
Please complete the “ID Only” application form. Any questions about applications should be directed to the DTCC Client Contact Center.
BNY Mellon offers different affirmation and instruction support models. Clients should discuss with their BNY Mellon representative the appropriate setup for their account(s) to align with their desired approach.
No. BNY Mellon will not record confirmation or affirmation times, and our reporting on affirmation status does not meet the SEC recordkeeping requirement.
Clients should get their own TradeSuite ID, and use DTCC’s Trade Archive or Confirm Archive (or another vendor solution) for their recordkeeping. The SEC has confirmed that outsourcing does not change the “responsible party.” The broker-dealer, investment manager and central matching provider will all be responsible for keeping records of the affirmation process. The central matching provider must provide aggregate records to the SEC; the broker-dealer and investment manager must provide records on request.
At the end of March 2024, the SEC issued:
- FAQs from the Trading and Markets and Investment Management Divisions
- An investor bulletin regarding the T+1 transition
Details on how the Division of Examinations plans to assess the changes:
BNY Mellon strongly encourages affirmation, given that affirmed trades have a higher likelihood of timely settlement.
The SEC rule changes require that the allocation, confirmation and affirmation processes be completed “as soon as technologically practicable and no later than the end of the day on Trade Date.”
Affirmations also have a recordkeeping impact. The new rules place a requirement on U.S. investment advisers to record trade details. Clients trading with U.S. broker-dealers will be expected by their counterparties to affirm any confirmations issued, regardless of the client’s own requirements with the SEC.
For investment advisers, the SEC states that records must be kept of the allocation, confirmation and affirmation processes with timestamps. To complete this in an automated manner, clients will need an affirmation model in place, which can include self-affirmation.
Canada
Given the existing relationship between DTCC, the Canadian Depository for Securities (CDS), and the highly inter-related capital markets with a significant proportion of cross-listed securities, the settlement cycles need to remain in alignment.
The Canadian Capital Markets Association (CCMA) have iteratively released updates to their T+1 Asset List. As updates are made, the newest copy of the T+1 Asset List can be found on the CCMA website.
The Canadian T+1 compliance deadline is May 27, 2024.
Canada Settlement Cycle T+1 Transition Timeline
Friday |
Saturday |
Sunday |
Monday |
Tuesday |
Wednesday |
Thursday |
May 24, 2024 |
May 25, 2024 |
May 26, 2024 |
May 27, 2024 |
May 28, 2024 |
May 29, 2024 |
May 30, 2024 |
Last T+2 |
Conversion Weekend |
Conversion Weekend |
First T+1 |
Double Settlement Date for T+1 and T+2 trades |
Trade & Settle T+1 |
Trade & Settle T+1 |
May 27, 2024 is not a market holiday in Canada as it is in the U.S. If Canada were to transition to T+1 on May 28, 2024 – on the same day as the U.S. – Canadian market participants would need to implement system changes on May 27, 2024. This would not allow enough time to validate changes. By moving the deadline forward, implementation can be completed over the weekend (along with the U.S.) with time to validate.
BNY Mellon and CIBC Mellon (our Canadian joint venture and sub-custodian) are actively engaged in the CCMA T+1 steering committee and working groups. We are supporting industry feedback on the change such as the comment letters presented to Canadian regulators.
From a technology perspective, our systems are equipped for end-to-end securities lifecycle processing on T+1 and we are assessing our trade platforms for any enhancements to support automation efforts and awareness of client trading activity.
The market cut-off times will be reduced by one day. The Canadian market cut-off time is currently 4:00 p.m. ET and will remain so after the transition from T+2 to T+1.
NI 24-101 is a regulation that supports more timely and efficient processing and settlement of trades in Canada through Institutional Trade Matching (ITM). NI 24-101 mandates that 90% of trades should be pre-matched.
Pre-matching refers to the process of confirming trades between parties involved before settlement date.
The Canadian Securities Administrators (CSA) have recently published amendments to this regulation. They have:
- Shortened the settlement cycle from two days to one in alignment with T+1 in the U.S.
- Moved the pre-match deadline from 12:00 p.m. (noon) to 3:59 a.m. ET on T+1.
Having already been circulated for industry comment, these amendments are set to take effect on May 27, 2024 – the same day the settlement cycle changes.
Mexico
The Mexican market is moving from T+2 to T+1 to remain in alignment with the U.S. and Canada. The Mexican Central Counterparty for Equities (Contraparte Central de Valores (CCV)) and the Mexican Association of Brokerage firms (AMIB) announced that a formal request for this change has been made to the Mexican financial authorities.
In addition, Mexico is seeking to move to a T+1 settlement given the existing market activity tied to the International Quotations System (also known as SIC), a platform used for stocks and exchange-traded funds (ETFs) listed in other parts of the world. SIC today represents more than half of the total volume traded daily on the Mexico Stock Exchange (BMV).
Mexico has confirmed that they will align with the U.S. and Canadian markets and will go live on May 27, 2024.
The change will apply to the Mexican equities market and the securities listed in the International Quotation System (SIC). The current settlement cycle for fixed-income instruments is negotiated between the parties and can be T, T+1, T+2 or more.
BNY Mellon Markets
BNY Mellon established an enterprise-wide program with senior management oversight that focuses on understanding and addressing the impacts of T+1 settlement for clients and counterparties. BNY Mellon will be fully prepared for industry go-live.
While our FX product offerings support the move to T+1 already, we are looking at additional enhancements and extended instruction deadlines to further assist our clients.
The move to a shortened settlement cycle means that investors will need to take a fresh look at their operational processes. T+1 will also shorten their time to process trade instructions, execute FX, and meet funding obligations.
The move to T+1 may apply pressure on clients in the Asia-Pacific (APAC) and Europe, Africa and Middle East (EMEA) specifically, regarding operational constraints to ensure USD and CAD funding is in place to prevent failed trades.
For some, this may require same day FX with tighter deadlines, stricter oversight and more operational risk.
Yes, BNY Mellon can execute securities trades for both Fixed Income and Equities (FIEQ). Any trades done with the Markets teams are also able to settle automatically into your BNY Mellon custody account.
By participating in our straight-through processing model, clients are able to alleviate the burden of trade affirmation, as well as reduce settlement risk associated with changing settlement cycles. Additionally, our FX solutions help clients reduce the operational risk and burden associated with FX settlement.
BNY Mellon Markets has a full-service package inclusive of Custody FX, Equity and Fixed Income products offering operationally efficient, transparent and automated solutions to our clients.
For more details on BNY Mellon’s securities execution capabilities, please email the FIEQ Platform Sales team: FIEQPlatformSales@bnymellon.com
For more details on BNY Mellon’s foreign exchange capabilities, please email the FX Platform Sales team: FXPSGlobal@bnymellon.com
Yes, please refer to the Custody FX deadline document in NEXEN® for same-day execution deadlines.
FX cut-off times are available in the Custody FX deadline document in NEXEN.
We are extending Custody FX deadlines in a number of currencies and will publish the new deadlines when available.
In addition to our current same-day FX capabilities, BNY Mellon recently rolled out FX Now, which allows for near real-time execution, providing extended same day cut-offs and later execution.
As the U.S. equity market closes at 4:00 p.m. ET, many managers will be executing Market-On-Close (MOC) orders and therefore the funding requirement is not known until then. All our Custody FX programs support trading after this time, but FX Now specifically facilitates FX execution until 6:00 p.m. ET.
BNY Mellon will be extending our FX Benchmark program to start at 9:00 a.m. HKT.
Our Session Range same day FX capabilities have expanded and now include AUD, NZD, JPY, HKD, and SGD. Prior to May 2024, four additional currencies will be added to allow for same day settlement – NOK, SEK, DKK, CHF.
BNY Mellon Markets has also expanded securities execution capabilities and now offers trading via the NEXEN Markets Platform.
Yes, for more information please contact your respective regional desk.
For more details on BNY Mellon’s securities execution capabilities, please email the FIEQ Platform Sales team: FIEQPlatformSales@bnymellon.com
BNY Mellon ETF Services
Default Settlement Cycle Change
When exchange-traded funds (ETF) orders are placed through BNY Mellon, the default settlement cycle for creating or redeeming will be T+1. This will be effective May 28, 2024, for U.S. listed ETF shares, and May 27, 2024, for those listed in Canada. Standard or custom order placement windows can be established for this settlement cycle.
Shortened Settlement Cycle
A shortened settlement cycle of T+0 is available for U.S.-listed ETFs. The order placement window to create or redeem ETF shares for the shortened settlement cycle will be either:
- On Trade Date -1.
- Between 4:00–5:30 p.m. ET.
- Or on Trade Date between 8:00–9:30 p.m. ET.
Extended Settlement Cycle
Customized order placement windows can be established for settlement cycles up to T+5.
Standard In-kind Creation
For ETF orders using the T+1 settlement cycle, any pending in-kind trades with T+2 or T+3 settlement will require receipt of collateral prior to delivery of the ETF shares for U.S.-listed ETFs.
In-kind Creation with Market Restrictions
For the T+1 ETF order settlement cycle in markets with restrictions (list below), cash in lieu must be delivered by the Authorized Participant (AP) to the fund on settlement date (T+1). This will act as surplus funding until the settlement of market-executed trades.
Standard In-kind Redemption
For the T+1 ETF order settlement cycle in markets without restrictions, ETF shares or collateral must be received before in-kind trades are released for matching. This is the current standard industry process, and there will be no change related to the transition to T+1.
In-kind Redemption with Market Restrictions
For ETF baskets which hold a substantial weight in restricted market securities, the ETF shares settlement can be extended to either T+2 or T+3 to align with the underlying market settlement cycle, to avoid the fund being overdrawn.
Some APs have requested T+0 when transitioning to a T+1 settlement cycle, to accommodate stock loan desks as part of a create-to-lend transaction.
Continuous Net Settlement (CNS) Orders
Once the order is placed via the early order window, BNY Mellon will instruct the National Securities Clearing Corporation (NSCC) based on an estimated order value using the prior day’s Net Asset Value (NAV), as the actual NAV will not be known prior to settling the order. The estimate can include a buffer of up to 3% which can be customized as a standing instruction per fund. Once the actual NAV is established, BNY Mellon will instruct the NSCC with the actual NAV and a true-up value which will settle via security payment order on T+1.
Ex-CNS Orders
Once the order is placed via the early order window, BNY Mellon will request cash collateral for the total value of the order, plus a markup, by 12:00 p.m. ET. Upon receipt of collateral, ETF shares will be delivered for creations prior to 5:30 p.m. ET. Collateral will be returned once in-kind trades have settled, per standard industry protocol. For redemption orders, either receipt of collateral or early delivery of ETF shares will be required prior to releasing in-kind trades for matching.
AP Outreach
Issuers are encouraged to discuss optionality with the APs who are enabled to create and redeem on their funds. Some fund structures might warrant different settings for establishing order windows and settlement cycles.
Order Window Updates
BNY Mellon Service Directors will work with issuers upon request to review and confirm changes to update order windows for each fund. Established order windows can be addressed with accommodations based on settlement cycle, time of day, basket type, order type and assisted/directed trading. In addition, rules can be defined based on certain parameters for distributor and/or sponsor approval.
For further questions, or to discuss the impacts of T+1 transition, contact your BNY Mellon representative.
List of Restricted Markets
Countries listed below are not permitted delivery of in-kind trades.
Country Code |
Country |
Settlement Cycle |
IN |
India |
T+1 |
AR |
Argentina |
T+2 |
BH |
Bahrain |
T+2 |
BR |
Brazil |
T+2 |
CL |
Chile |
T+2 |
CO |
Colombia |
T+2 |
HR |
Croatia |
T+2 |
CY |
Cyprus |
T+2 |
EG |
Egypt |
T+2 |
JE |
Jersey |
T+2 |
KR |
Korea (South) |
T+2 |
LT |
Lithuania |
T+2 |
MY |
Malaysia |
T+2 |
PK |
Pakistan |
T+2 |
PE |
Peru |
T+2 |
RO |
Romania |
T+2 |
SA |
Saudi Arabia |
T+2 |
TW |
Taiwan |
T+2 |
AE |
United Arab Emirates |
T+2 |
VN |
Vietnam |
T+2 |
KY |
Cayman Islands |
T+3 |
CN |
China |
T+3 |
KE |
Kenya |
T+3 |
KW |
Kuwait |
T+3 |
MA |
Morocco |
T+3 |
NG |
Nigeria |
T+3 |
OM |
Oman |
T+3 |
QA |
Qatar |
T+3 |
LK |
Sri Lanka |
T+3 |
ZW |
Zimbabwe |
T+3 |
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