Settlement & Clearing

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Many individual investors were introduced to market structure anomalies because they had their “buy button turned off.” This was a multi-level failure of our complex market structure, from under-capitalized clearing brokers to flawed margin calculation cycles. It exposed an underbelly of markets that has remained opaque for too long, and has left many investors questioning the very heart of our markets and whether they actually own the shares that they have purchased. Current regulatory disclosures are inadequate to give the public confidence in the system, and inadequate to police systematic abuse of the system.

key issues

  • FTD Visibility: Failure To Deliver disclosures need to be updated more often, and include more information, including how and when FTDs are remediated, what type of counterparty is responsible for the failure (bucketed into clearing broker, exempt market maker or custodian), and how long the FTDs remained open.
  • Margin Transparency: Investors need visibility about estimated margin per security for Clearing Brokers.
  • Netting Transparency: Investors need disclosure of gross versus net notional or share count per security to help understand trading dynamics and discern the level of real investment versus intraday trading activity.

opportunities for advocacy

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