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Same Day Affirmation

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Title: Same Day Affirmation


1
Same Day Affirmation
Issue Summary for Consideration by the AMF
Membership July 16, 2009
Lee Cutrone John Burchenal
2
Background 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

3
Canada vs. US SDA T 1 Comparison - Before
(2006) After (08 09) SDA Mandated
Canada Surpasses US Affirmation Rates
4
Background 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

5
Goal 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

6
Key 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

7
The 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
8
How 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

9
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