ACATS Industry Best Practices

Transcription

1 ACATS Industry Best Practices ACATS Shortened Cycle 10/30/2017 Version 1.0 Contributors: SIFMA CAT Division ACATS Shortened Cycle Best Practices Working Group This Best Practice document outlines suggested usage in conjunction with ACATS Shortened Cycle initiative. See Important Notice a8340.

2 Disclaimer: This Best Practice document is a collaborative effort of the industry firms and participants listed in this document. The best practices suggested are the views and opinions of the contributors and not necessarily DTCC. This Best Practice document is not a legal document and the statements contained herein do not set forth any legal obligations of DTCC, National Securities Clearing Corporation ( NSCC ) or any other DTCC subsidiary, nor do any statements contained herein set forth any legal rights of any NSCC user. All such legal rights and obligations are set forth in NSCC s Rules & Procedures and each user s Membership Agreement with NSCC (together, the Legal Documents ). The user is referred to the Legal Documents for a statement of all legal obligations. In general, unless the context clearly indicates otherwise, terms used in this Best Practice document have the same meanings as in the Legal Documents. 1

3 Contents Contributing Members Cycle Time and Input Deadline Best Practices Acceleration Best Pracitces

4 Contributing Members The following individuals contributed to one or more sections to this ACATs Shortened Cycle Best Practices document. Firm BETA Broadridge Broadridge Capital One Cetera Etrade Etrade First Clearing First Clearing Goldman Sachs Interactive Brokers LPL Merrill Lynch Morgan Stanley Pershing Pershing Pershing RBC Robert Baird Robert Baird Stifel Stifel Talisys TD Ameritrade TD Ameritrade TD Ameritrade Participant(s) Vamsi Krishna Judy Luo Sandy Prus John Goodrich Tim Elhard Cindy Little Chris Buman Heidi Heister Josh Dean Kody Townsend Katie Stephan Robert DeCaro Blake Rosevear Jason Lamparter Pattie Schuchman Mark Storey Mark Hall Jason Gutierrez William Kutters Ed Leddy Dianne Tilley Keith Troller Lenny Wilson Helene Garcia Suzie Steger Karl Fehn Gary Kutz Kristie DeRoide Mickenzie Carlson Anne Klenke Nicole Westcott Merna Thompson Georin LaGrant Courtney Hess Cory Church Jan Phelan Bree Lynn 3

5 Vanguard Vanguard Vanguard Vanguard Wells Fargo Maggie Dumas Ryan Drew Ryan Malenke Kelly Cornwell Richard Stiebel 4

6 1. Cycle Time and Input Deadline Best Practices Action Best Practice TI Adds Submit TI adds on every available cycle (1-10) Asset Input Acceleration Deliverer submits assets as soon as possible (same day) for accounts that do not have management fees or trading activity If accounts need to go through overnight batch process, load assets on first available cycle If no adjustments needed by delivering firm, day 1 validation should occur If adjustments are needed on day 2, validate by cycle 4 for a buffer of cutoff. Sooner if possible Delivering firm needs to review transfer request as soon as received in order to reject if needed. Load AT records on first available cycle for that particular accounts scenario. (ie, cash only, management fees, etc) Upon receiving AT records, receiver should accelerate next available cycle Submit FR records same cycle of acceleration Day 1 AT record If delivering firm submits AT on Day 1, receiving firm should accelerate transfer and submit FR records on Day 1 by cycle 11. Rejects/Adjustments FR Records General Once AT record is received, receiving firm to take actions to reject, adjust on next possible cycle Send FR records on every cycle and accelerate so that 018 records can be transmitted earlier in the day Not holding all work for particular cycles will spread work evenly throughout cycles to lessen impact on either side. 5

7 2. Acceleration Best Practices Receiver Actions: Accelerate all cases possible and send the Fund Registration (FR) in the same cycle acceleration the acceleration is executed. This will not only settle the transfer sooner but intended to help reduce fails and clean ups. Accelerate as soon as possible on Review Day 1. It will be best effort by the receiver to attempt to settle the transfer sooner. If Day 1 accelerate is not possible, accelerate on Day 2 if there are mutual funds in the transfer. In this case, the acceleration will not remove a review day, but it will send FR records to the fund companies earlier in the day. For reclaims: Give advisors until the end of the day (before cut off) to reject the claim with a valid reason. If no reject is received, validate and accelerate by the end of day one cutoff (4pm et). Deliverer Actions: Before posting the asset list, make sure all adjustments were made. Try not to post asset list until the account is correct and post on Request Day 1, when possible. If it is not possible to post assets on all accounts on Day 1, attempt to post accounts that can be validated. Limit the amount of adjustments you need to make to avoid looping the transfer and delaying for the client. Firms will need to do this based on more the fact that there will be more restrictions due to new receiver acceleration rules. Posting assets Request Day 1 will mean not allowing rescinds. Firms should attempt to promote a new incoming transfer if the client changes their mind. Charge management fees up front opposed to charge when client s leave. Give rebate opposed to claim. 6