Thursday, October 6, 2022

Is T+1 Something We Can All Agree On?

The Industry Reacts to a Compressed Settlement Plan

Author: David Schwartz J.D. CPA

In moving to shorten the U.S. securities settlement cycle by one day to T+1, the Securities and Exchange Commission appears to have hit on something upon which virtually everyone can agree. Judging by the comments to the SEC's T+1 proposal, everyone from State Street to the Cornell Securities Law Clinic agrees that moving to T+1 is both desirable and beneficial to risk management in the long run. That said, despite this rare moment of accord between the regulator and the regulated, according to some commenters, some parts of the proposed implementation need attention, fine-tuning, or reconsideration. 

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Tuesday, February 15, 2022

T+1: The Future is Now (or at least as early as 2024)

The SEC Boldly Sets Course for T+1 and T+0

Author: David Schwartz J.D. CPA

While real-time settlement is still something that may happen far in the future, perhaps on the Starship Enterprise, T+1 is now imminent. On February 9, 2022, the Securities and Exchange Commission proposed to make T+1 a reality. The proposal aimed at reducing risks in clearance and settlement seeks comment on shortening the current T+2 standard settlement cycle for most broker-dealer transactions by one day to T+1. Notably, the proposal also makes clear that T+0 is the ultimate and eventual goal and explicitly solicits comments on associated challenges and potential paths to achieving a same-day settlement cycle.

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Tuesday, May 16, 2017

Fed General Counsel Addresses the New Compliance Landscape

Compliance is More Important than Ever, but Approach May Be Too “Rules Based”

Author: David Schwartz J.D. CPA

In a May 9th Address, Michael Held, Executive Vice President and General Counsel of the Federal Reserve Bank of New York, gave his thoughts on the new compliance landscape. Held told his audience at SIFMA’s Compliance and Legal Society Monthly Luncheon that in recent years the role of compliance within supervised financial institutions has grown dramatically in size, scope, and relevance. He also said that since the financial crisis, risk and compliance functions have grown in respect and stature across the financial services industry. Despite this new stature, however, those charged with monitoring compliance at financial institutions face an environment that has become perhaps “too rules-based.” Held offered his thoughts on firms and compliance personnel can meet these new challenges.

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Sunday, May 15, 2016

Fordham Students Submit Comment Letters to Basel Committee

Author: David Schwartz J.D. CPA

On May 16, 2016, Fordham students participating in the Center's Regulatory Outreach for Student Education (ROSE) Program submitted their comment letters on the Basel Committee's December 17, 2015 consultation, "Identification and Measurement of Step-in Risk."  

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Friday, April 15, 2016

SEC Chair White and the Evolving Role of Fund Directors

Author: David Schwartz J.D. CPA

In her March 29, 2016 keynote address before the Mutual Fund Directors Forum’s annual policy conference, SEC Chair Mary Jo White laid out some of her thoughts on the role of mutual fund directors in assessing risks and exercising their oversight responsibilities.  In addition, she highlighted recent changes in markets and regulation affecting the role of fund directors, as well as some of the potential challenges ahead. 

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