corfinancial implements CSDR compliance software at Man Group

M Logo

London, 15 May 2023 – corfinancial®, a leading provider of specialist software and services to the financial services sector, announces the implementation of its Central Securities Depositories Regulation (CSDR) software, SureVu®, at Man Group, a global active investment management firm with $144.7 billion of AUM (as of 31st March 2023).

SureVu® enables buy-side firms to manage failed trades and cash penalty fees, as defined by the Settlement Discipline Regime, in one single solution.

“We were impressed by the speed with which SureVu went into production. Within three months, we had 90% of our custodians and prime brokers on-boarded and expect to have 100% of these parties live by the end of May,” said Antonio Dos Santos, Head of London Investment Operations at Man Group.

“One of the big drivers to implement SureVu was the changes introduced by the CSDR, but we also saw T+1 on the regulatory horizon and knew that we needed to be on the ‘front foot’ regarding failed trade management. With 15,000-20,000 allocations per day, we needed a clear picture of our pending trades,” explains Dos Santos. “With CSDR, it is important to have failed trade monitoring and cash penalties in the same solution.”

“SureVu helps firms stay in control and manage trade settlement along with high volumes of data associated with cash penalties, applying effective governance across the processes. Companies need a solution in place quickly, without major overheads in IT and operational staff. Man Group has noted the ease and speed with which our solution starts to add real benefits to the business,” said David Veal, Senior Executive at corfinancial. “Such efficiencies are critical when considering the operational pressures envisaged when T+1 goes live next year.”

For more information on the SureVu CSDR solution, contact corfinancial at info@corfinancialgroup.com.

Baillie Gifford goes live with SureVu for CSDR compliance

London, 5 December 2022 – corfinancial®, a leading provider of specialist software and services to the financial services sector, announces the implementation of its SDR (Settlement Discipline Regime) management software SureVu® at Edinburgh-based investment manager Baillie Gifford.

Baillie Gifford is unique in the UK in being a large-scale investment business that has remained an independent private partnership, who manage and advise £228bn (US$ 253bn) in specialist equity, fixed income and multi-asset portfolios for a global client base.

“SureVu is a very user-friendly system that clearly presents data on the problem trades that require attention. The ‘exceptions’ tab and the management dashboard is an immediate time-saver for us. The visibility and prioritisation that SureVu provides has improved efficiency for us, enabling us to proactively resolve unmatched trades before they fail,” says Daryl Salmon, Equity & Bond Operations Manager at Baillie Gifford. “Additionally, the shift towards a reduced settlement period is certainly driving operational process efficiencies across the investment management industry. By onboarding SureVu it is ultimately going to make our lives easier when T+1 comes into play,” explains Salmon.

“In an ever-tightening regulatory environment, it is even more critical to closely monitor trades through the settlement cycle,” says Bruce Hobson, CEO at corfinancial. “Following the introduction of the new CSDR regulation, it is imperative to have a timely and reliable solution that enables firms to effectively govern middle office processes.”

For more information on the SureVu solution, contact corfinancial at info@corfinancialgroup.com.

How have buy-side firms adapted to the Settlement Discipline Regime?

Penalty spot kick

How have buy-side firms adapted to the Settlement Discipline Regime and what are the operational challenges that remain? By David Veal, Senior Executive: Client Solutions, corfinancial®.  

The Settlement Discipline Regime is a new obligation stemming from the European Commission’s review of the Central Securities Depositories Regulation (CSDR), which came into force on 1 February 2022. These additional regulatory processes supplement the existing CSDR protocols and focus on enhanced controls and governance around trade settlement.

In this article we highlight anecdotal thoughts and feedback received from market participants and corfinancial clients who have been working with the proposed changes. Full details of this feedback can be found in this Discussion Paper.

Failed Trade Management and T+1 Lifecycle

Buy-side firms in Europe that trade in US instruments will soon have less time in which to allocate and fund stocks, resolve any settlement issues and comply with the CSDR’s new penalties regime.

Having access to a central source of executed trade data and being able to track transactions throughout the entire securities lifecycle is vital to facilitating settlement efficiencies. Clients want robust governance with which to minimise trade settlement failure. However, there are changes to operational processes and potentially regional coverage that need to be considered in future   environments that support global trading from Asia to Europe and the US, especially when a single middle office team manages this. Firms must work towards avoiding trade failure rather than managing this after the event. Having the right tools to achieve this in a near real-time environment is essential.

Cash Penalty Fees Management

The provision of prime broker or custodian statements to support the reconciliation of cash penalty fees is improving, but there is still a way to go. The sentiment we received was that some parties still lack the full infrastructure to manage the timely provision of cash penalty fee data, so some may be choosing to absorb cash penalty fee debits rather than passing them on (although penalty fee credits are being sent). The argument is that penalty fee amounts are often too small, and net/net are not worth passing on. However, this approach certainly goes against the essence of the SDR cash penalty objective.

Automating The Processes

Some feedback focused on the most effective trade records on which to base best practice controls and governance. It was suggested that some solutions base their primary trade position records on the market side of trades, whereas solutions like SureVu® centre on the buy-side view of executed trades. There are clear differences with how solutions in the space have been designed. It is uncertain how these different models will evolve in the lead up to T+1 and beyond.

The SureVu SDR solution from corfinancial was designed differently.

SureVu clients believe it is essential to manage post execution trade settlement positions from their own record of executed trades, not data assimilated by third parties.  

For a more detailed assessment of our investigations, please download our free Discussion Paper or contact us at info@corfinancialgroup.com and we will be happy to share our thoughts and details of how we help address the SDR challenges.

www.corfinancialgroup.com

corfinancial launches penalty fee management for failing trades under CSDR

SureVu helps buy-side firms manage failed trades under forthcoming changes to the Central Securities Depositories Regulation (CSDR)

London, January 19, 2022 – corfinancial®, a leading provider of specialist software and services to the financial services sector, announces the launch of SureVu® Penalty Fees Processing and Management. 

SureVu® helps buy-side firms manage failed trades under forthcoming changes to the Central Securities Depositories Regulation (CSDR), which requires trading venues and investment firms established in the EU to improve settlement discipline by 1 February 2022. These enhancements, known as the Settlement Discipline Regime (SDR), state that where a settlement failure occurs, depositories must impose cash penalties on failing participants.

SureVu supports complex processes associated with penalty fees management, with a set of management information dashboards that summarise data and priorities. SureVu reflects accumulating net fees, in multiple currencies throughout the penalty fee lifecycle. Furthermore, users can lodge and manage appeals against fees that are in dispute. Firms are adopting these new features to ensure they have a comprehensive solution and are ready to go live on 1 February 2022.

“Now that the European Commission has postponed the implementation of the Central Securities Depositories Regulation mandatory buy-in provisions following months of speculation, there are no further reasons to delay the deployment of a solution that supports failing trades. The postponement has created an opportunity for the industry to move forward and the time for action has come,” says Bruce Hobson, CEO at corfinancial. “A comprehensive solution like SureVu will ease the many additional operational burdens that are causing such industry-wide consternation. We suspect that these concerns essentially stem from the fact that many firms are still a long way away from having a tried and tested solution that is simple and quick to deploy.”

Prevention rather than cure Is best way to tackle trade settlement management

Trade Failure

Buy-side believes prevention rather than cure is best way to tackle trade settlement.

Many people are aware that the European Central Securities Depositories Regulation (CSDR) that introduces a Settlement Discipline Regime (SDR) has been delayed by another year to February 2022. The deferment, however, should not be seen as a reason to avoid introducing better controls and processes now. On the contrary, firms are recognising that preventing trade failures rather than managing them is best practice, irrespective of SDR being implemented.

SureVu - Trade Failure

When every failed trade will have a price tag

Failed Trades

The avoidance of failed trades is now business critical, not a nice-to-have, writes Paul Bowen, corfinancial.

Every failed trade will have a price tag from February 2021.

Although the Central Securities Depositories Regulation (the “CSDR”) came into effect on 17 September 2014, its operational impacts on buy and sell-side firms is just coming into focus. In particular it is the Settlement Discipline Regime (SDR) element of CSDR that will have the most significant impact on market participants.

The SDR reform stipulates that trading venues and investment firms must implement measures to prevent and address failures in the settlement process. Every failed trade will cost businesses. Where a settlement fail does occur, CSDs must impose cash penalties on failing participants. The basis of the penalty is determined by the number of business days beyond settlement date that a transaction remains unsettled. Over and above this, there will also be a mandatory buy-in process for failed trades and the recovery of the costs will be passed on to the defaulting party.

In other words, increased settlement discipline and the avoidance of failed trades is now business critical, not a nice-to-have.

Slipped through the net

One may ponder, when so much automation has been successfully introduced into middle and back office processes over the years, how it is that failed trades have slipped through the net? How have failed trades become the last bastion of non-automation?

It could be argued that current penalties are not significantly punitive or material to attract focus and investment in this process. With the introduction of the new penalty structure, however, non-compliance could result in significant monetary and reputational cost. In a sense, therefore, failed trades were not the highest priority; SDR will have a substantial impact as it formalises the settlement process and gives failures added significance.

Another factor is SWIFT messaging. This communication method has been available for many years yet has not been adopted in its entirety. The custodians instead have often provided failed trade reports, either through portals or daily spreadsheets. The problem here is that all those portals and spreadsheets are different, with the result that the buy- and sell-sides would assign multiple resources to manually process numerous failed trade reports and rationalise them as best they could. The custodians had little incentive to introduce standardisation, hence manual workarounds were commonplace.

Operational challenges

In operational terms, there are several obstacles that the industry must overcome in order to effectively deal with SDR.

Firstly, the industry must minimise the cost impact of buy-ins. Trade failures will often occur in illiquid markets where there is a shortage of stock. If a firm is receiving buy-ins in illiquid markets, potentially there could be some large price differentials at a ‘Buy-in-Auction’ at the end of the day. In these circumstances, the premiums levied by empowered sellers are generally significant, leaving the counterparty at fault and with a painful variance.

Secondly, firms must reduce the manual processing stemming from SDR. This labour-intensive administration is likely to include extensive effort associated with buy-ins. It’s not just a case of sending an email; asset managers, for instance, may need to start cancelling trades, rebooking trades, pursuing the brokers for all the fines and so on. The introduction of SDR will mean that businesses will have to deal with far more manual workarounds.

Thirdly, operational teams must prove that they are in control of the settlement process. These teams will now need to report in more detail to senior management on unsettled trades and counterparty exposure. One of the key observations from the Lehman collapse was the lack of information regarding consolidated counterparty exposures. The new SDR regime, while imposing penalties, has the benefit of reducing settlement exposure and cash management for all parties involved in the trade cycle.

In summary, the most significant changes being made through SDR is fining firms, introducing rigour around buy-ins and reporting the worst offenders. All firms need to proactively prevent trade failures, understand their exposure to unsettled trades and protect their company’s reputation. SDR means asset managers and brokers must move nearer to real-time monitoring, compelling them to transition up the settlement cycle and adopt a pre-settlement mentality.

Just looking at trade fails is not solving the problem.

Paul Bowen
Senior Executive – Operations corfinancial
info@corfinancialgroup.com

Post trade transparency: shining a light into dark corners

Post trade transparency

An effective post-trade programme is now business critical, writes David Veal, Senior Executive - Client Solutions at corfinancial.

Although well over ten years ago, many people still vividly remember the immediate chaos during the financial crisis. Firms were scrambling to understand counterparty exposures and settlement risk, along with a key requirement to know the exact state of asset and cash positions. Executed transactions sitting between trade date and settlement date fell into deep voids where the status, even post-settlement date, was not absolutely clear. It took many firms days, sometimes even weeks, to piece together a conclusive picture of the actual situation.

With multiple industry utilities, a plethora of systems and with transactions recorded in multiple mediums (including paper tickets ‘enhanced’ with coloured marker pens, faxes and spreadsheets) it swiftly became clear that such an environment only works when the outside world cooperates. Post-crisis, sanctions were introduced to impose responsibilities and liabilities upon firms, with the aim of firms having more control of transaction data. Equally, lucidity in post-trade processes supports the maintenance of IBOR platforms that also require near real-time position data. Can a company therefore survive without a transparent post-trade system? The regulators would say ‘absolutely not’.

spotlight

The upcoming enhancements to the Central Securities Depositories Regulation (CSDR), which must be implemented by February 2021, pushes the responsibilities even further. In particular, the Settlement Discipline Regime (SDR) within CSDR means that where a settlement fail does occur, CSDs must impose cash penalties on failing participants, as well as compulsory buy-ins after a short time. The impact of this change will only add to reputational damage for parties that are unable to apply effective measures and controls.

I would argue that a better level of post-trade transparency brings challenges but also opportunities for the industry as a whole. Depending on the definition of transparency, additional controls and processes improve the ability to monitor the settlement status of a transaction and reduce exposure to settlement risk.

It’s time to shine a light into the dark corners.