Good morning. This is an open
meeting of the U.S. Securities and Exchange Commission on March 22,
2017, under the Government in the Sunshine Act. The Commission today
will consider a recommendation from the staff to adopt an amendment to
shorten the standard settlement cycle for most securities transactions
from three business days after the trade date, T+3, to two business days
after the trade date, T+2.
At last, today is Judgment Day for T2. As I mentioned during my remarks
at last year's open Commission meeting to propose moving to a T+2
settlement cycle,[1]
rarely is an issue as commonsensical or broadly supported as this one.
As many of you know, I have been an enthusiastic supporter of this
initiative for quite some time. I am pleased that the Commission is now
in a position to consider the adoption and implementation of a T+2
settlement cycle, thus terminating a long and overdue process. It is
finally time to say hasta la vista to the antiquated T+3 settlement cycle.
The financial markets have changed significantly since the Commission
adopted Rule 15c6-1 in 1993. New products have emerged, trading volumes
have grown, and technology has evolved. In addition, the regulatory
community and market participants have increased their respective focus
on effectively managing credit, market, and liquidity risk. Transition
to a T+2 settlement cycle will reduce by one business day the time
horizon for risk exposures as well as for potential liquidity pressures,
which should yield other benefits for market participants and the
clearance and settlement infrastructure as a whole. Market participants'
overall exposure to unsettled trades should decrease, as should any
attendant credit, market, and liquidity risk. This, in turn, should
improve capital efficiency and enhance the resilience of the national
clearance and settlement system.
The recommendation before us sets Sept. 5, 2017 as the compliance date
for the implementation of T+2 settlement. Market participants, with the
assistance of an industry steering committee, already have been working
to prepare the securities industry for a transition to T+2 by that date.
The Commission's action today should help further that goal while also
demonstrating how an effective partnership between the public and
private sectors can result in stronger and more resilient financial
markets. It will be incumbent on each broker-dealer, mutual fund,
self-regulatory organization, trading venue, clearing agency, transfer
agent, and other affected market participant to do its respective part
to ensure a collective readiness for a smooth transition to T+2.
Before I ask Heather Seidel, the Acting Director of the Division of
Trading and Markets, to provide additional details about the
recommendation, I would like to thank Heather, her deputy director Gary
Goldsholle, as well as their counsels Moshe Rothman and Devin Ryan for
their leadership on this rulemaking. I also would like to thank Scott
Bauguess, Vanessa Countryman, and Hari Phatak for quarterbacking the
effort by the Division of Economic and Risk Analysis.
I am also incredibly grateful to the core rulemaking team for all their hard and exceptional work, in particular:
- Christian Sabella, Jeff Mooney, Justin Pica, Elizabeth Fitzgerald, Susan Petersen, Andrew Shanbrom, and Jesse Capelle from the Division of Trading and Markets.
- Adam Yonce and Charles Lin from the Division of Economic and Risk Analysis.
Many thanks as well to Sanket Bulsara, Meridith Mitchell, Lori Price,
Robert Teply, Cynthia Ginsberg and Leila Bham from the Office of
General Counsel.
In addition, I would like to thank many other staff throughout the
agency for their contributions, including Jonathan Ingram and Heather
Maples from the Division of Corporation Finance; Doug Scheidt, Sarah ten
Siethoff, Kathy Joaquin, and Jennifer Palmer from the Division of
Investment Management; and Ray Lombardo, Tim Fox, Josephine Tao, Valerie
Dahiya, Andrea Orr, and Darren Vieira from the Division of Trading and
Markets.
Last, but certainly not least, I would like to express my gratitude to
Commissioner Stein, who has been a great partner in bringing this
rulemaking to fruition.[2] Your engagement, and that of your counsels, is much appreciated.
Now, I will ask Heather and her team, as well as Scott Bauguess, our
Acting Chief Economist and Director of the Division of Economic and Risk
Analysis, to provide additional details on the recommendation.
[1] Michael S. Piwowar, "Statement of Commissioner Piwowar at Open Meeting Regarding Proposal to Shorten the Trade Settlement Cycle" (Sept. 28, 2016), available at https://www.sec.gov/news/statement/piwowar-statement-open-meeting-092816.html
[2] Commissioner Michael S. Piwowar and Commissioner Kara M. Stein, "Statement Regarding Proposals to Shorten the Trade Settlement Cycle" (June 29, 2015), available at https://www.sec.gov/news/statement/statement-on-proposals-to-shorten-the-trade-settlement-cycle.html.