Timing Matters: Statement on Shortening the Settlement Cycle

Thank you, Mr. Chair. And thank you to the staff in the Divisions of Trading and Markets, Economic and Risk Analysis, and Investment Management, and the Office of the General Counsel for your hard work on this rulemaking. I enjoyed our interactions throughout the process and appreciate your work on this important project.

I support the plan to move to T+1, but do not support the proposed timeline for making this change. Shortening the settlement cycle is a way to remove some risk from our markets. Mandating that the change occur in May 2024, however, could pose risks of its own by forcing the transition before market participants are ready. I propose instead a September 3, 2024 implementation date. Let me explain why:

• Although preferable to the proposed March 31, 2024 implementation date, the May 28, 2024 date is still too early. Shortening the settlement cycle by one business day is a big change with implications all across the market. We cannot afford a cavalier approach.
   
• Many commenters called for a September 3, 2024 date to ensure that the transition would happen with minimal disruption to the markets.
   
• Tuesday, September 3, 2024 is the first business day after the 3-day Labor Day weekend, and Canada, the only jurisdiction currently planning on moving with us to T+1, shares this 3-day weekend. The transition from T+3 to T+2 occurred successfully over Labor Day weekend in 2017.
   
• This later date would give other foreign market participants the time to work out some of the challenges they will face from our transition to a shorter settlement cycle than they have in their markets.
   
• The additional three months will allow more time for firm-specific and coordinated, industry-wide testing, which will make a smoother transition more likely.
   
• The transition from T+2 to T+1 is likely to present numerous operational challenges—some of them more difficult than in the last transition—related to, among other things, pre- and post-trade processes, securities lending, foreign exchange transactions, and processing corporate actions.
   
• The transition is happening at the same time the market is processing many other regulatory changes.

I do not have any questions for the staff, but do want to make one final plea to Chair Gensler. Why not adopt a September 3, 2024 compliance date? I will vote for the rule if you make this change.