On February 9, 2022, the SEC proposed rules that would shorten the securities transaction settlement cycle from the current T+2 standard to T+1. Speculation had increased in the past 12-18 months that a rule proposal would be forthcoming, given the exposure risk realized in early 2020 at the beginning of the COVID-19 pandemic, and in early 2021 when “meme stock” activity drove large amounts of volatility, both of which were specifically cited by the SEC in its discussion of the proposed rules. If adopted, the SEC expects that compliance with the shortened settlement cycle and other associated rule proposals would be required by Q1 2024. In addition to soliciting comments on the proposed T+1 settlement cycle and related rule amendments, the SEC requested comments regarding reaching a same-day, or T+0, settlement cycle, noting that it is something that the SEC is “actively assessing.” The public comment period will remain open for 60 days following publication of the proposing release on the SEC’s website or 30 days following publication of the proposing release in the Federal Register, whichever period is longer.

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