| Thinking
the Unthinkable: The Case for T+1 |
|
September 11, 2001 made us rethink probabilities
and the extent of impacts once thought of as unthinkable. With devastating
clarity, September 11 highlights the need to plan for "worst-case"
scenarios.
| What effect did the September
11th events in the U. S. have on T+1? |
 |
Clear demonstration of the
need for STP |
 |
Delay in the timing of T+1
by one year to June 2005 |
|
| by Barbara Amsden |
|
Risk is measured by analyzing probabilities and impacts. Where risk
is unavoidable or accepted for business reasons, it is managed to
an appropriate level by the application of policies, processes,
controls and oversight. The residual risk is financed or transferred.
The market volatility of the past few years and the increase in
securities transaction volumes over the past decade underscore the
need to address counterparty settlement, market and operational
risks. Two years before the September 2001 terrorist attacks on
the U.S., concerns with such risks and the system's capacity to
handle growing volumes led to proposals in Canada and the U.S. to
reduce the securities settlement cycle from T+3 to T+1 by moving
to straight-through processing (STP).
What are T+1 and STP and what are the exposures in the current
T+3 environment? What financial and operational gains will flow
from a shortened settlement cycle and what does this mean for the
Canadian securities industry? For investors and for your firm?
|
| |
| WHAT ARE T+1 AND STP? |
|
Many confuse T+1 and STP. T+1 is shorthand for reducing the securities
clearing and settlement cycle from the current standard of three
days after trade date (T+3) to one day (T+1). STP occurs when securities
transactions are processed electronically from seller through intermediaries
through buyer, with no manual intervention. STP is possible--desirable,
even--without T+1, but its true benefits arise only when it is adopted
market-wide. T+1 is a rallying point for moving to STP across the
industry to reduce risk, improve efficiency, lower costs and sustain
market competitiveness.
|
| |
| WHAT ARE THE RISK EXPOSURES
IN THE CURRENT T+3 ENVIRONMENT? |
| In the wake of the October 1987 market crash, the
Group of 30 (G-30), an international consultative body, questioned
whether securities firms and investors affected by huge losses could
cover their obligations. A key recommendation in the ensuing G-30
report was to shorten the settlement cycle. This led to the 1995 move
in North America from settlement on the fifth day after trade date
(T+5) to T+3. Canadian and U.S. G-30 Working Committees agreed that
differing settlement conventions in the two countries would risk disruptions,
distortions and a dislocation of business, likely increasing costs
and risks for investors.1 The significant increases in securities
volumes, values and market volatility that exist today are similar
to the conditions that led to the G-30 recommendations and the implementation
of T+3 (see Chart 1). |
|
Annual Canadian Exchange
Trading Volume and Value Growth, 1990-2000

|
|
A number of other trends exist today that have increased risk exposures
in the market. For example, the consolidation of market participants
and the institutionalization of investment activity can lead to
an increase in risk. This is due to a decrease in participants in
the settlement system and greater concentration of trading volumes
and values among fewer principals.
Another factor is the globalization of investment management. Fifteen
per cent of Toronto Stock Exchange (TSE) listings are now interlisted,
accounting for 40 per cent of TSE trading value. The trend to global
access and trading is attractive to issuers and investors, but less
so to regulators as they see potentially greater exposures to the
capital base of intermediaries, including those that may not be
subject to their direct oversight. When clients buy securities in
a market outside their home country, steps involved in a trade multiply,
contractual obligations of market participants and laws governing
ownership rights vary, and operational complexity is added by differences
in time zones, practices and languages.
New entrants also increase risk. New participants may be good for
competition, but they are not always as well-capitalized or able
to withstand significant trading losses. Stretched systems and processes
are also a risk. The current systems in use were designed to handle
fewer transactions and the processes are often still paper-based
and manual. U.S. experts predicted in 1999 that cross-border trades
would triple by 2002, increasing risks and strains in the system.
Even with the market slowdown, volumes are up significantly from
the beginning of the decade.
The result of these trends is the increased likelihood that a transaction
may not be completed or that one of the parties to a transaction
may fail. For example, as cross-border transactions have increased,
so too have transaction fail rates. The number of cross-border securities
trades that fail to be completed may be as high as one in five and
one international body estimates that over 40 per cent of securities
operations time is spent dealing with such failed trades. These
trends have several associated risks:
Settlement risk: The risk that
settlement will not take place as expected, comprised of credit
risk - the risk that a counterparty will not settle an obligation
for full value (a combination of principal and replacement cost
risk) and liquidity risk - the risk that an obligation will not
settle when due.
Market risk: The risk of losses
due to movements in market rates.
Operational risk: The risk
that a breakdown in information systems, internal controls or human
error may cause unexpected losses.
The convention of settling securities transactions over an extended
period of time also exacerbates systemic risk - the risk that the
failure of one institution will trigger failures of others, threatening
the stability of financial markets. Systemic risk rises with increased
volumes and volatility and is more concentrated as intermediary
numbers fall.
In January 2001, the Bank for International Settlements (BIS) published
a consultative report2 identifying risks in securities
settlement systems and recommending ways to reduce or eliminate
these exposures, including shortening the settlement cycle. As the
report noted, the G-30 recognized that "to minimize counterparty
risk and market exposure associated with securities transactions,
same-day settlement is the final goal." In September 2001,
the BIS issued its Working Paper on Regulatory Treatment of Operational
Risk. This contains proposals for calculating the capital levels
to be maintained against inherent operational risks in eight business
lines, including payment and settlement, asset management, trading
and sales, agency services and custody, and retail brokerage.
|
| |
| WHAT FINANCIAL AND OPERATIONAL
GAINS WILL FLOW FROM A SHORTENED SETTLEMENT CYCLE? |
|
Aside from risk reduction, the benefits from the move to STP and
from T+3 to T+1 will be seen in several areas:
The Canadian Capital Markets
In Canadian markets, an average of 135,000 equity, debt and money
market trades are made daily. In the T+3 settlement cycle, the value
of trades awaiting settlement at the end of each day ranges from
$100 to $150 billion. Given the three days it takes to settle trades,
the total dollar amount outstanding on any business day is three
times this, a daily credit/settlement risk of $300 billion to nearly
half a trillion dollars. Shortening the settlement cycle to T+1
will reduce the overall daily risk associated with unsettled trades
by two-thirds. This will strengthen our financial markets and maintain
Canada's competitiveness with the U.S. and globally, while keeping
business and the related tax revenues in Canada. As well, the proposed
BIS capital accord may lead to a reduction in regulatory capital
requirements for firms that demonstrate lower operational risk.
Securities Market Firms
Increasing the automation of trade processing will reduce credit
exposure and operational risks associated with securities trades,
while improving productivity and liquidity. Cost savings from a
shortened settlement cycle are derived from improved operational
efficiency and retention of revenues. The original G-30 report assessed
this risk of revenue loss as 10% of settlement and trading revenues,
a percentage viewed as conser-vative as it excluded estimates of
revenues from debt trades, custody, securities lending, deposit
balances and cash management/foreign exchange.
Investors
T+1 and greater automation of the system will reduce risk, improve
service and increase liquidity. The move to STP required for T+1
implementation will support round-the-clock trading demanded by
a growing number of investors. Also, by improving settlement efficiency,
we can expect to see lower risk and transaction costs that should
translate into improved trade prices for investors.
|
| |
| WHAT DO T+1 AND STP MEAN
FOR THE CANADIAN SECURITIES INDUSTRY? |
|
The U.S. T+1 business case shows that the move will generate tremendous
benefits for the American securities industry. The U.S. Securities
Industry Association (SIA) claims that the increased efficiencies
resulting from T+1 are expected to generate US$2.7 billion in pre-tax
annual net benefits for a one-time investment of US$8 billion. Consequently,
the U.S. remains committed to implementing T+1 despite and because
of the events of September 11.
Although both the investment and benefits for the Canadian market
are expected to be proportional to those in the U.S., the Canadian
securities industry has not undertaken a comparable analysis. This
is because Canada's very capital markets industry and the preservation
(if not expansion) of its securities business are at stake. In an
increasingly global market, Canada's processing systems must be
in harmony to support cross-border securities activities.
The disadvantages of not moving to T+1 at the same time as the
U.S. are that Canadian investors would almost certainly see higher
settlement costs and higher risks than in the U.S.3 With North American
securities markets so highly integrated, different settlement periods
between Canada and the States could result in the movement of some
trading activity south, given the natural convergence of transactions
to the marketplace with narrower bid-ask spreads.
|
| |
| THE MOVE FROM T+3 TO T+1
AND TO A GREATER DEGREE OF STP REQUIRES: |
|
 |
Fundamental systems and technology
changes to allow automated matching to handle growing trade
volumes |
 |
Seamless communication through agreement
on interconnectivity, data messaging and other standards and
best practices, including adoption of a mechanism to report
adherence to, and enforce, standards |
 |
Changes to operational procedures
and conventions |
 |
Electronic rather than physical securities
holdings, handling and payments |
 |
Resolution of legal issues. |
The costs associated with the change from T+5 to T+3 were mostly
process- and education-related. In the move to T+1, a major cost
to participants will be investment in new information and processing
technology. Hard costs aside, a key challenge will be the cultural
and organizational transformation that must accompany technology
changes.
|
| |
| WHAT DO T+1 AND STP MEAN
FOR INVESTORS AND INVESTMENT MANAGERS? FOR YOUR FIRM? |
|
With such a broad scope to the changes required, the move to T+1
and STP will have a dramatic effect on all participants in the securities
markets.
Custodians will benefit from lower costs due to reduction in time
spent obtaining missing information, correcting errors and matching
trade instructions. They may gain new business opportunities providing
outsourcing services.
Brokers have already faced the reality of lower commissions and
spreads falling while trade processing costs have remained flat
and therefore require the long-run savings possible from STP.
They will also benefit by having more time available for "real"
business as less time is spent dealing with errors, etc.
Investors and investment managers will have faster access and may
save considerably on cash management. They may be able to rationalize
their data architecture and receive securities data from fewer vendors.
However, as with Y2K worldwide, decimalization in the U.S. and the
move to the Euro in Europe to address identified risks, there may
be large costs involved in moving to STP and T+1.
The SIA estimated a US$1.7 billion investment for the asset management
industry in the United States. This is to be spent on modifying
internal processes to ensure compliance with compressed settlement
deadlines (US$790 million), sharing in the development of industry
matching utilities and linkages for all asset classes (US$195 million)
and standardizing reference data and industry protocols (US$675
million). Canadian investment managers will have to undertake their
own assessment of the costs of the changes required, which include:
 |
Upgrades to trade accounting to accelerate
the matching of order fill details to trade orders and provide
notification of errors in real time |
 |
Communication of trade details in
real time to brokers and settlement agents |
 |
Implementation of real-time trade
clearing and settlement systems |
 |
Communication more quickly and with
additional detail on bulk trade allocations. |
With the certainty of winners and losers, we will see increased
measurement of the cost and source of problems. The good news is
that already one investment manager, with information from its custodian,
pinpointed changes to make, at virtually no cost, to significantly
improve its STP rate: namely, devote some administrative time to
counterparty codes and securities identifier cross-references.
This being said, the decisions investors and investment managers
will face are standard ones: build, buy, outsource, exit. The cost
of build-and-buy options may be high, depending on the state of
a firm's current systems and business. Firms thinking that they
do not have to worry because they will outsource should think again.
As with Y2K, the question for those using service providers is 'will
their service providers be ready?' and, for those not already using
service providers, 'will there be service providers available?'
as it is no easy task to outsource a back office. And exiting? Already
some investment managers in the U.S. and, it is understood, in Canada
will no longer deal with brokers that cannot provide their information
electronically. U.S. research firm Tower Group estimates that 25
per cent of brokers will be out of business within 10 years due
to STP and T+1. There may be similar consolidation of investment
managers.
|
| |
| What should investment
managers do to start preparing for STP and T+1? |
 |
Assess where you are - use the T+1 Readiness Checklist
of the CCMA, (found at www.ccma-acmc.ca) |
 |
Inventory your status quo |
 |
Map your current workflow |
 |
Measure and cost your current performance |
 |
Determine if T+1/STP is strategic or tactical |
|
| |
| CONCLUSION |
|
In the securities industry, it is often said that "nothing
good happens between trade and settlement." This is due, in
part, to the complexity of the capital markets and variations on
securities transactions. Beyond buy or sell transactions and variations
on these, funding arrangements may need to be secured, foreign exchange
contracts may have to be executed and, if securities are on loan,
they may have to be recalled. For T+1, the same activities must
occur within little more than 24 hours. The compression of processing
will require adoption of advanced communications and technology,
as well as operational and behavioural/cultural change. As we look
at these changes, there are still a few questions:
Would settlement on T+1 have prevented
any settlement problems in capital markets following the events
of September 11?
T+1 would not have; STP would. Clearing and settlement in the U.S.
were only minimally affected by the terrorist attacks. There were
only a few certified trades, and some transactions where instuctions
were unconfirmed by the counterparty by the intended settlement
time, which failed to settle. The Federal Reserve's U.S.$38 billion
cash injection, coupled with the extension of agency settlement
hours of operation, are credited with easing the possibility of
failed trades. Greater straight-through processing and replacement
of certificates with electronic holdings necessary for getting to
T+1, rather than T+1 per se, would have helped. For example, firms
with affirmed September 10 trades (indicating use of STP) are credited
with being better off than ones that had unaffirmed trades and investors
without certificated securities were better off than those still
holding paper. They now face the time and cost required to replace
their holdings before they can sell in volatile markets.
If the benefits of T+1 are good, aren't
the benefits of T+0 - settlement on the same day as the trade -
better? Should T+0 be the goal?
Yes and no. Yes, T+0 is better. T+0 has been achieved in Canada
for money market instruments and T+0 settlement could be achieved
for marketable debt and soon, potentially, equities. No because
the U.S. is moving to T+1 and has concluded that the move to T+0
is too radical a move at this time. For Canada to move to T+0 would
add operational complexity at a time that the industry is already
undergoing dramatic change. Firms are encouraged to design with
T+0 in mind, so that such a change in the future can be easily accomplished.
The ultimate question is one that only individual organizations
can answer:
Do the risks of remaining in a manual,
paper-based environment now outweigh the risks of jumping into the
future?
September 11 has caused every thinking participant in the securities
industry to re-assess their disaster and business recovery plans
and identify changes that will more fully bullet-proof their services.
The outcome of this assessment should spur greater haste in moving
to straight-through processing, even as there is a delay in moving
to T+1.
In light of the U.S. decision to delay their T+1 target conversion
date from June 2004 to June 2005, the CCMA agrees that Canada's
target T+1 conversion date will similarly be delayed to June 2005.
This means that by June 2004, Canada must be ready to begin industry-wide
testing and testing with the U.S. The CCMA will press forward with
other changes to promote industry-wide adoption of straight-through
processing in all markets, where reasonable, as soon as possible.
The terrorist attacks of September 11th emphasize the need for more
extensive straight-through processing and the reduction of manual
processing of trade information and physical movement of paper certificates,
cheque payments and documentation. Plans in this regard are set
out in three papers being issued for comment in November and December,
2001, with a comprehensive plan expected to be released in the first
part of the New Year.4 The CCMA will continue to design and plan
for T+1 implementation in concert with the U.S. to make sure that
Canada remains globally competitive.
|
| |
| ACKNOWLEDGEMENT |
| Thanks to Keith Martin, an independent consultant,
for reviewing the drafts of this article and for providing input on
the Bank for International Settlements' recommendations regarding
risk management in securities settlement systems and proposals for
a regulatory minimum capital requirement for operational risk. * |
| |
| ENDNOTES |
|
1 The Canadian G-30 has now been succeeded by the Canadian
Capital Markets Association, a not-for-profit organization identifying,
analyzing and recommending ways to meet the challenges and opportunities
facing Canadian capital markets.
2 Recommendations for Securities Settlement Systems, Report
of the Committee on Payment and Settlement Systems ("CPSS")
and the Technical Committee of the International Organization of
Securities Commissions ("IOSCO") Joint Task Force on Securities
Settlement Systems, Bank for International Settlements, Basel, Switzerland,
January 2001 (www.bis.org or
www.iosco.org).
3 According to a November 2000 study commissioned by the
Canadian Capital Markets Association (CCMA).
4 For more information and updates, see www.ccma.ca.
|
| |
| REFERENCES |
|
Arthur Andersen Consulting and The Capital Markets Company. T+1
Business Case: Final Report, July 2000, Securities Industry Association.
Basel Committee on Banking Supervision. Operational Risk - Supporting
Document to the New Basel Capital Accord, Bank for International
Settlements, Basel, Switzerland, January 2001.
Basel Committee on Banking Supervision. Working Paper on the Regulatory
Treatment of Operational Risk, Bank for International Settlements,
Basel, Switzerland, September 2001.
Canadian Capital Markets Association. Institutional Trade Processing
T+1 White Paper, March 2001.
Charles River Associates. Free-riding, Under-investment and Competition:
The Economic Case for Canada to Move to T+1, November 10, 2000.
Forrester Research Inc., "The Real Benefits of T+1,"
The Forrester Report, September 2001.
John Kennedy, "A Perspective On Changes To Canada's Securities
Settlement System" (unpublished), October 7, 1999.
Report of the Committee on Payment and Settlement Systems ("CPSS")
and the Technical Committee of the International Organization of
Securities Commissions ("IOSCO") Joint Task Force on Securities
Settlement Systems (www.bis.org or www.iosco.org). Recommendations
for Securities Settlement Systems, Bank for International Settlements,
Basel, Switzerland, January 2001.
|
| |
| Barbara Amsden is treasurer of the Canadian Capital
Markets Association and assistant vice-president, Planning and Communications,
at the Canadian Depository for Securities |
| |
| |
|