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Are you ready for T2S? - Euroclear

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<strong>Are</strong> <strong>you</strong> <strong>ready</strong><br />

<strong>for</strong> <strong>T2S</strong><br />

Edwin De Pauw looks at<br />

the many questions firms<br />

are facing and how best<br />

to prepare <strong>for</strong> TS<br />

Edwin De Pauw,<br />

Director, <strong>T2S</strong> Product Management, <strong>Euroclear</strong>


<strong>Euroclear</strong> considers<br />

the options that market<br />

participants are considering in<br />

the run-up to <strong>T2S</strong>.<br />

<strong>Are</strong> <strong>you</strong> <strong>ready</strong><br />

By Edwin De Pauw, <strong>Euroclear</strong><br />

Target2-Securities (<strong>T2S</strong>) is scheduled to go live in about two years, with the first migration<br />

wave <strong>for</strong> central securities depositories (CSDs) planned <strong>for</strong> June 2015. In<strong>for</strong>mation from the<br />

ECB regarding the timing of the waves is common knowledge. However, banks and other<br />

financial institutions have yet to take many <strong>T2S</strong>-related decisions that could have a significant<br />

impact on how effectively they will work in the changing post-trade environment in Europe.<br />

Making the most of <strong>T2S</strong><br />

<strong>T2S</strong> offers opportunities to centralise liquidity and reduce the cost of cross-border settlement.<br />

Along with <strong>T2S</strong>, removal of the repatriation rule <strong>for</strong> collateral mobilisation to central banks will<br />

allow firms to post collateral from any qualifying CSD to a central bank of their choice.<br />

As if preparing <strong>for</strong> <strong>T2S</strong> was not enough, new regulations will also have an impact on<br />

financial institutions. Basel III, EMIR, AIFMD/UCITS are but a few examples. Meeting these<br />

challenges while confronted with continuous cost-containment pressures will <strong>for</strong>ce some<br />

in the securities industry to either exit the business or develop new business models. Some<br />

will go up the value chain, while others will turn to partners to deliver part of their service<br />

portfolio. We also expect further consolidation among CSDs, although we may see the<br />

arrival of new CSDs initially.<br />

The right way <strong>for</strong>ward<br />

So, how should a financial institution approach <strong>T2S</strong> The first and perhaps most obvious<br />

assessment to be made should be how <strong>T2S</strong> is likely to impact their day-to-day business. The<br />

conclusions will, of course, differ depending on the current business and operating models<br />

of the financial institution. However, we believe thinking should focus on three areas.<br />

First is to assess the impact of mandatory changes generated by <strong>T2S</strong> such as mandatory<br />

trade matching and settlement lifecycle management in some markets following the<br />

introduction of a ‘hold and release’ mechanism. Second is to evaluate the impact of the<br />

timing and breadth of the various harmonisation initiatives encompassing corporate actions,<br />

market claims and the like. Last but not least is to consider the opportunities created by <strong>T2S</strong><br />

to centralise liquidity, review/rationalise the firm’s network strategy, extend services to cover<br />

more markets, exit non-profitable markets, among other possibilities.<br />

Institutions that have direct CSD relationships today may choose to make the mandatory<br />

changes now and consider how best to access <strong>T2S</strong> once they can assess the true benefits of<br />

<strong>T2S</strong>. They may wind up paying twice, but they will manage the uncertainties of <strong>T2S</strong> better.<br />

Another option is to anticipate the benefits of <strong>T2S</strong> and make the necessary changes up front to<br />

access <strong>T2S</strong> in all or some CSD-direct markets, with the risk that the benefits will not materialise<br />

at the same pace as the investments. This option, we believe, will be most relevant to firms that<br />

have direct relationships with multiple CSDs as it will reduce the need <strong>for</strong> multiple adaptation<br />

projects. A new option that may be appealing to these firms is to work through a single ‘investor<br />

CSD’ to access all or some <strong>T2S</strong> markets, rather than maintaining multiple CSD relationships.<br />

2 <strong>Are</strong> <strong>you</strong> <strong>ready</strong>


An ‘investor CSD’ enables its clients to hold<br />

pan-European assets on its books based on<br />

links established with the CSDs where the<br />

securities have been issued. The option of<br />

selecting an investor CSD removes a large<br />

part of the operational burdens associated<br />

with maintaining multiple CSD (or multiple<br />

custodian/agent) relationships. It can also<br />

eliminate the need to develop in-house<br />

expertise to provide collateral management<br />

and other asset services <strong>for</strong> client holdings<br />

of <strong>for</strong>eign assets.<br />

The thinking process will be different <strong>for</strong><br />

firms that have indirect CSD relationships<br />

today. Clearly, the introduction of <strong>T2S</strong> is<br />

an opportunity to review and potentially<br />

rationalise their current network of service<br />

providers. Perhaps one of their current<br />

providers can shield them from having to<br />

make the changes associated with <strong>T2S</strong>,<br />

thereby limiting the need to make changes.<br />

Success will depend on the firm’s ability to<br />

capture the right business opportunities while<br />

keeping costs under control to profit from<br />

them. Let’s not underestimate this important<br />

part of the decision-making process.<br />

Here, <strong>T2S</strong> poses a considerable challenge.<br />

<strong>T2S</strong> implementation costs will be huge.<br />

Market infrastructures, <strong>for</strong> example, will<br />

spend €1 billion in addition to the €1 billion<br />

to be spent by the European Central Bank.<br />

Thus, the balance between pursuing the<br />

<strong>T2S</strong> business case versus other business<br />

objectives, such as cost containment, will<br />

be an individual firm decision.<br />

Key decision criteria<br />

Firms considering how best to connect to<br />

<strong>T2S</strong> and work with a partner to service<br />

multi-market <strong>T2S</strong>-eligible assets will need<br />

to match their business needs with their<br />

capacity and internal resources. The<br />

thinking process also will be influenced by<br />

cost and risk issues, the firm’s perceptions of<br />

<strong>T2S</strong> benefits, underlying client expectations<br />

and central bank requirements.<br />

When considering the best approach,<br />

including the choice of a partner, the key<br />

criteria to consider during the thinking<br />

process are as follows:<br />

• Service level/market coverage: What<br />

service/support levels do <strong>you</strong> expect<br />

from the partner Which markets do<br />

<strong>you</strong> wish to cover Where are <strong>you</strong>r<br />

counterparties likely to be located<br />

Can the provider meet <strong>you</strong>r settlement,<br />

asset servicing, liquidity and collateral<br />

management obligations <strong>for</strong> <strong>you</strong>r<br />

domestic and cross-border activities<br />

• Access to liquidity: Do <strong>you</strong> have access<br />

to euro central bank money or do<br />

<strong>you</strong> want to rely on a commercial<br />

credit provider Can the provider give<br />

<strong>you</strong> access to liquidity in each of the<br />

markets <strong>you</strong> want to cover<br />

• Risk protection: Which type of business<br />

partner will provide the best and most<br />

comprehensive asset protection to<br />

enable <strong>you</strong> to comply with increasingly<br />

strict regulation Which provider will<br />

best meet <strong>you</strong>r liabilities requirements<br />

• All-in cost: Does the provider offer<br />

fee-related economies of scale and<br />

have low running costs Which<br />

provider can best shield <strong>you</strong> from<br />

current and future investment costs<br />

Firms that al<strong>ready</strong> work with ICSDs, agent<br />

banks and other intermediaries have a head<br />

start on others that need to begin a due<br />

diligence study to select the right partner.<br />

Time-to-market<br />

management<br />

Time-to-market will be critical when<br />

considering the above questions. Financial<br />

institutions will need to have made all the<br />

mandatory <strong>T2S</strong>-related changes - or have<br />

appointed a partner to share the burden<br />

- to be able to keep their ‘licence to<br />

operate’. Equally important, they will need<br />

to be <strong>ready</strong> to defend their competitive<br />

position and take advantage of business<br />

growth opportunities.<br />

These challenges are intensified by<br />

uncertainties relating to the timing and<br />

breadth of market-practice harmonisation<br />

initiatives and the timeline <strong>for</strong> removal of<br />

the remaining legal and fiscal barriers.<br />

Roughly speaking, during the summer of<br />

2013, firms will need to propose budgets<br />

<strong>for</strong> 2014 to start their <strong>T2S</strong> development<br />

work, even though insufficient in<strong>for</strong>mation<br />

will be available to take final decisions on<br />

market coverage, precise service offerings<br />

and pricing.<br />

We expect that most critical decisions will<br />

need to be taken in 2014/2015. By then,<br />

most in<strong>for</strong>mation will be available <strong>for</strong> firms<br />

to decide definitively if and how they intend<br />

to evolve their business model and service<br />

portfolio. They will also know what budget<br />

will be necessary to fulfil their ambitions.<br />

Flexibility in this changing environment will<br />

be important as we expect more technical<br />

and operational changes to come be<strong>for</strong>e<br />

the first <strong>T2S</strong> ‘go-live’ date.<br />

Is outsourcing an option<br />

As settlement becomes a commoditised<br />

service, more firms may consider selfsettlement.<br />

However, partnering with<br />

experts in asset servicing and collateral<br />

management can be a wise decision.<br />

On the asset servicing side, it is fair to say<br />

that except <strong>for</strong> the Belgian, Dutch and<br />

French markets, which al<strong>ready</strong> operate on<br />

a single plat<strong>for</strong>m with harmonised market<br />

practices, other European markets have yet to<br />

harmonise to a common European standard.<br />

Many financial institutions al<strong>ready</strong> work<br />

with agent banks, multiple CSDs and<br />

ICSDs to bridge these market practice<br />

gaps. As said earlier, <strong>T2S</strong> will provide the<br />

<strong>Are</strong> <strong>you</strong> <strong>ready</strong> 3


opportunity to rationalise and examine<br />

the need <strong>for</strong> large intermediary networks.<br />

That said, we are convinced that many<br />

banks and other financial institutions will<br />

continue to appoint an agent or ICSD<br />

to help them access multiple European<br />

markets and beyond because it simply<br />

makes good business sense.<br />

Market infrastructures are opening their<br />

architecture to extend their plat<strong>for</strong>ms and<br />

operational expertise, to eliminate the need to<br />

create what al<strong>ready</strong> exists. Market participants<br />

benefit from additional economies of scale<br />

and cost mutualisation opportunities.<br />

Where are <strong>you</strong><br />

Let’s look at how different business<br />

segments could consider their options.<br />

Custodian businesses may want to hold<br />

securities in or as close to the ‘issuer<br />

CSD’ as possible and want to centralise<br />

their central bank money liquidity <strong>for</strong> all<br />

<strong>T2S</strong> markets. Those custodians might<br />

be looking <strong>for</strong> a provider that offers<br />

direct access to CSDs and central bank<br />

money liquidity, and highly competitive<br />

settlement, asset servicing and collateral<br />

management services.<br />

the options <strong>for</strong> their own activity and<br />

assets, but <strong>for</strong> their underlying clients as<br />

well, some of which are al<strong>ready</strong> insisting<br />

on segregated account structures. Global<br />

custodians and ICSDs have worked handin-hand<br />

<strong>for</strong> decades and we suspect this<br />

will continue in a <strong>T2S</strong> environment. In fact,<br />

we are seeing many partnerships between<br />

global custodians and <strong>Euroclear</strong> Bank <strong>for</strong><br />

collateral management services in the<br />

run-up to <strong>T2S</strong>.<br />

Broker-dealer businesses will require a<br />

top-class service to ensure high settlement<br />

efficiency, very rapid turn around time,<br />

wide access to trading counterparties<br />

and seamless access to financing through<br />

efficient collateral management services.<br />

Depending on settlement activity scale and<br />

breadth, inhouse expertise and capacity,<br />

self-settlement at the launch of <strong>T2S</strong> or<br />

thereafter may be appealing.<br />

It may be necessary to have direct CSD<br />

access <strong>for</strong> certain markets, with a provider<br />

that can manage CSD relationships <strong>you</strong><br />

choose not to manage <strong>you</strong>rself. It would<br />

be important to select a partner that can<br />

evolve with <strong>you</strong>, without imposing sizeabe<br />

transition costs, to manage <strong>T2S</strong>-related<br />

uncertainties, such as the level of CSD<br />

interoperability that will need to evolve.<br />

to benefit from <strong>T2S</strong>. Nevertheless, there<br />

are some crucial decisions that are al<strong>ready</strong>,<br />

or should be, under consideration by<br />

securities professionals.<br />

We are confident that <strong>Euroclear</strong> can<br />

accommodate any <strong>T2S</strong> scenario that<br />

securities professionals decide is the best<br />

<strong>for</strong> them in this changing environment.<br />

There is no other group of CSDs in Europe<br />

that will be as connected to <strong>T2S</strong> as <strong>you</strong><br />

will find at <strong>Euroclear</strong>, as <strong>Euroclear</strong> Belgium,<br />

<strong>Euroclear</strong> Finland, <strong>Euroclear</strong> France and<br />

<strong>Euroclear</strong> Nederland will all be migrating<br />

to <strong>T2S</strong>. Each of them will provide entry to<br />

<strong>T2S</strong>, with a range of relevant services. Easy<br />

access to non-<strong>T2S</strong> markets, such as the UK<br />

and Eurobond markets, also need to be<br />

brought into the picture.<br />

<strong>T2S</strong> time-to-market is fast approaching.<br />

Deciding <strong>you</strong>r way in, and how much<br />

ef<strong>for</strong>t it will take, is clearly an agenda item<br />

<strong>for</strong> 2013.<br />

This article is reprinted with the kind<br />

permission of International Securities<br />

Services magazine.<br />

Global custodians will be attracted by the<br />

largest pools of liquidity. <strong>T2S</strong> is unlikely to<br />

change this fact, although it remains to be<br />

seen whether <strong>T2S</strong> will - drastically - change<br />

the location of liquidity pools <strong>for</strong> some<br />

domestic securities.<br />

For example, in certain <strong>T2S</strong> markets such<br />

as France, liquidity is to be found locally,<br />

encouraging those firms that are active in<br />

French securities to have direct access to<br />

the local issuer CSD. In other cases, such<br />

as German bunds, a significant part of<br />

Bund trading activity settles on the books<br />

of <strong>Euroclear</strong> Bank, the ICSD.<br />

Global custodians will not only consider<br />

Firms that today specialise in a given<br />

domestic market and look to target<br />

non-domestic business growth<br />

opportunities will want to leverage their<br />

domestic CSD relationship in order to<br />

access and service other <strong>T2S</strong> market<br />

securities. While not wanting to have<br />

direct CSD relationships in all markets, they<br />

may consider an ‘investor CSD’ approach.<br />

Partnering on the <strong>T2S</strong><br />

journey<br />

With differing business objectives and<br />

priorities, there is no ‘one-size fits all’<br />

solution <strong>for</strong> the many avenues of approach<br />

© 2013 <strong>Euroclear</strong> SA/NV – 1 Boulevard du Roi Albert II, 1210 Brussels, Belgium – Tel: +32 (0)2 326 1211 – www.euroclear.com –<br />

RPM Brussels number 0423 747 369 – <strong>Euroclear</strong> is the marketing name <strong>for</strong> the <strong>Euroclear</strong> System, <strong>Euroclear</strong> plc, <strong>Euroclear</strong> SA/NV and<br />

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and services that may be of interest to <strong>you</strong>, please contact us at Data_Protection_Officers@euroclear.com and specify on what product<br />

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www.euroclear.com

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