The Office of the Comptroller of the Currency ("OCC") and the FDIC (collectively, the "agencies") filed a proposed rule change that would shorten the standard settlement cycle from T+3 to T+2 for securities sold and purchased by banks. The agencies issued the proposal in accordance with a securities industry-wide shift to the shortened settlement cycle. Alternatively, the proposal also contemplates "implementing the two-business-day settlement requirement by cross-reference to the standard settlement cycle provided under SEC Rule 15c6-1(a)."
The changes were discussed in previous OCC and FDIC bulletins that were issued on June 9, 2017 and July 26, 2017, respectively. Additionally, the agencies requested public comments, which must be submitted within 30 days of the publication of the proposal in the Federal Register.
Commentary / Patrick A. Calves
The FDIC and OCC are only now proposing rule amendments to transition OCC- and FDIC-supervised institutions to a T+2 settlement cycle. Regardless, firms should already be aware that the agencies issued guidance for OCC- and FDIC-supervised institutions to adhere to relevant industry standards and applicable securities and SRO rules implementing the T+2 settlement cycle as of September 5, 2017.
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