EBF members feel that this solution would facilitate the proper receipt of full and correct details of all individual penalty items by participants, while giving them sufficient time to reconcile Monthly Net Amounts with the individual penalty items captured on the daily reports.
      
    
    
      The EBF  supports the proposal made by the Association for Financial 
Markets in Europe (AFME) at the invitation of the Advisory Group on 
Market Infrastructures for Securities And Collateral (Ami-SeCo) of the 
European Central Bank (ECB) to set out temporary changes to the 
month-end processing timetable for CSDR late settlement penalties in 
order to mitigate and manage problems and delays registered by market 
participants in the context of the live phase started on February 1st, 2022.
Proposed timetable for the month-end process for CSDR penalties
| Process | 
Current Timetable | 
Proposed Extension | 
| Last Date for participants to raise appeals to CSD | 
14th March | 
28th March | 
| Last Date for CSD to report adjustments to participants | 
17th March | 
30th March | 
| Reporting of Monthly Net Amount | 
18th March | 
31st March | 
| Collection/Redistribution of Monthly Net Amount | 
23rd March | 
13th April | 
AFME proposes an extension of:
- An additional 9 business days to the window for further adjustments 
to be made by CSDs in response to issues raised by participants, before 
the Monthly Net Amount (MNA) is reported.
 - An additional 6 business days to the window between reporting of the MNA and collection/redistribution of the MNA.
 
EBF  members feel that this solution would facilitate the proper 
receipt of full and correct details of all individual penalty items by 
participants, while giving them sufficient time to reconcile Monthly Net
 Amounts with the individual penalty items captured on the daily 
reports.
EBF  members trust that this proposal may be rapidly considered by all
 relevant stakeholders, including, in particular, market infrastructures
 and securities regulators, and that market participants may receive 
further clarity as soon as possible concerning the appropriate way 
forward.
Finally, the EBF  remains committed to supporting  the full 
implementation of CSDR settlement discipline rules for the benefit of 
better integrated, efficient and transparent capital markets in Europe.
EBF
      
      
      
      
        © EBF
     
      
      
      
      
      
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