On 14 April 2022, SIFMA issued letter supporting accelerating settlement cycle to T+1.
- Benefits: risk reduction, capital optimization, improve post-trade processing efficiency.
- Recommended compliance date of 3 September 2024; did not support written agreement requirements, would disproportionately impact B/Ds; supported same day affirmation.
- Advocated to retain fallback exception for T+2 settlement in unforeseen circumstance.
- Requested an exemption from SEC Rule 15c6-1 for security-based swaps; called for commission support for dematerialization of all physical securities in circulation.
- Stated belief e-delivery should be default mechanism for prospectus, confirmations.