FINRA published Regulatory Notice 17-19, detailing changes to FINRA rules to conform them to the SEC's amended Exchange Act Rule 15c6-1(a) (see previous coverage), which shortens the standard settlement cycle for securities transactions from three business days after the trade date (T+3) to two (T+2). The FINRA rule changes will become effective on September 5, 2017.

FINRA rules that will be changed include Rules 2341 ("Investment Company Securities"), 11140 ("Transactions in Securities 'Ex-Dividend,' 'Ex-Rights' or 'Ex-Warrants'"), 11150 ("Transactions 'Ex-Interest' in Bonds Which Are Dealt in 'Flat'"), 11210 ("Sent by Each Party"), 11320 ("Dates of Delivery"), 11620 ("Computation of Interest"), 11810 ("Buy-in Procedures and Requirements"), and 11860 ("COD Orders").

Commentary / Steven Lofchie

Firms should be mindful of procedures that will be affected by the shortening of the settlement cycle, which will not be limited to the rules listed above. For example, the margin timing requirements also will be impacted.

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