在最近接受环球托管人的采访时, 存的马特·约翰逊报道, 副主任, ITPvnsr威尼斯城官网登入管理, looked at the key priorities and available solutions as buy-side firms prepare for the implementation of Central Securities Depositories Regulation’s (CSDR) 结算 Discipline Regime (SDR).
What’s most important for buy-side firms to know about CSDR?
CSDR’s provisions are very broad but a key aspect of this mandate is its settlement discipline regime. We expect the SDR to have a huge impact on every single 帖子-trade market participant – to the point that firms, 包括买方, will have to change the way they conduct business.
How can firms improve confirmation and settlement to reduce trade fails?
我们鼓励电子或自动确认. If you're trading with a broker that requires an email allocation or email confirmation, you may want to look at moving confirmation onto an automated platform.
We also advise automating the various steps in the settlement process. 现在欧洲实行的是T+2结算周期, you only have 48 hours after execution to capture the trade, 登记交易, 确认它, 确认它, 指导它, 基金, 赛前, 然后解决. At the same time, you need to make sure the reference data you're using - i.e.，结算说明-是正确的.
买方可以使用哪些工具?
存’s ITP no-touch workflow offers multiple tools to facilitate confirmation and settlement and minimize inaccurate or incomplete standing settlement instructions (SSIs), which are one of the biggest reasons for trade failure.
Confirmation ensures you understand what's been bought or sold, 什么需要交付或接收. Ideally it should also verify the place of settlement and location of the relevant accounts. If both parties provide that information and both parties have agreed, you've locked in your economic risk and your settlement risk.
Using the no-touch workflow eliminates your need to 赛前 prior to settlement because it's been done straight after execution as part of confirmation.
Our central trade matching platform (中医™) enables same-day confirmation and matching of trades globally. 中医 in tandem with our 警报 database can reduce SSI-related trade fails by enriching trades with golden-source account and standing settlement instructions. 另外, our 警报 Key Auto Select (AKAS) feature determines the preferred place of settlement and location of accounts.
We encourage clients to populate their outbound SWIFT messages to their settlement agent or custodian with this locked-in data. 这种方式, they’re distributing the same data they’ve agreed with their broker-dealer all the way through the 帖子-trade lifecycle.
For buy-side firms we offer the Global Custodian Direct workflow. This tool allows global custodians to manage SSI maintenance and ownership within 警报 on behalf of their buy-side clients by automating the exchange of SSIs between a custodian’s central repository and the 警报 database.
In cases w在这里 trade failures and exceptions do happen, 存 Exception Manager will allow counterparties to view exceptions when they occur so they can be addressed or fixed prior to settlement. 如果交易失败, 可以突出显示例外情况, and the dataset can be shared among the relevant parties to that transaction.
在交易失败之前修复异常, 或者很快之后, allows firms to mitigate their exposure to regulator-imposed penalties and buy-ins.
CSDR的准备工作可以外包吗?
Buy-side compliance cannot be outsourced to a custodian or a broker. 因此, firms must look for gaps in their current trade processes and 帖子-trade lifecycles in terms of what the CSDR discipline regime will impose, then run an analysis to judge whether they can plug those gaps internally or need to seek out a vendor or third-party system.
Our clients can do this gap analysis using a 存 best-practice scorecard that breaks the 帖子-trade lifestyle into four components: SSI and general reference data; confirmation and the automation of confirmations; notification out for settlement; and exception management capture and trade analytics. The scorecard can identify gaps in data sources or processing.
哪里有缺口, we can help clients plug them - by identifying the 存 services they can use or, 对于那些想把一些工作留在内部的人, recommending capabilities they should build in order to mitigate their settlement risk. Some clients may achieve top marks across all four areas of the scorecard yet still have trades fail. 在这种情况下, the scorecard says you're likely not at fault because your processes are designed to make sure the trade is settled with finality on its settlement date.
One thing that I emphasize to my clients is: make sure you're using your systems, 内部或外包, 它们本来的样子. 如果你使用一个服务, utilize all of its features - it doesn't cost you extra and you'll get additional benefit when CSDR’s discipline regime takes effect.
To hear more from 存’s experts about how the buy-side can prepare for the compounding impact of regulations such as CSDR, SFTR和UMR, 阅读完整的Global Custodian增刊 在这里.
欲了解更多vns6060威尼斯城官网CSDR的信息，请访问 www.存.com/csdr
This article was originally published in Global Custodian.