For trading desks, the new rules will result in a range of operational and regulatory shifts. Clearing obligations will become stricter, with enhanced oversight of margin requirements and risk management processes. 

Despite these new potentially arduous compliance pressures, trading desks are also likely to benefit from reduced counterparty risk and improved market confidence thanks to the changes. Day-to-day trading activities, liquidity, and risk management on fixed income desks are all things that could be impacted by these new rule changes. As with any regulatory change or evolution, industry participants will need to adapt their strategies and systems to navigate the shifting fixed income landscape.

“As numerous policymakers, academics, and market participants have recognised, greater central clearing of US Treasury transactions would improve the safety, soundness, and efficiency of the US Treasury market, promote competition, enhance transparency, and facilitate all-to-all trading,” notes Laura Klimpel, managing director, head of fixed income and financing solutions at The Depository Trust and Clearing Corporation (DTCC).  

“Increased central clearing can also reduce clearing costs and credit risk by incentivising direct participants to submit more balanced portfolios that have a lower risk profile and thus carry lower clearing fund and liquidity facility requirements.”

In addition, with the introduction of balance sheet netting and favourable regulatory capital treatment, central clearing could result in an increase of dealers’ capacity to transact and potentially improve some market liquidity constraints.

The SEC’s new rule changes are primarily aimed at improving market stability and minimising systemic risks. They aim to strengthen the security of the US Treasury market by requiring central clearing for eligible instruments such as repos, reverse repos, inter-dealer broker transactions, and other cash transactions. The objective of these rules is to reduce counterparty risk, curb contagion, and enhance market transparency.

“The lessons learnt from past financial stress conditions and crises, particularly those involving non-bank market participants, have driven these changes. One counterparty defaulting could pass risk on to another party, this in turn could have a cascading effect on liquidity across the market,” highlights Edoardo Pacenti, head of trading tools for fixed income at ION. 

“In addition, currently, the Fixed Income Clearing Corporation (FICC) is indirectly exposed if one of its members makes a trade with a non-member and subsequently defaults on the transaction. With these changes, there will be a dramatic increase in the amount of daily US Treasury clearing activity processed through the FICC.”

As it currently stands, two compliance dates exist which firms should be most conscious of. If no extensions are actioned, 31 December 2025 marks the beginning of the mandate for cash transactions, while on 30 June 2026 the repo transaction mandate will commence. 

Institutions should also note that the SEC has implemented a regulatory change to redefine the term ‘dealer,’ aimed at increasing oversight of proprietary trading firms (PTFs), which are key liquidity providers in the US Treasury market. 

PTFs, which trade using their own capital rather than on behalf of clients, will now be required to register as dealers with both the SEC and FINRA. Alternatively, if PTFs prefer not to register as dealers, they must set up a sponsored member arrangement.

“While this is a significant change for PTFs, they already have experience delivering similar large-scale projects following the change to the T+1 settlement in May 2024 which can be applied to the upcoming dealer redefinition and central clearing changes,” adds Pacenti. 

Another key consideration for institutions is the increase in clearing volume that will occur as a result of these rule changes. 

“Our understanding is that seven trillion or so is the daily average volume that is traded in these markets. Based on our engagement with market participants, we’re expecting that it’s going to be an increase in demand for capital – maybe a 20-30% increase,” notes Kevin Khokhar, head of investment funding at T. Rowe Price. “Firms will have to look at the infrastructure, systems and processes, to see if they can absorb this large market structure regulatory change.”

Khokhar continues to highlight that margin and portfolio funding impact should be another key focus for institutions as they adapt to these rules. When considering bilateral transactions, which typically occur in the treasury trading space, when shifting into a cleared model, there will be increased rules and regulations around the type of assets you can pose for margining, to optimise and normalise FI trading books.

“Being able to understand the impact of your liquidity profile in your trading portfolios will be one of the key factors, something that the market needs to consider as you get into clearing market structures,” he adds. 

Competition

The new fixed income clearing rules could potentially have a significant impact on competition in the bond markets, particularly for new entrants. By mandating central clearing for a wider range of transactions and increasing oversight on market participants, the new rules could raise the operational and compliance costs for smaller firms and new market entrants. Despite this potentially leading to barriers to entry, it could also enable a more level playing field by reducing counterparty risk and increasing transparency. 

“Transparency is always good for competition, right? It narrows bid ask spreads. It makes things easier to trade and encourages more to be involved because there’s more information,” notes Brian Rubin, head of US fixed income trading at T. Rowe Price. 

“The new rules should make markets more liquid. We’re always looking for greater transparency.”

Established firms, which have more robust infrastructure and regulatory expertise, may find it easier to adapt to these changes, while newer players will need to navigate increased regulatory expectations to compete effectively.

The new rules also have the potential to shift the ways in which transparency exists within the fixed income landscape. Particularly, with a shift from transparency solely being held by broker dealers, to the buy-side. 

“As you move from more of a bilateral transaction-based market to more of a cleared based model, market participants including buy-side participants will potentially see more transparency into what the transactions levels look like, what overall trading volume trends are, and also some of the post-trade aspects that impact FI Treasury and repo markets,” emphasises Khokhar. “That gives market end users more transparency on the buy-side to see what potentially may be happening from the dealer/broker community.”

Impacts on trading

Central clearing is expected to alleviate counterparty credit limits through improved risk management and transparency offered by central counterparties (CCPs) and shift previously uncollateralised bilateral agreements to CCPs. This transition should notably reduce the risks of counterparty defaults and fire sales.

“This could improve market liquidity by removing existing trading restrictions and mitigating counterparty and bilateral trading risk. This will be particularly beneficial in times of stress, as these factors will ensure that dealers don’t withdraw liquidity,” notes Pacenti.

“At the same time, the cost of central clearing and risk management activities will likely increase the overall costs of transactions for participants who don’t currently centrally clear transactions. These costs will be passed on from FICC members to non-FICC members.”

Likewise, highly leveraged or low-margin trading strategies, such as basis and relative value trades, may become less viable due to these proposals. As a result, fewer PTFs may engage in these trades, causing a decline in liquidity for the underlying asset classes, like US Treasury actives. This could offset some of the anticipated benefits of the new rules.

Anticipating the changes 

DTCC’s Klimpel tells The TRADE that as a covered clearing agency, FICC has been taking the necessary steps under the SEC rule requirements to prepare for this significant market structure initiative. 

“FICC offers a variety of both direct and indirect membership models for buy- and sell-side market participants. As we prepare for the upcoming mandate, FICC continues to work with the industry to educate firms, assess offerings, and ensure readiness,” she states.  

“Our guidance to market participants is to begin preparations now by evaluating direct and indirect access models to determine the best approach for their organisations and clients to achieve successful implementation by the SEC compliance dates.”

Another strategy being developed in response to these changes is increased investment in technology, primarily to offset the costs of central clearing. This involves investing in scalable transaction reporting systems, which reduce reliance on manual processes, lower the risk of errors, and decrease the marginal cost of each transaction.

“Overall, investing in technology will make it more economical for firms to comply with the new rule changes,” adds Pacenti. 

With rule changes such as these, the impacts will be felt across institutions, spanning across different areas of their operational structure. Having open and more transparent communication among the different strands of a business will have a positive impact on efforts to make compliance successful.

“We have to understand the impact from a fixed income trading perspective, but also post-trade services and capabilities. We need to assess the impact to operations, risk, and other business units as well as our external providers for sourcing portfolio liquidity,” argues Khokhar. 

“Another aspect is having operational strategies, where market participants should implement a governance structure across all potential impacted business units to fully understand the impact to your front-to-back trading platform.” 

Despite some hopes that the implementation of these fixed income clearing rules will be delayed, institutions should act as though the set dates are expected to go ahead as planned to ensure adequate adjustments are made to ensure successful compliance. Clearing obligations will undoubtedly become more prominent, requiring an increase in viewpoints of margin requirements and risk management processes. As with any key regulatory change, the sooner institutions can prepare, the better the outcome will be for the industry at large. 

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The updated risk tools seek to support firms as they prepare for the expansion of US Treasury clearing in 2025 and 2026.

Developed for the Fixed Income Clearing Corporation’s (FICC) Government Securities Division (GSD), the calculator functionality offers users estimated calculations of potential cross-margining reductions at FICC as well as other enhancements.

DTCC added that by providing users with access to new tools, firms can enhance their understanding of GSD’s risk management and margin requirements capabilities.

“FICC is the leading provider of trade comparison, netting and settlement for US Treasury transactions, and we continue to innovate and provide increased transparency to meet the needs of the industry as the markets evolve,” said Laura Klimpel, managing director, head of DTCC fixed income and financing solutions.

“FICC is laser-focused on providing the highest level of service and value to our diverse set of clients.”

The cross-margining VaR calculator allows users to estimate the potential cross-margin reduction on a sample portfolio containing GSD cash positions and CME Group futures which are based solely on FICC’s cross-margining methodology.

Market participants are able to determine whether they can take advantage of greater margin savings on a combined portfolio, including eligible positions at GSD and future contracts.

These tools can be used collectively by traders to calculate all available margins across multiple accounts using portfolio management to offset trades, which helps with capital efficiencies, alongside helping reduce the need for unnecessary position liquidation.

“Our risk management team is focused on creating new capabilities that support greater transparency for market participants. These enhancements represent a significant step forward to better understanding and managing members’ obligations while ultimately safeguarding the Treasury Market,” said Tim Hulse, managing director, financial risk and governance at DTCC.

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The calculator enables participants to evaluate potential margin and clearing fund obligations associated with becoming a member of DTCC’s Fixed Income Clearing Corporation (FICC) Government Securities Division (GSD).

With the amount of US Treasury clearing activity processed through FICC expected to rise by $4 trillion daily following the SEC’s expanded clearing mandate which will be implemented in 2025 and 2026, DTCC’s calculator will be a key tool for firms to determine VaR and potential margin obligations for any simulated portfolio.

“VaR is a widely used risk management concept in the financial services industry and is the primary component of GSD’s clearing fund requirements,” said Tim Hulse, managing director, financial risk and governance, at DTCC.

“The calculator considers factors such as historical data, volatility and confidence levels to estimate VaR, increasing market transparency.”

Using FICC’s VaR methodology, the new calculator will offer the opportunity for participants to calculate potential margin obligations on a simulated portfolio, for given positions and market value.

“FICC understands the urgency and importance of evaluating firms’ risk exposure associated with the expansion of US Treasury Clearing. The VaR calculator provides market participants with increased transparency into these obligations,” added Hulse.

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With the size of transactions in the US Treasury market now exceeding $7 trillion daily, CCLF is will serve as a risk management tool used for managing FICC’s liquidity risk linked to settlement activity.

Participants will be able to input their current settlement activity into the calculator to estimate and understand the CCLF-related liquidity obligations that could arise from membership, DTCC said.

CCLF is a rules-based liquidity resource facility able to offer FICC additional liquid financial resources to meet its cash settlement requirements in the event of a default of the largest Government Securities Division (GSD) family of affiliated netting members.

Ahead of potential funding needs, GSD netting members can include their determined CCLF obligation amounts into their own liquidity plans.

Although the CCLF obligation is a committed obligation for the netting members, does not require pre-funding or deposits of the obligation amount are not required by FICC.

Netting members instead provide up-front attestations linked to their ability to provide such CCLF amounts as an ongoing FICC membership requirement.

“By providing the public CCLF calculator, we continue to increase transparency into our financial risk management program, empowering potential members to understand their role and obligations as a FICC GSD member,” said Tim Hulse, managing director, financial risk and governance at DTCC.

“CCLF provides a critical backstop to address the financial impact of volatility and stress across repo markets while safeguarding the industry and individual members.”

The CCLF calculator requires a range of data points to be provided by users. Once provided and entered on screen, the calculator processes the data points using the existing GSD CCLF engine logic, which then provides an estimated individual CCLF obligation.

“FICC recognizes that many firms are considering membership with GSD to comply with the final SEC rule on expanded clearing of US Treasury activity,” said Claire Lough, executive director, financial risk and governance at DTCC.

“This calculator will enable market participants to simulate their potential CCLF obligations to assist in understanding what is required of a GSD Netting Member.”

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The new service will bring OTC cash equities trades into Cboe Clear Europe’s cleared environment, which can then be netted against on-exchange transactions for settlement purposes.

Creating a link between DTCC’s Institutional Trade Processing (ITP) central matching service, CTM, makes up the first part of the joint initiative. Subject to regulatory approvals, this is projected to go live in Q2 of next year.

Cboe Clear Europe will be the first CCP to connect to CTM.

“This joint solution enables us to bring greater efficiencies to our clients, helping to optimise their current post-trade workflows and operational processes as the global financial markets look to accelerate settlement cycles,” said Vikesh Patel, president, Cboe Clear Europe.

As part of the initiative, DTCC and Cboe Clear Europe each intend to develop a proof of concept that links Cboe Clear Europe with the tri-party trade matching workflow of CTM.

Prime brokers will receive a golden copy of transaction details when a match is achieved between a hedge fund and executing broker via DTCC’s CTM service. CTM could then automatically send matched trades to the CCP, providing netting and clearing benefits to Cboe Clear Europe and DTCC’s mutual clients.

The pair claim the new workflow could help reduce settlement and operational risk and will help facilitate a reduction in capital requirements when moving from OTC to CCP settlement, as well as lower trade fails and defaults.

“We are pleased to be working with Cboe Clear Europe on this important initiative to bring greater post-trade efficiencies to the industry as the global markets look to accelerate to a T+1 settlement cycle,” said Val Wotton, managing director and general manager, DTCC Institutional Trade Processing.

“Cboe Clear Europe’s extensive venue coverage combined with CTM’s large client base will deliver increased operational efficiency and netting opportunities across European trading venues.”

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The lack of major issues and positive data signals on affirmation and fail rates will come as a huge sigh of relief to the industry, which is benefitting from an over-preparedness strategy and its highly alert, round-the-clock ‘war room’ and ‘command centres’.

“It was very smooth and someone in our office likened it to Y2K, which I took umbrage with because I think the reason it was smooth was because the industry got its act together and made sure that everybody knew what they had to do and when they had to do it. I think that really folded into a very smooth transition,” said one operations executive from an asset manager, speaking on the T+1 War Rooms initiative launched by The TRADE’s sister publication, Global Custodian. 

“We don’t often get the chance to pat ourselves on the back, so you might as well take this opportunity.” 

Another buy-side source said: “I think as much as we can make a joke that it was kind of a non-event, that shouldn’t take away from the planning, preparation, full scale project teams that went on for a year or so beforehand.”

For such a far-reaching market structure change however, the true measure of success will be measured in weeks and months – not just for affirmation and fail rates, but across geographies, client types and adjacent functions such as ETFs, FX and securities lending. Further tests will also arise through upcoming public holidays and market participants exiting this phase of ‘hyper focus’ on the matter.

“It’s more the longer-term items of extending settlement stress testing, your custodian’s ability to afford you an overdraft, seeing what the claims do in this quarter compared to last quarter,” said another asset manager on the discussion being held under Chatham House rules. “It’s not the day-to-day so much now, but more those rainy-day scenarios and seeing how the market reacts to that along with your custodian and your counterparts.” 

What the data says so far

The first three days saw incrementally increasing affirmation rates – 92.76%, 94.55% and 94.66%, respectively – while fail rates stayed consistent with those seen in a T+2 environment over day one and two. However, affirmations then dipped to 91.26% on day four, while fails saw an uptick over days three and four.

What is important to remember though, is that within the opening week there was both a double settlement day – whereby T+2 and T+1 transactions were settling together – along with the MSCI rebalancing, an event which many believed would be a stumbling block for the new operational setup for US equities.   

What the data for Monday 3 June has shown us is that the affirmation rates jumped back up to 93.65%, while fail rates were the lowest since the transition. Despite this, Reuters, Bloomberg and Financial News quickly jumped on the spike in fail rates through alarmist headlines on 31 May. One day of fail rates is not indicative however, especially when that day coincided with a major market event – in this case the MSCI rebalancing on 31 May. Many market experts look at monthly, or three-monthly averages, for an indication.

Outside of the quantitative data, the feedback both on the record and behind closed doors from the securities industry has been overwhelmingly positive. 

One source at a leading custodian said that the double settlement date didn’t cause issues despite an increase in trades requiring repair and a notional increase. Meanwhile, they noted the MSCI rebalance saw a 50% increase in volumes, but – again – no concerns and it “all went smoothly”. 

In addition, SEC chair Gary Gensler, along with the DTCC and SIFMA, were quick to herald the transition a success.  

What else we’re hearing 

The data right now is so positive that fail rates on certain days are eclipsing those seen in a T+2 environment, however it’s almost inevitable that this purple patch will have days – and weeks, even – where it comes crashing down. 

A survey by The ValueExchange in January saw market participants predict the fails rate would eventually rise to 4.1%, so could we be seeing a temporary quiet before the storm? 

“Most have put in place contingency support to deal with the switchover but that isn’t a long-term solution – and the more markets that move to T+1, the more pressure there will be to move away from manual and batch-based processing,” said Virginie O’Shea, founder and CEO of Firebrand Research. “The costs are higher than anticipated too due to the service providers charging for lending and overdraft facilities for funding support.”  

Two tests have been passed thus far, but what would a spate of market volatility mean for participants? We have already seen spikes in fails during turbulent markets, and with so many elections on the near horizon – along with upcoming public holidays – it’s not out of the question to foresee some tough market conditions – which could serve as a true measure of industry readiness around T+1. 

In addition, we should begin to hear reports of how parallel functions are faring. CLS has said it will monitor the impact of the shift to T+1 and make assessments in both June and September through “temperature checks”. 

“It’s difficult to ascertain exactly what might be related to T+1, because we don’t have that level of detail, but we can look around certain parameters. If we found that actually volumes and values stay exactly the same, then we can safely assume that the impact has been negligible. Obviously, if impacted volumes are much higher than expected we’ll reassess it sooner,” Lisa Danino-Lewis, chief growth officer at CLS told The TRADE and Global Custodian earlier this year. 

In addition, the impacts on securities lending will be one to watch – along with how the ETF markets have adjusted. There may also be some impacts on corporate actions which soon come to light. 

“The real test is the test of time,” said one custodian, speaking under the condition of anonymity. “We will continue to monitor affirmation rates, settlement rates, non-STP trades and funding changes to ensure the initial behavioural partners maintain into BAU processing.”

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According to the survey conducted by DTCC across 83 sell-side institutions, daily activity on its Fixed Income Clearing Corporation (FICC) will see an increase of $4 trillion as a result of the regulatory change – thanks in large part to new stipulations around mandatory central clearing.

The prediction is up from a previous estimate of $1.63 trillion, reached as part of a prior industry consultation.

“Given the SEC’s rules around mandatory central clearing are now final and the industry’s understanding of their impact is becoming clearer, it is not surprising to us to see the incremental volume estimates hardening around $4 trillion daily,” said Brian Steele, DTCC managing director, president, clearing and securities services.

“While expanding Treasury clearing will be an important structural change for all Treasury market participants, we view it as a logical expansion of the services we provide and consistent with FICC’s mission.”

Steele confirmed that DTCC currently processes roughly $7 trillion in Treasury activity each day, adding that DTCC’s buy-side ‘sponsored service’ had seen volumes increase by 70% year on year.

“We expect these growth trends to steadily continue as we move toward go-live for the expanded Treasury Clearing requirement,” he added.

DTCC highlighted “done-away activity” as a key area of discussion as a result of the new SEC rules. Done away activity relates to US Treasury activity that is executed by a client using one counterparty but then cleared by a different counterparty.

According to DTCC’s survey, around a third of sell-side institutions said they plan to offer US Treasury clearing activity out of their prime brokerage, agency clearing or futures commission merchant business (FCM) business lines.

First announced in December last year, the SEC’s new rules are designed to enhance risk management practices for central counterparties in the US Treasury market and facilitate additional clearing of securities transactions in this market segment.

Under the new rules covered clearing agencies in the US Treasury market are required to adopt policies that ensure their members submit for clearing certain specified secondary market transactions.

Subject to conditions, the amendments also permit broker-dealers to include customer margin required and on deposit at a clearing agency in the US Treasury market as a debit in the customer reserve formula. The amendments also require covered clearing agencies to separately collect and calculate margin for house and customer transactions.

The new rules also set out that policies and procedures must be designed to ensure that the covered clearing agency has appropriate means to facilitate access to clearing. The new rule includes an exemption for transactions where the counterparty is a central bank, sovereign entity, international financial institution, or natural person.

The amendments will go into effect in two phases. The changes regarding the separation of house and customer margin, the broker-dealer customer protection rule, and access to central clearing required to be completed the end of March 2025.

“The $26 trillion Treasury market — the deepest, most liquid market in the world — is the base upon which so much of our capital markets are built,” SEC Chair Gary Gensler said in a statement in December. “Having such a significant portion of the Treasury markets uncleared — 70 to 80 percent of the Treasury funding market and at least 80 percent of the cash markets — increases system-wide risk.”

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The rate increased from 92.76% on the first day of T+1. 

In addition, settlement fails appear not to have spiked yet, with the percentage still under 2% over the first two days of the new setup. 

According to the data from DTCC, CTM Allocations Rate by 7PM ET also rose above 99%.  

Overall, there appears to have been no major issues across the first two days of T+1 settlement for US equities, however Global Custodian reported yesterday that DTCC had experienced system issues within its DTC and NSCC night cycle processing on the first day of T+1. 

The issue was described by sources as having minor impact and is in line with ‘expected teething issues’ anticipated by the US market infrastructure.  

DTCC has issued a notice to market participants that a system issue had occurred, but according to sources at a number of custodians, transactions were still processed in accordance with the DTCC deadlines for settlement.

The processing delays were subsequently resolved.  

Elsewhere, Global Custodian also revealed that Canadian exchange TMX had some minor system issues on its first night of T+1, which was one day prior to its North American neighbour.  
 
“We experienced some isolated intra-day processing delays on Monday, 27 May, and undertook measures to address the issue,” a TMX spokesperson said. “All key and critical functions have been operating as normal. CDS continues to prioritise communication with participants during the transition.” 

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The issue was described by sources as having minor impact, and is in line with ‘expected teething issues’ anticipated by the US market infrastructure.

DTCC has issued a notice to market participants that a system issue had occurred, but according to sources at a number of custodians, transactions were still processed in accordance with the DTCC deadlines for settlement.

The processing delays were subsequently resolved.

Following the affirmation process under T+1, trades are sent from DTCC’s ITP service to DTC and NSCC for processing in DTC’s night cycle batch  process. The process starts on the evening of trade date at 11:30 PM ET and runs for two hours.

In addition, Global Custodian understands that affirmation rates were 92.76%, topping the DTCC’s target rate of 90%.

Last week, for the week ending 18 May 2024, 87.92% of transactions were affirmed by the DTC cut-off time of 9:00 ET on trade date.

In addition, Global Custodian understands that affirmation rates were 92.76%, topping the DTCC’s target rate of 90%.

Last week, for the week ending 18 May 2024, 87.92% of transactions were affirmed by the DTC cut-off time of 9:00 ET on trade date.

Global Custodian also understands Canadian exchange TMX had some minor system issues on its first night of T+1, which was one day prior to its North American neighbour.

“We experienced some isolated intra day processing delays on Monday, 27 May, and undertook measures to address the issue,” a TMX spokesperson told The TRADE. “All key and critical functions have been operating as normal. CDS continues to prioritise communication with participants during the transition.”

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Val Wotton

Specifically, Sumitomo is aiming to boost its trade processing through leveraging ITP’s central trade matching (CTM) platform which includes Match to Instruct (M2i) workflow. 

The asset manager is also set to fully automate the post-trade processing and develop its same day affirmation capabilities for cross-border transactions within APAC by leveraging TradeSuite ID, ALERT and Settlement Instruction Manager (SIM).

Yosuke Hosokawa, associate general manager at Sumitomo Mitsui Trust Asset Management, highlighted the relevance in the lead up to the settlement shift: “It is important that financial markets outside the US leverage automation to enable straight through processing and align with global standards. We are happy to collaborate with the wider industry to bring accelerated settlement to our clients.”

Sumitomo Mitsui Trust is the first Japanese asset manager to adopt the ITP services through Nomura Research Institute’s (NRI) SmartBridge Advance – the collaborative offering built in partnership by DTCC and NRI.

In addition, Japanese regulators require specifically appointed trust banks to oversee the trading activities of their underlying investment managers’, as well as being included in the pre-settlement, post-trade communications chain. With this in mind, DTCC’s SIM facilitate this and enables the “soto-soto” arrangement, helping to enable the T+1 settlement within the APAC region.

Val Wotton, managing director and general manager, DTCC ITP, said: “We are pleased to partner with Sumitomo Mitsui Trust Asset Management to bring best practice capabilities that enable accelerated settlement in the region. As we look toward the US move to T+1, achieving faster time to settlement for both cross-border and domestic transactions is more important than ever.

“ITP’s suite of services is uniquely positioned to enable counterparties to reach settlement finality faster while seamlessly connecting them to thousands of counterparties around the world.”

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