CSA NVS Amend T+1 Trade Matching

On Dec. 15, CSA authorities proposed harmonizing T+1 in regulations.

  • CSA NVS, CSA authorities proposed amending national instrument (NI) 24-101.
  • NI 24-101: Institutional trade matching and settlement, to align with T+1 settlement.
  • Follows Feb. 2022 CSA OSC T+1 accelerated settlement rulemaking, see #128430.
  • The proposal notices for the instrument and companion policy were disseminated by six provincial authorities: CSA NVS, CSA Que, CSA BC, CSA ALB, CSA NBW, CSA OSC.
  • Key Proposed Amendments
  • Proposed to amend in-the-money (ITM) deadline from 12pm on T+1 to 9pm on T.
  • Also, permanently repeal the exception reporting requirement for Form 24-101F1.
  • Remainder of proposed amendments are technical, reference, housekeeping, language
  • Separately, the authorities published CSA staff notice 81-335 Investment fund settlement cycles to exclude NI 81-102 Investment funds from the T+1 requirements.
  • Allows funds the flexibility to set a shorter settlement cycle, as deemed appropriate.
  • Further, acknowledged operational difficulties for mutual funds re T+1 time horizon.
  • Effectiveness
  • Recommends effect in 2024 for SEC alignment; proposal comments by Mar. 17, 2023.
  • Dec. 15, 2022 CSA SSK NI 24-101 Proposal
  • On Dec. 15, 2022, CSA SSK published NI 24-101 and companion policy proposals.
  • Annex C is the backline to NI-24-101; Annex D is the backline to the companion policy.
  • Document dated Dec. 15, 2022, received Jan. 4, and summarized on Jan. 6, 2023.
  • In Jun. 2023, CSA issued blanket orders re Form 24-101F1 exemption, see #176430.
  • In Oct. 2023, CSA proposed amendments to facilitate shorter settlement, see #188670
  • Dec. 2023 CSA Final Amendments
  • On Dec. 14, 2023, CSA published final amendments to NI 24-101, companion policy.
  • Amendments reflect upcoming shortening of settlement cycle for equity and long-term debt market trades from two days after trade (T+2) to one day after trade (T+1).
  • The amendments had originally proposed an ITM deadline of 9pm Eastern Time on T.
  • In response to comments, the ITM deadline has been revised to 3:59am on T+1.
  • If all necessary approvals are obtained, final amendments take effect May 27, 2024.

Regulators CSA; CSA ALB; CSA BC; CSA NBW; CSA NVS; CSA OSC; CSA Que; CSA SSK
Entity Types B/D; Bank; Depo; FCM; OTC
Reference PR, RF, 12/14/2023; CSA OSC: Nt, Bul Vol. 46 Is. 50 p.10059, 12/14/2023; CSA Que: Bul Vol. 20 No. 49 p. 616, 12/14/2023; RF NI 24-101, NI 81-335, PR, 12/15/2022; CSA NI 24-101; CSA NI 81-102; CSA NI-81-335;
Functions Compliance; Legal; Operations; Risk; Settlement; Technology; Trade Reporting; Trading
Countries Canada; United States of America
Category
State
Products Banking; Custody; Derivatives; Futures; Securities
Regions Am
Rule Type Final
Rule Date 12/15/2022
Effective Date 5/27/2024
Rule Id 156887
Linked to Rule :128430
Reg. Last Update 12/14/2023
Report Section International

Last substantive update on 12/19/2023