April 13, 2022

Vanessa Countryman
Secretary, Securities and Exchange Commission
U.S. Securities and Exchange Commission
100 F Street NE
Washington, DC, 20549-1090

Re: File No. S7-05-22: Shortening the Securities Transaction Settlement Cycle

Dear Ms. Countryman,

On February 9, 2022, the Securities and Exchange Commission (“SEC” or “Commission”) proposed to adopt rules and rule amendments to shorten the standard settlement cycle for most broker-dealer transactions from two business days after the trade date (“T+2”) to one business day after the trade date (“T+1”) (the “Proposal”).1 The Commission also requested comments on a number of aspects of its proposed rules and rule amendments, as well as on considerations relating to shortening the settlement standard settlement cycle to the trade date (“T+0”).

The Securities Industry and Financial Markets Association (“SIFMA”) and the SIFMA Asset Management Group (“AMG”) (together referred to in this letter as “SIFMA”) appreciates the opportunity to provide comments on the Proposal.2 Like many other industry participants and regulators alike, SIFMA, along with ICI and DTCC, played a leading role in transitioning the industry from T+3 to T+2 in 2017 and are again playing a leading role in the transition to T+1. SIFMA recognizes the benefits of shortening the

 

1 See Shortening the Securities Transaction Settlement Cycle, Exchange Act Release No. 94196 (Feb. 9, 2022).
2 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). SIFMA AMG brings the asset management community together to provide views on policy matters and to create industry best practices. SIFMA AMG’s members represent U.S. and multinational asset management firms whose combined global assets under management exceed $45 trillion. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds. For more information, visit http://www.sifma.org/amg.