euroclear moves france
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Euroclear moves France, Netherlands and Belgium to T+2settlement
Euroclear will move the Paris, Amsterdam and Brussels markets to T+2 settlement
Securities trading in France, the Netherlands and Belgium is to move to T+2 settlement in October 2014,
following a decision by Euroclear to pre-empt Europe-wide settlement reforms.
Euroclear runs the central securities depositories across large parts of Europe, in which securities are settled
after a trade. T+2 settlement means that securities transactions settle two days after the trade date, rather than
three as at present. The move pre-empts the proposed 2015 start date suggested in the European Commissions
pending CSD Regulation for T+2 settlement across the European Union. It also pre-empts the European Central
Banks T2S platform, due in 2016, which will also operate T+2 settlement.
Euroclears central securities depositories in France, the Netherlands and Belgium will be the first to move.
Euroclear Finland, Sweden and UK & Ireland are also considering a switch to T+2, with recommendations and
timelines expected during 2014.
The concept of a shorter settlement cycle across Europe has its roots in the work of the Giovannini Group in
2001-3, said Valrie Urbain, chief executive officer of Euroclear Belgium, France and Nederland. We concur
with the Association for Financial Markets in Europes recent findings that a move towards a shorter settlement
cycle will increase operational efficiency, as well as drive down counterparty risks. After extensive
consultationwe took the decision to commit to T+2 settlement now and to make the transition earlier than
required.
The AFME study referred to by Urbain, Impacts of implementation of T+2,was published in May 2013 and
suggests that T+2 settlement will reduce risks post-trade. The document recommends that T+2 implementation
should precede T2S in June 2015, to allow market participants time to prepare. It also notes that affirmation,
allocation and confirmation will need to take place on the trade date, with pre-settlement date matching preferably
on the trade date and taking place on T+1 at the latest.
Urbain added that the Euroclear CSDs are ready to settle in T+2, but acknowledged that making the changes
suggested by AFME would require a period of time for market participants to adjust.
Previously, most of Europe had operated on a T+3 model. The main exceptions were Germany, where German
CSD Clearstream has operated T+2 settlement for many years, and Russia, where T+0 settlement has been the
norm. However, in the case of Russia, the creation of a single CSD called NSD in late 2012 heralded the first
step in a move towards T+2 settlement. According to the Moscow Exchange, all stocks, RDRs and sovereign
bonds will be moved to T+2 in September.
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Comment: Europe faces
Settlement raceWith a host of European regulation coming over the next year, its difficult to know what requires immediate
attention.
In the last couple of weeks, the big focus has been on the progression of Mifid II, but market participants may
need to address aspects of a lesser-known incoming regulation far earlier than they realise.
European policy makers are putting the finishing touches tonew laws around settlement,contained in the Central
Securities Depositories Regulation (CSD-R). One of the most significant measures contained within in it is the
harmonisation of European settlement cycles, the period after a trade has been executed. Currently it is usually a
two or three day timescale and Europe wants a uniform period of two days. The switch, known in the industry as
T+2, is due to come fully into effect in January 2015.
But in reality this change will have to be put into practice in just over a years time. This is because the
implementation of T2S,a project with a similar-sounding name but one which the European Central Bank has
predicted will have a transformational effect on Europes financial markets.
Although the ECBs plan comes into effect in June 2015, it requires market participants give themselves ample
time to test the new system. Those tests are contingent on Europes settlement cycles being harmonised to T+2
in summer next year.
The two cannot be implemented separately. Paul Bodart, a member of the T2S Board at ECB was unequivocal
about the importance of shortened settlement cycles to T2S when he said at a recent Omgeo event, Shortened
settlement cycles and T2S go hand in hand. Trading with different settlement cycles will increase risk and failure,
the move to harmonised settlement cycles is critical.
This point was also highlighted in a recent report from the Association for Financial Markets in Europe, which
concluded that the optimum time for the introduction of shortened settlement cycles to T+2 was between August
and November 2014. Ultimately, this means the industry needs to start preparing for shortened settlement cycles
now.
As AFME also identified, one of the main prerequisites for achieving shortened settlement cycle is the need for
market participants to verify trades on the day they are executed. The shorter the time it takes for the two parties
to agree on the price and quantity details of their trade, the faster the trade can be settled. AFME also noted that
this process needed to be automatedwhich means that some institutions will have to significantly reengineer
their internal processes, which may incur costs.
But the rewards will be worth it because CSDR will bring three significant benefits to the securities industry:
reductions in the numbers of failed trades; a reduction in counterparty risk and more efficient use of collateral.
Faster verification of trades will significantly reduce counterparty risk since the economic details of a trade will be
agreed between counterparties more quickly. Given the volatility we are currently experiencing in both the equity,
and fixed income marketswhich looks likely to continue as central banks begin to exit stimulus programmes
acceleration of the settlement cycle becomes even more important.
Second, a reduced settlement cycle from three days to two will mean that clearing brokers will have less risk
exposure to their underlying clients. Finally,much-needed collateral for trading will be freed up as market
participants will only need to post margin with their clearing brokers for two days rather than three.
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This last point in particular will be welcomed by those concerned by the impact on the market of regulation that
will require more over-the-counter derivatives to be cleared.
Finally, it should not be forgotten that CSD-R propose fines for late settlement. The exact levels of punishment
have yet to be determined but the most likely penalty for counterparty which does not deliver the security within
the two-day settlement timeframe would be a cost relating to a buy-in.
As envisaged, if a trade does not settle, the market infrastructure operator would buy back the asset in the
market at prevailing market price, and then deliver it to the non-defaulting party. The defaulting counterparty
would incur the cost of this. If a buy-in is not possible, cash compensation would be paid instead.
The draft CSD-R also contains provisions for market infrastructure operators to report settlement failure statistics
to their regulators and also publish annual statistics for rates of trade failure. It also proposes that participants
who consistently and systematically fail to deliver can be suspended.
Being ready early, with all systems and processes tested, will save the risk of such costs being incurred. With just
over a year before harmonised and shortened settlement cycles are introduced, market participants should start
to prepare now if they wish to reap the benefits which it will deliver and avoid the financial penalties should they
not be ready.
Marianne Brown is chief executive of Omgeo, a trade processing group jointly owned by the Depository Trust and
Clearing Corporation and Thomson Reuters
EU to reduce settlement period for securitiesFrom 1 January 2015, securities transactions in European Union
regulated markets will have to settle no later than the secondbusiness day after trading takes place. This will shorten thesettlement cycle by a day in most member states, creating anumber of benefits but also some difficulties.
When the Central Securities Depositories Regulation (CSDR) comes into effect from 2015, it will create a
common regulatory framework for securities settlement across the European Union (EU).
One of its key measures is the harmonisation of the maximum settlement period for securities transactions at two
days after the trading day, T+2, and even shorter periods will be allowed. Most EU countries currently settle on
T+3, though a few, including Germany, are already on T+2.
After the 2008 financial crisis, the European Commission decided that national CSDsas key institutions
performing the vital post-trade process of securities settlement, as well as maintaining records of securities
accounts and transactionsneeded to harmonise their practices and improve the safety and efficiency of
transaction settlement.
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Central Securities Depositories (CSD) operations are generally safe within their countries, but when handling
intra-EU securities transactions the risks, likelihood of 'fails' and costs increase. Also, a longer settlement cycle
creates a longer period of counterparty risk exposure. Harmonisation through the CSD Regulation will help create
a true, open single market in CSDs and settlement, reduce the risks, improve efficiency and reduce costs.
The CSDR has three key components. First, it requires transferable securities issued by companies to be
dematerialised (ie kept in electronic rather than paper format) or immobilised and represented in book-entry form
on a CSD before they can be traded on regulated trading venues. This requirement is anticipated to come into
effect on 1 January 2020.
Harmonisation through the CSD Regulation will help create a true, open single market
in CSDs and settlement, reduce the risks, improve efficiency and reduce costs
Second, as already stated above, it harmonises securities settlement periods at a maximum of two days after the
trading day, T+2, across the EU. This requirement comes into effect on 1 January 2015, in time for the launch of
Target2 Securities (T2S) in June 2015. T2S is the provision by the European Central Bank of a central settlement
function for securities in central bank money in the euro area, with other European currencies invited to join.
Third, it introduces a common set of rules to harmonise 'settlement discipline' across the EU. These consist of ex
ante measures to prevent settlement fails, and ex-post measures to address settlement fails.
The CSDR dovetails with two other important regulatory developments in the securities sector: the second
version of the Markets in Financial Instruments Directive (MiFID II), which regulates trading venues; and the
European Market Infrastructure Regulation (EMIR), which regulates central counterparties and trade repositories,
especially in relation to over-the-counter (OTC) derivatives transactions.
T+2 the detail and the rationale
As stated above, the CSDR requires the intended settlement date to be no later than on the second business day
after the trading takes place. Elsewhere, the CSDR sets out that longer settlement periods of transactions in
transferable securities cause uncertainty and increased risk for securities settlement systems participants, and
that different durations of settlement periods across Member States hamper reconciliation and are sources of
errors for issuers. The CSDR states that it is therefore necessary to provide a common settlement period which
would facilitate the identification of the intended settlement date and facilitate the implementation of settlement
discipline measures.
The history
The first Giovannini report, published by the European Commission in 2001, recommended that settlement
periods should be harmonised across the EU. Meanwhile in the US at about the same time, the Securities
Industry Association (SIA) embarked on a project to examine the feasibility of moving to T+1, but decided it would
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not work due to the high use of paper and low levels of straight-through processing in the industry, and the fact
that foreign exchange settled on T+2.
The problem of long settlement cycles was highlighted by the 9/11 attacks in 2001 and the collapse of Lehman
Brothers in 2008, both of which left billions of dollars of securities transactions in the pipeline waiting to be
settled, creating hazardous levels of counterparty exposure.
The European Commission set up the Harmonisation of Settlement Cycles Working Group in 2009. The group
decided that T+1 would not work for the same reasons identified by the SIA, along with the fact that less batch
processing could be done and that it would create difficulties for trades involving counterparties in distant time
zones. The group therefore recommended T+2, which would harmonise with foreign exchange settlement
periods. Most of the EU operates to T+3 though Germany, Slovenia and Bulgaria are on T+2.
The US and Japan currently operate on a T+3 settlement cycle, Hong Kong is on T+2, and Russia is following
suit. The US will probably move to T+2 in the near future. Last year, the US CSD, the Depository Trust &
Clearing Corporation (DTCC) commissioned Boston Consulting Group to look into the costs and benefits of
shorter settlement cycles. It estimated that the costs of moving to T+1 would be so high that it would take 10
years for the costs to be recouped, whereas for T+2 the payback would come after three years.
The implications
For domestic electronic securities transactions in the EU, T+2 will have little impact, as most market participants
could already settle mainstream securities in two days if they needed to. For cross-border trades and less liquid
securities, especially those involving paper, there will be significant benefits of moving to a two-day cycle, but
also some potential challenges.
The key benefits, as I have already suggested, are:
Reduced counterparty exposure and, in turn, less systemic risk
Harmonisation of the rules across the EU, leading to greater certainty and clarity, increased efficiency and lower
costs in the long term
Greater efficiency and lower risk through 'dematerialisation' under CSDRelectronic records replacing paper
documentation
The possible challenges include:
The short-term costs and risks of dismantling existing practices and complying with new practices
Certificated trades possibly becoming harder to process
Overnight batch processing of trades having to become more efficient if they are to be completed in time
Communications with counterparties in different time zones, especially in Asia and the Americas, becoming
compressed
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Securities lendingstock that has been lent, especially down several layers, may be difficult or impossible to
recall in two days. Germany has been on T+2 for some time and its securities lending market functions well, but
other countries may have a different experience
Market participants that fail to deliver securities within four days of the agreed settlement date will be subject to
penalties, and will have to buy those securities in the market and deliver them to their counterparties
Looking ahead
Securities firms will need to take into account a number of wider operational and strategic business
considerations. In particular, shorter settlement might lead to more rapid trading and higher volumes. It could also
free up additional capital, because capital tied up in counterparty exposures could be released earlier.
Currently most trades are settled in batches and netted overnight, with firms having until the evening of T+2 to
get trades into the last batch and then settling the remainder in real-time on T+3. Under the new regime, the last
batch will be at the end of T+1, which could mean fewer trades making the batch (and therefore fewer netted),
and more settled in real-time on T+2. Longer term, batch processing itself may need to be reconsidered in favour
of earlier and more frequent real time settlement, in order to promote efficiency.
For all the potential drawbacks of shorter settlement, they should be outweighed by the benefits. As for
implementation, the move from T+5 to T+3 went smoothly, and there is every reason to expect that the migration
to T+2 will be successful too.