SEC Places Short Order for T+1: But Insurance Products Mostly Off the Menu
These amendments will require numerous entities — which may include broker-dealers, clearing organizations, investment companies, and investment advisers — to make various changes to their methods of operation, systems, relevant agreements and disclosures, and/or certain SEC filings. For some firms, these changes will require substantial time and resources, and concerns are being expressed that some firms may not be ready by the May 28, 2024, deadline by which the SEC is requiring that T+1 be implemented. Indeed, the SEC’s two Republican commissioners dissented from the SEC’s adoption of these amendments, fearing that not all required operational changes could be adequately implemented in time. Instead, they, like some industry commenters on the proposal, argued (unsuccessfully) for an effective date of September 3, 2024.
Given these concerns, firms are having to promptly determine what, if any, steps they must take to comply with these amendments and plan accordingly. Moreover, the SEC examination staff during the coming year will likely be asking questions about the status of firms’ preparations in this regard.
Importantly, however, the SEC left in place a 1995 order that will exempt transactions in most variable annuities, variable life insurance, and other insurance products that are registered as securities from the new one-day requirement (as that order now exempts them from the current two-day requirement).
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