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
Following equity market volatilities in early 2021, the US Securities and Exchange Commission (SEC) proposed changes, including a transition to a shorter trade settlement cycle.
When trades are made, the buyer and seller must exchange money and process the stock during what is known as the “settlement window,” before ownership is officially transferred. Currently, if a stock is bought on Wednesday (day “T”), the buyer pays for the shares and the seller delivers them by Friday (day T plus two days, or T+2).
The future process would see the trade settle one day earlier, on Thursday (T+1).
The SEC announced on February 15, 2023, that the U.S. transition to T+1 would take place on May 28, 2024, before which the industry and all market participants have to make and test the necessary operational changes and technological upgrades required to settle trades in one day.
Key U.S. changes include:
- Same day allocations by 7:00 p.m. ET and affirmations by 9:00 p.m. ET
- Written agreements or policies and procedures requiring allocations and affirmations as soon as “technologically practicable and no later than by the end of the trade date.”
- Requires investment advisors (buy-side) to maintain records of confirmations received and allocations and affirmations sent.
The U.S., Canadian and Mexican securities markets will be impacted by these changes. This means anyone who operates in these markets may be affected, regardless of where they are based around the world. Other jurisdictions are expected to announce moves to T+1 in the coming months. The U.K. and EU established taskforces to review potential moves to T+1 settlement. Brazil and other LATAM markets have not yet indicated whether they will transition to a T+1 settlement standard.
After the transition, the shorter timeframes for funding and processing in U.S. markets will have an outsized impact on market participants based in time zones ahead of the U.S. Additional challenges may stem from FX markets, as they will stay at T+2 settlements, which will introduce complexities for funding trades. Industry practices in other areas including securities lending recalls may require further exposition.
Industry Engagement: BNY Mellon contributed to several industry comment letters to the SEC, including those by SIFMA, the ICI and the AGC.
Technology Investment: Though BNY Mellon’s platforms support substantial T+1 and T+0 settlement today, an impact assessment of the proposed U.S. Depository Trust and Clearing Corp (DTCC) changes has been completed, and development to meet the new process timings is required. Enhanced data exchange and transmission will be critical, so planned platform enhancements will have T+1 support integrated into the design.
One-Firm Approach: We have a firmwide Steering Committee for T+1 ensuring cross-firm impacts and dependencies are identified and best practice is shared.
BNY Mellon Thought Leadership: BNY Mellon participates in the various industry working groups established by SIFMA, DTC, AGC and ICI. We are participating in industry events and panels to discuss the impact of T+1 and readiness of the market. We are engaging with key clients in focused sessions relating to T+1 impact and to better understand their readiness.
Settlement Date cutoff times are reducing by one day. The current market cutoff for valued deliver orders is 3:00 p.m. (ET) and will remain so after the move from T+2 to T+1.
U.S. settlement cycle T+1 Transition Weekend Timeline
Friday |
Saturday |
Sunday |
Monday |
Tuesday |
Wednesday |
May 24, 2024 |
May 25, 2024 |
May 26, 2024 |
May 27, 2024 |
May 28, 2024 |
May 29, 2024 |
Last T+2 |
Conversion Weekend |
Conversion Weekend |
Conversion Weekend |
First T+1 |
Double Settlement Date |
There is no indication the FX cutoff times will change for the global markets. Please refer to the Markets FAQ section below for further information.
If loaned securities are recalled, these will need to be identified in a shortened timeframe. Despite a suggested best practice of 11:59 p.m. (ET), the industry recall deadline remains 3:00 p.m. (ET) on trade date. Further details are available from the Risk Management Association (RMA).
BNY Mellon’s initial approach to address sales of securities on loan is to seek to reallocate your loan. Today, more than 90% of our clients’ sales of on loan positions are reallocated to other clients. This is only possible due to the size and scope of our lending portfolio ($4.5T).
If reallocation is not possible, BNY Mellon issues a recall notice to the borrower for the return of the loaned security.
DTCC opened their window for testing on August 14, 2023, and will continue leading up to the May 28, 2024 compliance deadline. BNY Mellon works closely with DTCC and will continue to do so on industry testing.
BNY Mellon will not require client testing. Certain fixed-income, lending and collateral trades in the U.S. market already settle T-0 or T+1. Testing is not required where the infrastructure is already in place. Clients who have specific test requirements can reach out to their Client Service Representative for review by the project team.
Please refer to the DTCC's T+1 Product List for the full list of impacted products.
We recommend clients consider taking the following actions to prepare:
- Review internal operating models to determine if additional coverage is needed, or if movement of functions across geographies will be required.
- Leverage e-delivery for the delivery and receipt of trade documentation.
- Additional information will be made available from BNY Mellon businesses to clients as required.
Ex-Date will align with the Record Date for regular-way corporate actions. Additionally, market participants should adopt SWIFT messaging across the corporate actions lifecycle to increase efficient communication by industry participants related to corporate action events.
Please reference our BNY Mellon T+1 Transition and readiness page or contact your BNY Mellon representative.
QUESTIONS 16 TO 20 FOR CUSTODY CLIENTS ONLY
There is no penalty regime for failed settlements in U.S. DTC and Canadian markets.
We do offer affirmation services to our clients to affirm on their behalf and support both Deliver Order and Night Deliver Order transactions but prefer to get trade allocations earlier so we can include the transaction as part of the Night Deliver Order.
Yes, BNY Mellon supports multiple affirmation models on behalf of clients and can also support the use of third party affirmation providers and submit trades for ID settlement.
The Institution ID/TSID 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, agent, or interested party) on the trade should have their own TradeSuite ID Number. The Custodian is identified under the Agent ID which is provided separately.
Clients who will use record-keeping services through DTCC need to use a TSID registered in their own name.
Many brokers will require clients to have their own institutional ID for execution due to the rule change requirements for T+1. To make use of available DTCC reporting of affirmation rates and other metrics, separate institutional ID’s will be needed. Additionally, if the broker-dealer is relying on 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 institution.
For clients interested in DTCC’s Match to Instruct (M2i) service, it is a requirement to have your own institutional ID.
Clients should complete the TradeSuite ID application available via DocuSign.
How does a client obtain an ‘ID Only’ TradeSuite ID?
Please complete the ‘ID Only’ application available via DocuSign.
You should expect to receive your “ID Only” within one week of submitting your application. Requests for TradeSuite ID Limited and Web require a minimum of a week to process once all paperwork has been submitted and will be put in queue based on submission date.
Any questions about applications should be directed to the DTCC Client Contact Center at 1-877-664-3625.
To meet the T+1 deadline all TradeSuite ID requests should be submitted by February 28, 2024.
Canada
Given the existing relationship between the DTCC, 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. The link below will take you to the latest update. 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 |
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, which will not allow enough time to validate changes. The May 27, 2024 compliance date allows for system implementation to be completed over the weekend (along with the U.S.) and time to validate the success.
BNY Mellon and CIBC Mellon (our Canadian joint venture and sub-custodian) are activity 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 the Canada 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). This 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 Instrument.
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. 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 Central Counterparty for Equities (Contraparte Central de Valores “CCV”) and the Mexican Association of Brokerage firms (AMIB) announced that a formal request to the Mexican financial authorities will be sent to adopt a settlement cycle change from T+2 to T+1 to remain in alignment with the U.S. and Canada. 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 in 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 as their time to process trade instructions, execute FX, and meet funding obligations will be shortened as well.
• The move to T+1 may apply pressure on clients in APAC and 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. Any trades done with the Markets teams are also able to settle automatically into your BNY Mellon Custody account.
• By participating in our STP 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.
• 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 US equity market closes at 4:00 p.m. ET, many managers will be executing Market-On-Close (MOC) orders and so 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.
• BNYM 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 effective May 28, 2024, for US 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.
Shorten Settlement Cycle
A shortened settlement cycle of T+0 is available for US 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 T 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 US listed ETFs.
In-kind Creation with Market Restrictions
For the T+1 ETF order settlement cycle in markets with restrictions (list in appendix), cash in lieu must be delivered by the authorized participant (AP) to the fund on settlement date i.e., T+1, as surplus funding until 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.
CNS Orders
Once the order is placed via the early order window, BNY Mellon will instruct NSCC based on an estimated order value using the prior day’s 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 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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