Investment Services Regulatory Update - September 2017

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Market and Product Developments -

Securities Industry Implements T+2 Settlement Cycle -

On September 5, 2017, the securities industry transitioned to a shorter settlement cycle for most broker-dealer securities transactions, pursuant to amendments to Rule 15c6- (a) under the Securities Exchange Act of 1934 adopted by the SEC in March 2017. As noted in a comment letter from the Investment Company Institute, the move from three business days after the trade date (i.e., T+3) to two business days after the trade date (i.e., T+2) for the standard settlement cycle reduces the timing mismatch and funding gap between settlement of a mutual fund’s portfolio security trades and the settlement of transactions in the shares of the mutual fund itself (which generally settle on a T+1 basis), improving cash management for funds to meet redemptions.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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