存托信托 & 清算 Corporation (“存”) plans to implement structural changes to settlement processing at 存托信托 Company (“直接转矩”) for money market instruments (“MMI”). 这些增强功能, 须经监管部门批准, are referenced in two 存 white papers published in December 2012: “A Roadmap for Promoting Intraday 和解终结 in U.S. Markets” and “Reducing Risk and Enhancing Intraday Finality in the 结算 of Money Market Instruments.” This service description provides additional detail and an updated timeline regarding the proposed MMI settlement processing enhancements.
美国的mmi.S. represent more than 50% of 直接转矩’s total settlement value (and less than 5% of the total transactions processed). 尽管mmi在美国.S. have experienced some market contraction in the last five years, they remain attractive financial instruments to 发行人 and investors. 直接转矩 continues to reduce credit and liquidity risk in this market. 直接转矩 also seeks to adhere to the Principles for Financial Market Infrastructures (the “PFMI Principles”) of the Committee on Payment and 结算 Systems and the Technical Committee of the 国际 Organization of Securities Commissions (“CPSS-IOSCO”). 特别是, PFMI原理8, 和解终结, recommends that a Financial Market Infrastructure should promote final settlement intraday or in real time. To better satisfy this principle, 直接转矩 seeks to modify the current MMI process that allows an Issuing & Paying Agent (“IPA”) to issue “refusal to pay” and trigger a reversal of MMI deliveries prior to settlement.
The MMI settlement process at 直接转矩 has facilitated the growth of the MMI market over the years by providing substantial settlement efficiency. 但是，IPA可以在下午3点前通知直接转矩.m. EST of a refusal to pay (“RTP”) with respect to an issuer acronym1. The RTP notice triggers a reversal of transactions associated with that issuer’s MMI acronym in the 直接转矩 settlement system. These reversals may create additional risk exposure to 直接转矩 and its Participants but that exposure is currently offset by 直接转矩 controls to protect settlement from two issuer failures. 在下一个发展阶段, 直接转矩将寻求消除逆转和, 同时, to eliminate the offsetting Largest Provisional Net Credit Control, to improve intraday settlement finality and reduce credit and liquidity risk as further described in this service description.
In 2012, MMI蓝天工作组, a joint project of 存 and The Securities Industry and Financial Markets Association (SIFMA), developed a model that would eliminate intraday reversals of MMI transactions in the 直接转矩 system.
The proposed MMI 结算 model will effect changes to 直接转矩’s RTP procedures and to the current market practices for in- vestors, 发行人, 托管人, 配售代理、经销商和帕斯. These changes will allow transactions to be processed intraday for end-of-day net funds settlement, without the risk of reversal prior to settlement.
The model will depend on achieving certainty of funding by the issuer to the IPA and by the IPA to 直接转矩 and/or the IPA prior to 直接转矩 processing presentments and issuances of an acronym of the issuer. 帕斯 will be asked to forego the option for a re- fusal to pay if they are satisfied that funding will be sufficient based on receipt of issuer funds and/or any decision they may make to extend credit on behalf of the issuer, subject to satisfaction of their 直接转矩 risk management controls, 如果和何时
直接转矩 is able to confirm that all counterparties to the IPA on that day and with respect to the acronym, have satisfied risk management controls for the further processing of deliveries of the acronym. 当这些条件得到确认，直接转矩
will process delivery versus payment (“DVP”) maturity presentments and issuances of the acronym as further set out in procedures specified. New and/or revised Rules and Procedures of 直接转矩, 经监管机构批准, will set forth the terms and conditions for this new process.
This change will optimize the netting and offset of maturity presentments, income presentments and reorganization payments for MMI’. 帕斯 will retain the ability to instruct 直接转矩 of an RTP in the event of an issuer insolvency. 拟议的MMI办法将:
- Mitigate the credit and liquidity risks to 直接转矩, 帕斯, Custodians and Dealers associated with MMI pre-settlement reversals.
- Maintain the current levels of intraday settlement throughput and participant funding requirements.
- Reduce risk control blockage within the system by no longer withholding the two Largest Provisional Net Credits (“LPNC2”). Currently, 直接转矩 holds an average of $150 billion of LPNC daily in the system across all participants.
- Leverage existing infrastructure and technology to minimize the changes necessary to participant’s procedures or systems.
- Increase transparency in the system for all stakeholders with regards to issuer funding, 包括帕斯, 投资者及其保管人.
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