SEC Risk Alert Announces Exams of Firms’ Preparations for T+1 Settlement

On February 15, 2023, the SEC adopted final rules (Rules) shortening the standard settlement time for securities transactions from the current two business days after the trade date to one business day after the trade date (T+1). The Rules also shorten the process for confirming and affirming trade information and facilitate so-called “straight-through processing” of securities transactions. The Rules take effect for most broker-dealer transactions on May 28, 2024. In anticipation of that date, the SEC Division of Examinations (Exams) issued a Risk Alert reminding registrants it will continue to assess their preparedness for the change through examinations and outreach and detailing the information Exams will request. “As May 28, 2024, nears, it is critical that Registrants and other market participants prepare for the shortened settlement cycle and understand the impacts of T+1 and the [Rules] to identify necessary changes and critical dependencies in order to successfully manage this transition,” Exams advised. This article discusses the Risk Alert, with commentary from Genna Garver, partner at Troutman Pepper, and Charles A. Sommers, partner at Sidley Austin LLP. See “SEC Adopts Final Rules on Trade Clearance and Settlement” (May 11, 2023).

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