The discussion around CSDR implementation has focused largely on how the banks, custodians and asset managers are preparing, but the clock is also ticking for the CSDs as they finalise their plans ahead of implementation a year from now.
Those CSDs using TARGET2-Securities (T2S) to record their positions and settle their participants’ transactions have collectively agreed with the European Central Bank that the platform will form part of the solution. T2S will support the CSDs in their CSDR obligations by calculating the penalties for all in-scope securities and reporting them to the CSDs who will, in turn, process them and distribute to their own participants. The CSDs stay in control of their participant relationships and are accountable for their obligations. The DCPs (Directly Connected Parties) will receive their own reports from T2S.
But what about the assets CSDs hold outside of the T2S platform that are also in scope for CSDR – how are these to be reconciled under the new regime? And with T2S calculating penalties on each of its settlement days, irrespective of local variations in individual CSD operating days, how will they address the penalties that are calculated on those additional dates and their removal after the fact?
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