EFAMA US T+1 FX Settlement Risks


On Mar. 14, EFAMA informed of US move to T+1 settlement's risks.


  • EFAMA said US move to T+1 creates FX settlement risks for European asset managers.
  • EFAMA issued a policy statement entitled Impacts of the US move to T+1 settlement in Europe-How to avoid a new Herstatt crisis?, re dealing FX trades across time zones.
  • Follows SEC final rule to B/D settlement cycle from T+2 to T+1, see rule #128801.
  • Call for Action
  • EFAMA called on central banks, regulators to consider the FX settlement risk impact.
  • A recent EFAMA survey of European fund managers estimates that 40% of daily FX flows will not be able to settle through the CLS platform, amounting to USD 50-70 bn.
  • EFAMA urged central banks and regulators to take a more pro-active role in requiring mitigating measures e.g. CLS cut-off time extension, and improved custodial cut-offs.
  • This urgency is further compounded by the fact that soon after the US go-live on T+1 implementation, major indices like MSCI World are set to rebalance on May 31, 2024.
  • Policy Statement
  • CLS Bank International was set up in 2002, as a private sector initiative, by a number of large global banks; CLSSettlement mitigates settlement risk for market participants.
  • CLS operates a Payment versus Payment (PvP) system, and relies on a time window when all major central banks’ RTGS (real time gross settlement) are operational.
  • In order to enable simultaneous settlement across all trade exchange participants.
  • CLS also offers funding and operational efficiencies by settling via a single platform.
  • When the US shortens its settlement cycle to T+1, European asset managers, will have a very limited ability to access CLS for their USD trades; CLS access will be reduced.
  • The inability to use CLS pushes asset managers into costlier and riskier alternatives.
  • Without necessary adjustments to make the CLS platform accessible, the asset management industry cannot agree that T+1 will make the system safer for everyone.
  • SEC, NY Federal Reserve, ECB should take a more active role in understanding impacts on settlement risk and to take mitigating measures e.g. CLS cut-off time extension.
  • And adoption of later cut-offs (more aligned with CLS) by the custodian community.
  • Effectiveness
  • The US go-live on T+1 implementation has been scheduled for May 28, 2024.

Regulators EFAMA; SEC
Entity Types B/D; Bank; IA; Inv Co
Reference Rp, PR, 3/14/2024; Cycle
Functions Compliance; Legal; Operations; Product Administration; Record Retention; Risk; Settlement; Trade Reporting
Countries Canada; European Union; Mexico; United States of America; Cross-Border
Category
State
Products ABS; Banking; Clearing; Derivatives; Equity; ETFs; Fixed Income; Forex; Fund Mgt; Issuance/IPO; MMF: Money Market Fund; Mutual Funds; Securities; Structured Products
Regions EMEA
Rule Type Final
Rule Date 3/14/2024
Effective Date 5/28/2024
Rule Id 204811
Linked to Rule :128801
Reg. Last Update 3/14/2024
Report Section EU

Last substantive update on 03/19/2024