
T+1 Program
Project Background
On December 01, 2021, The Depository Trust & Clearing Corporation (DTCC) announced an industry-wide initiative partnered with Securities Industry and Financial Markets Association (SIFMA) and the Investment Company Institute (ICI), to accelerate the settlement cycle from trade date plus 2 days (T+2) to trade date plus one day (T+1). This is in an effort to reduce risk, strengthen and modernize securities settlement in the U.S. financial markets. At the same time, the Canadian counterpart of DTCC, the Canadian Depository for Securities (CDS) will also be migrating the settlement cycle to T+1 as to ensure the US and Canadian markets remain in synch.
Current technology and operational infrastructure at CIBC enables teams to input high volumes of trades daily in the US and Canadian markets on a T+2 cycle. To support the T+1 cycle, all impacted processes and systems are thoroughly reviewed to identify and implement any necessary changes, automation opportunities and elimination of any redundancies.
T+1 Benefits
T+1 settlements reduce the risk associated with security settlement by minimizing both outstanding settlements and their associated replacement costs. In addition, this change will mitigate operational and systemic risk by reducing exposure between counterparties and central clearinghouses.
This change will align the North American markets to the Asian markets which have already moved to T+1 settlement cycle.
Even at T+2, one of the last remaining exposures in the settlement system is time. Time increases the risk that an unpredictable event could significantly affect the transfer of cash or ownership of securities from the point of trade execution through settlement. T+1 will significantly reduce the marginal relief, risk and volatility.
Accelerating the settlement cycle reduces the number of unsettled positions in a member’s portfolio.
Reviewing and streamlining current operational processes through automation or by removing redundancies in each operational area enables operational efficiencies that are scalable and reduce risk.
T+1 Regulatory and Governing Bodies
- US Securities & Exchange Commission (SEC)
- SIFMA
- DTCC
- ICI
- Canadian Capital Markets Association (CCMA)
- CDS
T+1 Implementation Date(s)
USA: May 28th, 2024
Canada: May 27th, 2024
USA and Canadian T+1 transition schedule
What actions has CIBC undertaken
A comprehensive Business Requirement gathering exercise was undertaken in 2022 by the CIBC to ensure all Lines of Business (LOBs) had an opportunity to identify areas of change required to meet T+1 timelines. LOBs participated in providing input to the requirements as well as jointly collaborating in operational review sessions. A consolidated Business Requirement Document was created which identified all the people, process, technology and vendor changes required to support T+1.
CIBC technology, operations and vendor partners executed thorough development and testing cycles to implement the changes and enhance any underlying processes. An extensive testing cycle including Unit Testing, System Integration Testing, Regression and User Acceptance Testing was conducted to ensure the new changes worked as expected without impacting any downstream or upstream systems or processes.
CIBC is participating in T+1 Industry Testing in both US and Canada to test the T+1 changes with the following industry partners within USA and Canada to test the end-to-end trade booking, clearing ands settlement process in the new T+1 environment:
USA:
- Depository Trust and Clearing Corporation (DTCC) for Equities and Fixed Income
- National Securities Clearing Corporation (NSCC) for Fixed Income
- Options Clearing Corporation (OCC) for futures and options
Canada:
- The Canadian Depository for Securities (CDS) for Equities and Fixed Income
- FundServ for Mutual Funds
- Canadian Derivatives Clearing Corporation (CDCC) for OTC and Derivatives
All CIBC vendor partners are also participating in the industry testing. A comprehensive Industry Test Strategy and Test Plan has been prepared and socialized with our operations, technology and vendor partners in readiness for Industry Testing.
Industry Testing in Canada started on January 12th, 2024. The testing comprises of 4 testing cycles throughout the months of January through April 2024; this includes 2 weeks of active testing and 2 weeks for application reset.
Industry Testing in the US commenced in August 2023 and will continue through May 2024.
CIBC is participating in Industry Testing as per the below schedule:
What Is Changing?
USA (DTCC/NSCC/FED):
- All Trade Order Entry & Ticketing applications must update (where necessary) their default settlement period to T+1.
- Affirmation cut-off time is revised from the current 11:00 AM ET on SD-1 to 9:00PM ET on trade date.
- Authorizations and Exemptions cut-off time is revised from the current 6:30 p.m. ET on SD-1 to 10:45PM ET on trade date.
- Disaffirmed trades occurring between 9:00PM ET on T to 1:30PM ET on T+1 would result in NSCC generating reversal transaction for same day settlement .
- Disaffirmations between 1:31 PM ET on T+1 to 5:00 PM ET on T+ 1 would result in NSCC generating reversal transactions for the next settlement day.
- Securities Lending Recall cut off is revised from the current 3:00 PM ET on T+1 to 9:30 PM ET on trade date.
- For Distributions, the ex-date will be record date.
- For Voluntary Offers, Cover/ Protect period will be the expiration date plus 1 day.
Detailed DTCC/NSCC proposed changes can be found here.
Canada (CDS/CDCC/FundServ):
- All Trade Order Entry & Ticketing applications must update (where necessary) their default settlement period to T+1.
- Trades will be reported by exchanges to CDS on an hourly basis.
- Retail ETF Secondary Market is moving to T+1 settlement aligning to other Exchange trades.
- For Distribution type Corporate Actions, the ex-date will move to the record date.
- For Voluntary Offers with Letter of Guarantee (LOG) Corporate Actions, the Cover/Protect period will be the expiration date plus 1 day.
- The exercise and assignment of options will move to T+1 to align with the settlement of the underlying securities.
- Regulators have not mandated the move of Mutual Funds settlement to T+1 and have left the decision to individual Fund companies. As such, Fundserv will support both T+2 and T+1 settlements for Mutual Funds.
- CIBC will be moving its proprietary Mutual Funds’ settlement cycle to T+1.
CDS current and future state document can be found at here.
What Is Not Changing?
- Batch schedules of CIBC vendors.
Client/Custodian Accountabilities
All clients/custodians must review their internal procedures and systems, and make all necessary updates, to ensure strict adherence to the revised T+1 timelines outlined below:
- All trade instructions must switch to T+1 from May 28th 2024 onwards
- All trade allocations must be completed by 6:30 PM ET (end of the day on) Trade Date.
- Clients and custodians using CIBC technology systems (ETM, SS&C Net etc.) for allocations must send allocation files to CIBC systems before 6:30 PM on Trade Date.
- Clients and custodians providing allocation information via alternate channels (emails, chat etc.) must provide allocation information to CIBC by 6:30 PM ET on Trade Date.
- All trade affirmation and confirmation must be completed by 6:30 PM ET (end of the day on) on Trade Date by Custodians.
- All trade files must be received by CIBC by 6:30 PM on Trade Date.
- Clients should contact the CIBC Securities Lending desk for hard to borrow securities in advance of executing short sales.
- All trade allocation instructions must switch to T+1 from May 27th 2024 onwards
- All trade allocations must be completed by 6:30 PM ET (end of the day on) on Trade Date.
- All trade files must be received by CIBC by 6:30 PM ET on Trade Date.
- All custodians must input the matching leg of the trade in CDS before 3:59 AM on Trade Date + 1 to ensure adherence to NI 24 101, trades are matched and settlement goes through CDS Batch Net Settlement Cycle.
- Clients should contact the CIBC Securities Lending/Global Credit Financing desk for hard to borrow securities in advance of executing short sales.
Frequently Asked Questions (FAQs)
Need additional information? Check out our frequently asked questions here.