Title: Same Day Affirmation
1Same Day Affirmation
Issue Summary for Consideration by the AMF
Membership July 16, 2009
Lee Cutrone John Burchenal
2Background on SDA Initiative
- SDA first suggested in US after failure of T1
settlement initiative - SDA recognized as a critical building Block for
shorter settlement efficiency - SDA was a key question raised in SEC Concept
release in 2004 - Embraced by Canadian Market NI 24-101
- Canadas SDA rate now exceeds US rate
- SDA momentum building in Europe as a single
Pan-European CS model begins to takes shape - Oxera Research helps quantify the value of SDA,
i.e., - Automation SDA leads to reduced operational
risk improved settlement efficiency - Automation SDA are enablers to more efficient
and volume insensitive processing - Efficiency gains translate into lower transaction
costs for end-investors - SDA is estimated to save the European market 200
million Euro/year - Current financial crisis presents a window of
Opportunity for an SDA mandate - SDA mitigates risk
3Canada vs. US SDA T 1 Comparison - Before
(2006) After (08 09) SDA Mandated
Canada Surpasses US Affirmation Rates
4Background on SDA Initiative, Contd
- SDA first suggested in US after failure of T1
settlement initiative - SDA recognized as a critical building Block for
shorter settlement efficiency - SDA was a key question raised in SEC Concept
release in 2004 - Embraced by Canadian Market NI 24-101
- Canadas SDA rate now exceeds US rate
- SDA momentum building in Europe as a single
Pan-European CS model begins to takes shape - Oxera Research helps quantify the value of SDA,
i.e., - Automation SDA leads to reduced operational
risk improved settlement efficiency - Automation SDA are enablers to more efficient
and volume insensitive processing - Efficiency gains translate into lower transaction
costs for end-investors - SDA is estimated to save the European market 200
million Euro/year - Current financial crisis presents a window of
Opportunity for an SDA mandate - SDA mitigates risk
5Goal of SDA Initiative
- Educate Legislators and Regulators on the Same
Day Affirmation (SDA) value proposition - Support SIFMAs broader ongoing effort to partner
with Regulators to drive meaningful and realistic
regulatory change - Gain the support of key Legislators and
Regulators for the creation of a Same Day
Affirmation regulation across asset classes. - A critical element in gaining such support is an
endorsement from SIFMAs (Broker) Operations
Committee and the AMF
6Key Messages to Legislators/Regulators
- Mind the Gap
- Regulators should ensure that the ability to
process a transaction in any asset class keeps
pace with the ability to trade that asset class - Dont ignore the middle and back office
- Where practical, there must be consistency of
regulation across asset classes (particularly in
the Middle Office confirm/affirm area) - Same Day Affirmation
- The faster trade details are agreed upon, the
lower the Operational Risk and Settlement Risk - In order to fully mitigate this risk, SDA must be
universally adopted - Universal adoption of SDA requires regulation
it will not happen voluntarily - Electronic trade processing (A Gateway to SDA)
also promotes better audit trails, lowers risk of
fraud increases investor confidence
7The SDA Value Proposition
- Buy-Side
- Fewer Fails/Reclaims/Claims
- Reduced operational risk
- Reduced market error risk
- Lower costs for clients
- Higher Rates of STP
- Aligned with global regulatory reform
- Potentially forestall regulatory push to reduce
settlement cycles - Increases capacity to trade and process
- Sales tool for new business
- Custodian Banks
- Fewer Fails/Reclaims/Claims
- Lower FTE costs
- Leverage investment in existing technology
- Higher customer satisfaction
- Reduced operational burden
The SDA initiative is an easy win that shows
regulators and the public how the Securities
Industry can come together to drive substantive
positive changes to lower industry costs, reduce
systemic risks and increase electronic processing
8How the AMF Can Help
- Endorsement of an SDA regulatory mandate from the
AMF Steering Committee and general membership - Add SDA to the AMFs ongoing agenda
- Identify actions to be taken by the AMF to
promote an SDA Regulation - Together with the SIFMA (Broker) Operations
committee, provide assistance in educating the
SIFMA Government Relations staff on role of
Middle Office value of SDA as a risk mitigation
tool - Include SDA in SIFMAs regulatory agenda
- Participate in meetings with Legislators and
Regulators, as needed
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