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Claire Santaniello

Regulation and Compliance > Federal Regulation

How BNY Mellon's Pershing Prepped for T+1

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With the U.S. securities market converting to a T+1 standard settlement cycle on Tuesday, ”all transactions need to match perfectly with counterparties on the day a trade takes place, leaving very little room to correct issues,” according to Claire Santaniello, managing director and head of operations for BNY Mellon’s Pershing.

ThinkAdvisor caught up with Santaniello, who leads initiatives to help broker-dealers and wealth management firms meet new compliance requirements, as the T+1 countdown closed in.

BNY Mellon was among the first firms to build a T+1 preparation program in 2021, according to the financial services giant.

The industry, according to Santaniello, needs to be educated on best practices in order to comply with T+1. She explained in the interview with ThinkAdvisor how BNY Mellon has been prepping for the T+1 transition and details other new rules taking affect in May.

THINKADVISOR: What has the testing revealed that BNY Mellon has been conducting regarding readiness for T+1?

CLAIRE SANTANIELLO: Since last August, BNY Mellon, along with other firms, has participated in rigorous industry testing in collaboration with the Depository Trust and Clearing Corporation. We also prioritized business testing, testing with clients, clients’ vendors and our own vendors across our various lines of business, including BNY Mellon’s Pershing.

All of this testing has enabled stakeholders across the industry to look holistically at the impact T+1 will have on all of our processes, and work together on solutions for not just our clients but the industry as a whole. A good example of this is the extensive testing we did collectively for different regional events and circumstances, such as holiday and corporate action processing.

It’s been hard work, but after executing thousands of test cases, we feel prepared that our systems and processes can handle all the complexity a shorter settlement cycle involves. We’re ready to support clients on go-live day.

You said T+1 touches the whole lifecycle of a transaction. Please explain. 

A common misconception is that T+1 is just about the settlement process, but it impacts so much more, starting at the beginning of the lifecycle. Case in point: The account opening process is key to ensure that settlement instructions are properly set up to meet the new affirmation requirements.

We’ve been helping firms with this readiness component through metrics and reporting tools that can help give firms a better understanding of how they’re doing and where they may be facing challenges within client accounts.

We’re also helping clients manage the settlement aspect with new tools, such as a bulk account opening tool for custodians, real-time trade transparency and repair tools, record-keeping tools, and tools that integrate with DTCC’s tools.

Can you explain how advisors need to meet new allocation, confirmation and affirmation requirements on trade date, and how post trade activities are now compressed from 19 hours to five hours. They need data and new systems?

Previously, while trades still had to be allocated, confirmed and affirmed, there weren’t specific SEC rules that governed when all of this had to happen. Affirmation didn’t have to take place for a settlement to be affected.

Now, this means all transactions need to match perfectly with counterparties on the day a trade takes place, leaving very little room to correct issues. As a result, trade activities are compressed from 19 hours to five hours. Trades must be allocated by 7 p.m. and affirmed by 9 p.m. So updated systems and data are essential for handling the tighter timeframes in settling trades, especially for firms in APAC.

The most pressing thing for firms is knowing what action to take should there be an issue, such as if a trade could be missing, or not matching up correctly. We provide a self-service tool to our clients that helps identify which trades might need attention so they can take action immediately.

Similarly, firms that have access to data on what trades haven’t been timely allocated or affirmed can then confidently know the next course of action to take with correcting a transaction and updating settlement instructions. We’ve made data available to do just this.

Other major rules go live in May: CAT, CAIS 2E and FINRA Rule 4210. Can you give some highlights about these new rules?

May is indeed a big month for new industry rules.

Take FINRA Rule 4210, which requires broker-dealers to collect funding for covered agency transactions until settled, effective May 22. This means they now need to have tools for collecting funds from customers when trades are pending. This affects institutional firms too.

CAIS is FINRA CAT’s Customer Account Information System. This is the final leg of the FINRA CAT plan and requires all member firms to submit the CAIS eligible data for all CAT reportable transactions. The compliance go live date for this is May 31, with an interim reporting obligation of May 24.

Ultimately, all these new mandates have created an exciting opportunity to bring the industry together to envision and ensure smooth implementations. Preparation has been key, and I’m looking forward to continuing to support our clients with more information and tools to help them be successful — and compliant.


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