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’.
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.